FCC Announces Compliance Dates For Reassigned Numbers Database Recordkeeping

July 2, 2020 – The FCC’s Consumer and Governmental Affairs Bureau has announced compliance dates for the Reassigned Numbers Database recordkeeping rules.[1]

Beginning July 27, 2020, voice service providers must maintain records of the most recent date each number was permanently disconnected and must age telephone numbers for at least 45 days after disconnection and before reassignment. Small business voice service providers have an additional six months, i.e., until January 27, 2021, to comply with the record maintenance rule.

In December 2018, the Federal Communications Commission established a Reassigned Numbers Database to address the problem of unwanted calls – robocalls – to consumers with numbers reassigned from a previous consumer.[2] The Reassigned Numbers Database will contain reassigned number information from each provider that obtains North American Numbering Plan U.S. geographic numbers and toll-free numbers.

Once the Reassigned Numbers Database is established, callers will be able to consult the database to determine whether a telephone number has been reassigned from the consumer they intend to reach, thus allowing them to avoid calling consumers with reassigned numbers who may not wish to receive the call.

The Reassigned Numbers Database rules apply to all “reporting carriers,” as defined in the FCC’s numbering rules – wireless, wireline, and interconnected VoIP providers that obtain numbers from the North American Numbering Plan Administrator (NANPA), a Pooling Administrator, or another telecommunications carrier.[3] Reporting carriers have three obligations under the FCC’s a Reassigned Numbers Database rules: (1) disconnection recordkeeping, (2) number aging, and (3) disconnection reporting.

Disconnection Recordkeeping.  Reporting carriers must maintain records of the most recent date each North American Numbering Plan (NANP) telephone number allocated or ported to the reporting carrier was permanently disconnected.[4]

Number Aging Minimum.  The more quickly a number is reassigned from one consumer to another, the less opportunity there is for callers to learn of the reassignment and the more likely it is that a caller will misdirect a call to the reassigned number. The FCC’s rules now establish a minimum limit for how long numbers must be aged before reassignment. The minimum aging period for all numbers is 45 days.[5]

Disconnection Reporting.  When the database is operational, voice service providers must report the last date of permanent disconnection associated with their allocated and ported-in numbers to the Administrator of the Reassigned Numbers Database. The disconnection report is due on the 15th day of each month.[6]

Definition of Permanent Disconnection.  A “permanent disconnection” occurs when a subscriber permanently has relinquished a number, or the provider permanently has reversed its assignment of the number to the subscriber such that the number has been disassociated with the subscriber for active service in the service provider’s records. Permanently disconnected numbers therefore do not include instances where the phone number is still associated with the subscriber, such as when a subscriber’s phone service has been disconnected temporarily for non-payment of a bill or when a consumer ports a number to another provider. A ported number remains assigned to and associated with the same consumer even though a different provider serves the consumer after the number is ported.[7]

Reporting carriers must keep accurate and complete records associated with the permanent disconnections of their subscribers on a going-forward basis as soon as the Reassigned Numbers Database information collection becomes effective, regardless of when the reassigned numbers database is launched.[8] On June 26, 2020, the Office of Management and Budget (OMB) approved the information collection associated with rules governing information to be provided to the Reassigned Numbers Database.[9] Accordingly, beginning July 27, 2020, voice service providers must maintain records of the most recent date each number was permanently disconnected and must age telephone numbers for at least 45 days after disconnection and before reassignment.[10] Small business voice service providers have an additional six months, i.e., until January 27, 2021, to comply with the record maintenance rule.

Disconnection Recordkeeping: Beginning July 27, 2020, voice service providers must maintain records of the most recent date each number was permanently disconnected and must age telephone numbers for at least 45 days after disconnection and before reassignment.

Small Provider Recordkeeping: Small business voice service providers have an additional six months, i.e., until January 27, 2021, to comply with the record maintenance rule. Small providers are providers with 100,000 or fewer domestic retail subscriber lines as reported on their most recent Forms 477, aggregated over all the providers’ affiliates.

Database Information Reporting: The FCC will announce the compliance date for the new rule requiring voice service providers to send information to the Reassigned Numbers Database once the database is established.

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[1] Consumer And Governmental Affairs Bureau Announces Compliance Date For Reassigned Numbers Database Rules, CG Docket No. 17-59, Public Notice, DA 20-706 (July 2, 2020), https://www.fcc.gov/document/cgb-announces-compliance-date-reassigned-numbers-database-rules.

[2] Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, Second Report And Order, 33 FCC Rcd 12024, FCC 18-177 (Dec. 13, 2018) (Reassigned Numbers Database Order), https://www.fcc.gov/document/fcc-creates-reassigned-numbers-database-combat-unwanted-robocalls-0.

[3] Reassigned Numbers Database Order at ¶¶ 20-21. See 47 C.F.R. § 52.15(f)(2). The obligation to report the permanent disconnect status of toll free numbers will be on the Toll Free Numbering Administrator. Reassigned Numbers Database Order at ¶ 23.

[4] 47 C.F.R. § 64.1200(l)(1).

[5] Reassigned Numbers Database Order at ¶ 15. The FCC’s rules establish maximum times for how long numbers may be aged before reassignment – four months for toll free numbers and 90 days for other numbers. See 47 C.F.R. § 52.103(d); 47 C.F.R. § 52.15(f)(ii).

[6] 47 C.F.R. § 64.1200(l)(2).

[7] Reassigned Numbers Database Order at ¶ 38.

[8] Reassigned Numbers Database Order at ¶ 41.

[9] 85 Fed. Reg. 38334 (June 26, 2020), https://www.federalregister.gov/documents/2020/06/26/2020-13748/advanced-methods-to-target-and-eliminate-unlawful-robocalls.

[10] Consumer And Governmental Affairs Bureau Announces Compliance Date For Reassigned Numbers Database Rules, CG Docket No. 17-59, Public Notice, DA 20-706 (July 2, 2020), https://www.fcc.gov/document/cgb-announces-compliance-date-reassigned-numbers-database-rules.