Removing Barriers Blog

Sign Up to Beta Test the Reassigned Number Database
Posted June 17, 2021 by CUNA Advocacy

The FCC is launching a beta testing period where credit unions can sign up to use the new Reassigned Numbers Database for free. Callers and caller agents interested in participating in the beta test can go to https://www.reassigned.us/ or email support@reassigned.us for more information. 

For some background, in 2015 the FCC issued a Declaratory Ruling addressing situations where a consumer might change their phone number and not tell an entity that calls them, such as their credit union. In the ruling, the FCC found that even though the caller has no idea that the number has been reassigned, because the caller doesn’t have the consent of the number’s new owner, the call may be a violation of the TCPA. The ruling established a one-call safe harbor, but if the caller doesn’t discover that the number has been reassigned on that one call, any future calls may be a violation of the TCPA. Given that there is currently no way to know when numbers have been reassigned without the consumer informing the caller, this poses huge compliance and litigation risk to credit unions. Since 2018 the FCC has been working on a database for callers to check and see if the number still belongs to the intended recipient of the call before calling. Once the beta period is over, callers will be able to scrub their numbers against the database. Callers that use the database are given a safe harbor from TCPA liability if it turns out the number in fact has been reassigned.  After the testing phase, callers will have to pay to access the database. It likely is worth the cost given that calling a reassigned number was often the basis for lawsuits.