FCC Supplements Guidance on the Reassigned Numbers Database

The FCC recently supplemented their guidance on the Reassigned Numbers Database, clarifying that a caller may be eligible for safe harbor from TCPA liability if its agent makes the query into the database.  The database, which was created in 2018, allows callers to check to see if a number has been reassigned before calling the number to avoid calling consumers who do not want to receive their calls. 

The clarification hopes to resolve confusion regarding whether agents’ use of the database would deprive callers of the safe harbor.  Importantly, callers should note that they, not their agents, are responsible for providing proof that the most recent version of the database was queried and that it returned an erroneous response.  Callers are also responsible for providing proof that they authorized the agent to check the database on their behalf.

Previous WBK coverage on the database can be found here.