The Reassigned Numbers Database (RND or Database) is an important part of the Federal Communications Commission’s (FCC’s) multi-pronged approach to addressing the problem of unwanted calls. When a telephone number is reassigned, callers may inadvertently reach the new consumer (who now has the reassigned number) rather than who they intended to call (the number’s prior owner). These calls can be annoying to the recipients who do not want to receive them and can subject callers to liability under the Telephone Consumer Protection Act (TCPA). The FCC defined a safe harbor from potential TCPA liability for callers that can demonstrate that they appropriately checked the most recent update of the database.
There are generally two types of users of the Reassigned Numbers Database (RND)— those that query data in the RND (Callers) and those that submit data into the RND (Service Providers). Callers and Service Providers may appoint RND Registered Agents to act on their behalf under separate contracts with those agents. Neither Callers nor Service Providers are required to use an Agent, nor does the RNDA endorse any particular Agent.
Caller Agents may query the RND on behalf of their clients to determine whether a telephone number has been permanently disconnected from the consumer their client intends to reach after the date the client obtained consent to call the number, thus allowing their clients to avoid calling consumers with potentially reassigned numbers who may not wish to receive the call.
Service Provider Agents may submit permanently disconnected telephone numbers on behalf of their clients. The Toll-Free Numbers Administrator will act on behalf of Responsible Organizations to submit disconnect telephone number reports for toll-free numbers.
When adding clients, Agents are required to provide a Letter of Authorization (LOA) for each client. Client companies may use their own templates as long they include all data elements contained in the following templates: