Reassigned Number Database Up And Running

It's official: The Federal Communications Commission's (FCC) reassigned number database (RND), which will hopefully minimize claims brought under the Telephone Consumer Protection Act (TCPA), is up and running after several years in the making.

The RND has a long and tortured history. As our readers will recall, the FCC adopted a rule in December 2018 creating a single, centralized database administered by a third party. The general idea is to reduce the number of TCPA claims where a defendant had proper consent from the prior subscriber of the number but does not have such consent from a new subscriber to whom the number was reassigned.

However, multiple petitions were filed seeking reconsideration of certain aspects of the rule, resulting in the timeline being pushed back on more than one occasion.