FCC Creates Reassigned Phone Number Database With Safe-Harbor Against TCPA Liability for Users

The Federal Communications Commission (FCC) has issued a Second Report and Order in its Advanced Methods to Target and Eliminate Robocalls proceeding to create a comprehensive database of phone numbers subject to reassignment because they have been disconnected from their prior subscribers.

This initiative will come as welcome news to companies transmitting calls and texts based on consent previously received for these numbers, in that they will now have the ability to avoid directing them to recipients who have not requested them, just because they inherited a phone number reassigned from a prior user who had consented. This database should thus bring relief to legitimate and well-meaning companies facing significant financial exposure under the Telephone Consumer Protection Act (TCPA) for innocently contacting unintended recipients.

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