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Reassigned Numbers Database: How the TCPA Safe Harbor Works for Insurance Agents

Insurance agent at an office desk reviewing a printed list with a pen, a desk phone beside her
  • The Reassigned Numbers Database (RND) was created by the FCC in FCC 18-177 and opened to paid subscribers on November 1, 2021.
  • Consent comes from the person who held the number when it was given; a new subscriber on a reassigned number never agreed to your calls.
  • The safe harbor in 47 CFR 64.1200(m) applies only when you queried the database and it erroneously returned "no," and you carry the burden of proof.
  • A "no" response does not replace consent, revocation checks or do-not-call scrubbing.
  • Keep the consent date, query date, response and call records together for each number.

The Reassigned Numbers Database is an FCC tool that tells callers whether a phone number has been permanently disconnected since a date they enter, such as the date consent was obtained. Under 47 CFR 64.1200(m), a caller that queries it and gets an erroneous "no" may avoid TCPA liability for reaching a reassigned number. Using the database is optional, and the caller bears the burden of proving the safe harbor applies.

What Is the Reassigned Numbers Database?

The Reassigned Numbers Database (RND) is a tool created by the Federal Communications Commission (FCC) to help callers find out whether a phone number may have been permanently disconnected, and so possibly reassigned to a new person, since the caller last had a good reason to believe it reached their consumer. The FCC describes it as designed to prevent a consumer from getting unwanted calls intended for someone who previously held their phone number.

The FCC adopted the database in its Second Report and Order on reassigned numbers (FCC 18-177, CG Docket No. 17-59), adopted December 12, 2018, released December 13, 2018 and published in the Federal Register at 84 FR 11226 on March 26, 2019. According to the FCC's RND page, the database became operational for paid subscribers on November 1, 2021, and is run by SomosGov Inc., which the FCC selected as the Reassigned Numbers Database Administrator. The official reassigned number database site is reassigned.us.

Why Do Reassigned Numbers Matter for Final Expense Agents?

When a consumer fills out a final expense inquiry and agrees to be contacted, that consent comes from the person who held the number at that time. If that person later gives up the number and the carrier assigns it to someone else, the new subscriber never agreed to anything. The FCC's order describes this problem directly: the new subscriber receives calls meant for the prior one, the original consumer misses calls they expected, and callers face wasted effort and potential liability under the Telephone Consumer Protection Act (TCPA).

For agents working older records, see our guide to aged final expense leads calling rules.

The FCC also limits how fast numbers can be reused. The 2018 order set a minimum "aging" period of 45 days before a disconnected number can be reassigned, reasoning that this allows time for monthly disconnect data to reach the database plus a buffer.

How Does the Reassigned Numbers Database Get Its Data?

Under 47 CFR 64.1200(l), reporting carriers subject to 47 CFR 52.15(f) must keep records of the most recent date each North American Numbering Plan number allocated or ported to them was permanently disconnected, and report those dates to the database administrator monthly. Smaller providers (100,000 or fewer domestic retail subscriber lines) received a delayed schedule.

The rule defines "permanently disconnected" as when a subscriber permanently has relinquished the number, or the provider permanently has reversed its assignment of the number so that it has been disassociated from the subscriber. Porting a number to another provider is not a disconnection.

How Do You Query the Reassigned Number Database?

Per the administrator's querying page at reassigned.us, the process works like this:

  1. Register. A primary contact requests access by email as either a "Caller" or a "Caller Agent," completes a registration form with company details and a management "Authorizer," and accepts the Terms of Use. According to the administrator, RND Customer Support will process the application within 7 calendar days of receipt.
  2. Subscribe. Callers and caller agents must hold a prepaid subscription before querying. The FCC and the administrator's pricing page list one-month, three-month, six-month and annual terms in several tiers.
  3. Add clients if you are an agent. A caller agent that queries for client companies must add each client with a signed Letter of Authorization.
  4. Submit numbers with a date. Each query includes the telephone number and a "last known contact date." The FCC's page describes this as the date the caller obtained consent or the last date the caller verified the consumer could be reached at that number.
  5. Choose a method. The administrator lists entry in the web interface (up to 50 numbers), file upload through the web interface or SFTP (up to 1,000,000 numbers per file), and API options.
  6. Read the response and keep it. Save the response with the date and query details for each number you call.

What Do the Database Responses Mean?

The database returns one of three answers. The table below combines the descriptions on the FCC's RND page and the administrator's querying page.

ResponseWhat It IndicatesSafe Harbor Status (per administrator)
YesThe number was permanently disconnected on or after the date you entered, so it may now belong to someone else. The FCC says not to call unless you have separate consent from the current holder.Does not apply
NoThe number has not been permanently disconnected since the date you entered.May apply
No DataThe number is not in the database, and the date you entered is before January 27, 2021.Does not apply

How Much Does the Reassigned Numbers Database Cost?

Use of the database requires a paid subscription. The FCC's order directed that database costs be recovered through usage charges paid by callers who choose to use it. The FCC's page notes that interim pricing was announced October 1, 2021, with revised pricing in effect April 3, 2023, among other pricing updates. Pricing is tiered and published by the administrator on its pricing page at reassigned.us. Check reassigned.us for current tiers.

