Recycled Number Relief Pushed to 2020: FCC Grants Further Extension on Reassigned Number Database Implementation

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Quick update for anyone wondering what has become of the FCC’s reassigned number database.

Last December, 2018 the FCC issued an Order creating a reassigned number database. The database would track the date of the last permanent disconnect of a cell phone number and enable potential callers to scrub against the database before attempting a call to a cell phone number. By using the database callers could avoid calls to wrong numbers—and the attendant risk of TCPA liability. And, in the event of an error in the database, callers would be granted a safeharbor if they otherwise properly scrubbed before attempting a call.

The database was originally expected to be rolled out in late 2019. But a series of delays have hampered its implementation. First, the FCC issued a public notice on two petitions seeking reconsideration of certain aspects of the order creating the database. Then, the North American Numbering Council’s (NANC) Numbering Administration Oversight Working Group—the outfit responsible for making technical recommendations needed to implement the database—sought a several month extension to complete its work. Whereas NANC’s recommendations were originally due June 13, 2019, the date was extended to September by order of the FCC issued June 12, 2019.

Well last Thursday the Commission granted a further extension—this time to January, 2020– to complete the technical analysis and an additional month to set a pricing structure. NANC reported that the work was more challenging than expected and needed vendors are, apparently, not cooperating. Notably the NANC had sought an extension to April, 2020 but the FCC was reluctant to wait that long.  As the FCC put it: “We are mindful of the need to establish an operational database as soon as possible and believe that this is sufficient time for the remaining work to be completed.”

The ruling can be found here: Reassigned Number Database Requirements

After the technical specifications and pricing elements are completed an Administrator will need to be chosen and the carriers will need to supply data to populate the database. Hence, it now looks like Summer, 2020 is now the earliest possible deployment for the database.

We’ll keep you posted.

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Published by Eric J. Troutman

The Czar of TCPAWorld Eric Troutman is one of the country’s prominent class action defense lawyers and is nationally recognized in Telephone Consumer Protection Act (TCPA) litigation and compliance. He has served as lead defense counsel in more than 70 national TCPA class actions and has litigated nearly a thousand individual TCPA cases in his role as national strategic litigation counsel for major banks and finance companies. He also helps industry participants build TCPA-compliant processes, policies, and systems. Eric has built a national litigation practice based upon deep experience, rigorous analysis and extraordinary responsiveness. Eric and his team feel equally at home litigating multibillion dollar telecommunications class actions in federal court as they do developing and executing national litigation strategies for institutions facing an onslaught of individual TCPA matters. They thrive in each of these roles – delivering consistently excellent results – while never losing sight of the client experience. While many firms now tout TCPA expertise, Eric has been there from the beginning. He built one of the country’s first TCPA-only defense teams and began serving as national TCPA counsel for his clients nearly a decade ago. This perspective allows him to swiftly develop the right litigation strategies for dealing with recurring problems, without wasting time on tactics that are bound to fail. Eric’s rich historical perspective and encyclopedic knowledge of the TCPA landscape also make him an invaluable resource to institutional compliance teams struggling to comply with the shifting regulatory landscape. No task is too small – or too big. Indeed, Eric and his team have helped build TCPA-compliant systems and processes for some of the largest and most complex corporate entities in the country. He commonly works with in-house compliance counsel to build and implement enterprise and business-line specific TCPA solutions, performs TCPA audits and drafts and reviews proposed TCPA policies and procedures. He and his team also have the technical expertise necessary to assist call centers seeking to develop TCPA-resistant call path architecture or to modify existing telephony and software integration to better insulate from potential TCPA exposure. Eric has built a reputation for thought leadership. An avid blogger and speaker, he has been at the forefront of the industry’s effort to push for clarity and a return to sanity for the TCPA for years. He was selected to advocate for the financial services industry on important TCPA issues before the Federal Communications Commission and co-authored the nation’s only comprehensive practice guide on TCPA defense. In his spare time, Eric leads defense teams representing banks and other financial services companies in consumer finance litigation matters. He has experience representing clients in UCC, TILA, RESPA FCRA, CCRA, CLRA, FDCPA, RFDCPA and FCCPA claims, as well as in fraud and bank operations issues.