Reassigned Numbers Database: How the Safe Harbor Works and Where It Stops

The table gives the short answers with their sources. Most of the operating detail comes from the administrator's own site at reassigned.us. The legal effect comes from the FCC's rule and the 2018 order that created the database.

The FCC created the database in its Second Report and Order on advanced methods to target and eliminate unlawful robocalls, FCC 18-177, adopted on 12 December 2018 and published in the Federal Register on 26 March 2019. The order's stated aim was a single database of reassigned number information that callers could check before dialing.

The administrator's site says the FCC selected SomosGov, Inc. as the independent entity that manages the database, including registration, customer support, billing and system operations. The data comes from providers. Each provider that obtains US geographic numbers reports its permanently disconnected numbers, and the toll-free numbering administrator reports toll-free disconnections.

The FAQ on the administrator's site says the database contains over 361 million numbers and grows as carriers report each month. The order defines a permanent disconnection as the point when a subscriber has permanently relinquished a number or the provider has permanently reversed its assignment. A number that is ported to another carrier stays with the same consumer and is not treated as disconnected.

The date matters as much as the number. The FAQ describes it as the date of consent. It can be the actual date the consumer consented, or a past date on which you are reasonably certain the consumer could still be reached at that number, such as the last conversation or the last update of contact details.

The response is one of three values. The administrator explains each in terms of the safe harbor, and the table below follows its wording. The FAQ gives worked examples: a number disconnected on 11 February 2021 returns 'yes' when queried with a date of 11 January 2021, and 'no' when queried with a date of 11 July 2021.

Queries can be run several ways. The site lists a web interface for up to 50 numbers at a time, an API for up to 1,000 numbers per call, and file uploads of up to one million numbers by web, SFTP or API. Each number queried counts as one query against a subscription, whichever method is used.

The rule is at 47 CFR 64.1200(m). It says a person will not be liable for violating the prohibitions in paragraphs (a)(1), (2) or (3) by making a call to a number for which the person previously had obtained prior express consent of the called party, where at the time of the call the number is not assigned to the subscriber to whom it was assigned when that consent was obtained.

The protection is conditional. The person, 'bearing the burden of proof and persuasion', must demonstrate two things. First, that by querying the database, based on the most recent numbering information reported to the administrator, and receiving a response of 'no', the person verified that the number had not been permanently disconnected since the date prior express consent was obtained. Second, that the call was the result of the database erroneously returning 'no' to that query.

Put plainly, the safe harbor has four moving parts: real consent from the earlier subscriber, a query that used the right number and the right date, a 'no' from the most recent data, and an error by the database. The caller has to be able to show all four.

The rule begins from consent. It protects a caller who 'previously had obtained prior express consent', so a number that was never properly consented is outside it from the start. A clean database result says nothing about whether the original consent met the definition that applies to the call.

The paragraphs it reaches are limited too. The rule refers to paragraphs (a)(1), (2) and (3) of section 64.1200, which are the autodialer and artificial or prerecorded voice provisions. It does not mention the national do-not-call rules, calling hours or company do-not-call requests.

The FCC said as much when it adopted the rule. The order states that the safe harbor should not be broadly applied to all calls made by a caller who uses the database, and that the Commission declined to extend the safe harbor to other commercial databases. A reassigned-number product from a data vendor may be useful, but by the order's terms it is not the database the safe harbor refers to.

The administrator's pages treat 27 January 2021 as a hard line. The FAQ calls it the date all providers were required to maintain records. For a number with no recorded disconnection, a query date on or after that day returns 'no'. A query date before it returns 'no data', and the administrator says the safe harbor does not apply to that response. The FAQ's example is a number that was never disconnected, queried with a date of 30 December 2020, which returns 'no data'.

For consent gathered before 2021, that leaves the second option the FAQ describes: a later date on which you are reasonably certain the consumer could still be reached at the number. A logged conversation or a confirmed account update after January 2021 gives you a date the database can answer for.

The date you supply becomes evidence. Under the rule, the query has to show the number was not disconnected 'since the date prior express consent was obtained'. If the date you used cannot be tied to a record of consent or contact, the result is harder to rely on. How a court would treat a last-contact date in place of a consent date is a question for counsel.

Two timing facts set the rhythm. Providers report disconnections to the administrator monthly; the FAQ says files are submitted from the 11th and no later than the 15th of each month. And the FCC's order set a minimum aging period of 45 days for all numbers, so a disconnected number cannot be handed to a new subscriber until at least 45 days have passed.

The rule refers to 'the most recent numbering information reported to the Administrator'. It does not set a number of days. A check that was run once when the list was loaded says nothing about disconnections reported in later months.

Other rules and tools show how different the intervals in use are. The CFPB's debt collection rule, at 12 CFR 1006.6(d)(5), describes a procedure for texts in which a collector confirms within the past 60 days, using a complete and accurate database, that the number has not been reassigned. Retell's documentation for its dialer lists a Reassigned Number Database check with a default consent lookback of 30 days, and says results are a snapshot from the moment of the check and are not refreshed. Neither is the FCC's standard. They show why the date of each check belongs in the record.

The administrator sells prepaid subscriptions. The FAQ describes tiers from extra-small to jumbo, with terms of one, three, six or twelve months. Unused queries do not carry over, and wrong-number queries are not credited. The pricing page describes three options when queries run out: buy a new subscription once 75 percent of queries are used, upgrade to a higher tier for a prorated difference, or top off by paying 10 percent of the subscription price for 10 percent more queries.

We could not read the dollar amounts. The current price table is published as an image on the pricing page, and the site's home page says subscription pricing changed with effect from 28 April 2025. Check reassigned.us/pricing for the current figures.

The burden of proof and persuasion sits with the caller, so the safe harbor is only as good as the records behind it. The administrator's site mentions a query report for specific numbers and a summary report of query counts over a period. Those reports sit in the administrator's system. A caller's own log ties each result to a customer and a campaign.

The list below follows the elements of the rule. It describes what the rule makes relevant and is not a statement of what any particular business must keep.

• The telephone number queried
• The date supplied with the query, and the consent or contact record that date comes from
• The date and time the query was run
• The response returned: yes, no or no data
• The result file or report, saved unchanged
• The date and time of each later call or text to the number
• What was done with 'yes' and 'no data' results, such as suppression or a fresh consent request