What Does the TCPA Reassigned Number Safe Harbor Cover?

The safe harbor is in 47 CFR 64.1200(m). In plain terms, a caller will not be liable under paragraphs (a)(1), (a)(2) or (a)(3) of the rule (the restrictions on autodialed, prerecorded and artificial voice calls) for calling a number that was reassigned after the caller obtained prior express consent, if the caller shows both of these things:

  1. The caller, through the database, checked the most recent numbering information reported to the administrator and received a "no" response, meaning the number had not been permanently disconnected since the date prior express consent was obtained.
  2. The call resulted from the database erroneously returning "no" for that number and date.

The rule puts the burden of proof and persuasion on the caller. The FCC's order adds that callers must show they appropriately checked the most recent update of the database, and it declined to widen the time allowed between checking the database and making a call. The FCC's RND page says a caller may be eligible for the safe harbor when its duly authorized agent queries on its behalf.

What Does the Safe Harbor Not Cover?

  • It is not a requirement. The order speaks of callers that "choose to use" the database. Nothing in the text cited here requires you to query it; the safe harbor is only available to those who do.
  • It is not an exemption. The order states that the safe harbor "is not an 'exemption'" from the TCPA and the FCC's rules.
  • It does not create consent. A "no" response only speaks to disconnection. You still need valid consent where the TCPA requires it.
  • It only covers database errors. If the database correctly answered "yes" or "no data," or you never queried, the safe harbor in paragraph (m) does not apply.
  • It is tied to specific paragraphs. The text names paragraphs (a)(1) through (a)(3). It does not refer to the national Do Not Call provisions in paragraph (c) or the company-specific list rules in paragraph (d). Ask counsel how this applies to your calls.

What Records Should You Keep for the Safe Harbor?

Because the caller carries the burden of proof, the safe harbor is only as good as your records. A reasonable file for each number might include:

  1. The consent record and the date consent was obtained. See our guide to building a TCPA consent audit trail.
  2. The date you entered in the RND query and why you chose it.
  3. The query date, the response, and any RecordID you submitted with the query.
  4. The date and time of each call made in reliance on that response.
  5. If you use a caller agent, the Letter of Authorization on file with the administrator.

How Does the RND Relate to Revocation and Do Not Call?

The RND answers one question: has this number been disconnected since a given date? It does not tell you whether the consumer revoked consent or is on a do-not-call list. Those are separate checks.

Revocation. Under 47 CFR 64.1200(a)(10), a called party may revoke consent for calls and texts made under paragraphs (a)(1) through (a)(3) and for National Do Not Call Registry solicitations under (c)(2). Revocations must be honored within a reasonable time not to exceed ten business days. Until November 25, 2026, the rule lets consumers revoke by any reasonable method, and callers may not designate an exclusive means of revocation. Starting November 25, 2026 (FCC 26-67, 91 FR 67214, published October 26, 2026), a caller may designate one or more exclusive methods (an automated voice or key-press opt-out on the call, replying to a text with a standardized word such as "stop," or a designated website or phone number) if it clearly and conspicuously discloses them; a caller that designates none must accept revocation by any reasonable means. Starting November 25, 2026, a revocation made in response to a call or text that contains advertising or constitutes telemarketing applies to all future such calls and texts from that caller.

Do Not Call. Registry registrations under paragraph (c)(2) are honored indefinitely or until cancelled or removed. Company-specific do-not-call requests under paragraph (d) must be honored within a reasonable time not to exceed ten business days from receipt, and honored for five years from the time the request is made.

Where Do Inbound Calls Fit?

This article covers outbound calls to numbers on existing lead records. Reassignment questions arise when you dial a number that a consumer gave you earlier. When the consumer places the call to you, the number-reassignment question this article covers does not come up in the same way. Agency owners can read how CallX works with agencies.

Prefer calls where the consumer dials you? CallX connects licensed final expense agents with inbound insurance calls.
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Frequently Asked Questions

Who Must Use the Reassigned Numbers Database?

Callers are not required to use it under the text cited here. Carriers subject to 47 CFR 52.15(f) must report disconnections to it. Callers that want the reassigned number safe harbor must query it.

What Date Should I Enter When I Query?

The safe harbor in 64.1200(m) refers to the date prior express consent was obtained. The FCC's page also mentions the last date you verified the consumer could be reached at that number. Ask counsel which date fits your records.

Does a "No" Response Mean I Can Call?

Not by itself. The FCC says you may call if you have consent where the TCPA requires it. A "no" does not cure missing consent, a revocation, or a do-not-call request.

Can a Vendor Query the Database for Me?

Yes. The administrator allows registered caller agents to query for client companies with a signed Letter of Authorization, and the FCC says a caller may be eligible for the safe harbor when its duly authorized agent queries for it.

Does the Safe Harbor Apply to Text Messages?

The text of paragraph (m) refers to calls under paragraphs (a)(1) through (a)(3) and does not separately address texts. Ask counsel how it applies to your text messaging.

This article is general education, not legal advice. It summarizes federal regulations as published in the govinfo CFR 2025 edition, FCC orders and the database administrator's public pages as read in November 2026; state laws can add requirements. Confirm your calling practices with counsel or your compliance team before relying on any safe harbor.

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