Missouri HB 2658: Proposed Reassigned Numbers Requirements and Compliance Implications

Missouri House Bill 2658 hasn’t passed yet. At the time of writing, it remains a proposed bill introduced in the Missouri legislature.

But even in its proposed form, HB 2658 is worth paying attention to because it reflects a shift many compliance, operations, and marketing teams are already feeling:

Outreach is becoming less about good intent and more about what you can prove within your compliance processes.

The bill doesn’t introduce entirely new concepts to outreach or compliance but it would still create meaningful changes for businesses calling into Missouri.

It updates definitions for clarity and removes exemptions that many organizations still rely on, particularly around consent, referrals, licensing, and reassigned numbers. For a wide range of professionals who may not think of themselves as “telemarketers,” those changes could be easy to miss.

A Shift From “Reasonable Belief” to “Provable Process”

At a high level, HB 2658 would modernize Missouri’s telemarketing laws to better reflect how people actually communicate today across voice, fax, SMS, MMS, and VoIP.

But the more interesting story isn’t which channels are now clearly covered. It’s how little tolerance there appears to be for informal, inherited, or assumed permission to call or text.

If enacted, the bill would place more responsibility on the caller to actively confirm:

• Who currently owns the number
• Whether permission still applies
• Whether a prior relationship is still valid

This matters far beyond traditional call centers. HB 2658 reaches into industries that often view their outreach as personal, professional, or relationship-based.

It touches anyone whose job includes reaching out to leads, prospects, customers, members, patients, donors, or past clients. This would include but is not limited to financial services, insurance, real estate, home services, recruiting, healthcare-adjacent outreach, and distributed/work-from-home sales teams.

And the clearest example is reassigned numbers.

Reassigned Numbers: From “Best Practice” to Compliance Requirement

One of the most notable provisions in HB 2658 is direct and simple:

“A telemarketer shall use the Federal Communications Commission’s reassigned number database.”

The reassigned numbers database itself isn’t new. It has existed for years as a mechanism to help callers avoid reaching the wrong person after a number changes ownership. Use of the database currently offers safe harbor protections from TCPA liability at the federal level when used correctly. Currently, only Maine explicitly requires its use under state law.

Under existing federal law, consent and established business relationships already do not follow a phone number once it changes ownership. If a number is reassigned, prior consent tied to that number is invalid and calling it has always carried risk under the TCPA and TSR.

Historically, many businesses weighed that risk against the cost of proactively checking numbers for reassignment. The industry long argued there was no reliable way to know when a number changed hands, which is exactly why the FCC created the Reassigned Numbers Database.

What HB 2658 does is remove that discretion for Missouri calls. Instead of reassigned-number checks being a risk-based decision or best practice, they would become a requirement. Businesses could no longer opt out of checking and simply “take the risk.” Failure to do so would introduce exposure not only under federal law if a call goes wrong, but also under Missouri state enforcement.

For industries that rely on long sales cycles or ongoing client relationships such as mortgage lenders, insurance agents, financial advisors, and realtors that detail is particularly significant.

This raises practical questions worth thinking through for anyone initiating calls or texts to Missouri:

• How often are phone numbers being checked for reassignment?

• Does that check happen when a lead is acquired, when it’s dialed, or both?

• What happens operationally when a number flips ownership mid-campaign?

• How do you document that the check occurred (especially with outsourced dialing, CRMs, or multiple teams)?

These aren’t legal questions so much as process questions and they’re important to start asking before the law changes.

Takeaway: While the requirement around the Reassigned Numbers Database is narrow right now, the fact that additional states are proposing similar language suggests a broader trajectory. What has historically been treated as a best practice seems to be on a path toward becoming a baseline expectation for compliance.

The Removal of Familiar Protections and Exemptions

Another part of HB 2658 that stands out isn’t what’s added, it’s what’s been removed.

The bill strikes several carve-outs that many organizations have historically leaned on, including protections related to:

• Federal regulation or licensing
• Referral-based calls
• Appointment-setting by licensed professionals
• Calls made by individuals working from home or independently

Taken together, this suggests a broader legislative posture: who you are matters less than what you can demonstrate.

Being regulated, licensed, or referred may still provide helpful context, but it no longer appears to function as a deflection of certain compliance expectations.

This is particularly relevant for professionals who don’t typically think of their outreach activities as telemarketing at all, such as:

• Insurance agents calling referred prospects
• Realtors following up on listings or open-house leads
• Financial services teams working warm or aged leads
• Work-from-home sales representatives operating independently

For all organizations that rely heavily on referrals, partner leads, or appointment-setting outreach, this is a piece of the bill worth pausing on. These practices are being re-evaluated through a regulatory lens and it’s essential to understand.

The “Residential” Subscriber Definition Is Disappearing

HB 2658 also removes repeated references to “residential” telephone subscribers, replacing them with broader language around telephone subscribers generally.

That may sound like a technical edit, but it reflects a reality most businesses already know: the line between personal and business numbers has blurred.

Mobile phones, mixed-use numbers, and work-from-anywhere setups are now the norm. From a practical standpoint, this change reinforces the idea that treating certain numbers as “safer” simply because they’re associated with business use may be an increasingly fragile position.

What Missouri HB 2658 Does Not Do

First, this is a proposed bill that can still be amended, narrowed, expanded, or stalled before ever becoming law. Nothing in it is enforceable today simply because it has been introduced.

Second, the proposal does not ban calling or texting. It does not eliminate outreach as a business practice, and it does not prohibit organizations from contacting prospects or customers where valid permission or a qualifying relationship exists.

The core compliance foundations most teams already work from are still present in the bill’s structure. That includes things like prior express written consent and recent business relationships. What changes is not the existence of those concepts, but how they are treated if underlying facts, like number ownership, have changed.

It also does not single out one industry or outreach model. Instead, it focuses on the activity of solicitation itself, regardless of who performs it or what industry they’re in.

And importantly, it does not suggest that good-faith outreach automatically becomes unlawful. What it signals instead is that good faith alone is not enough; documentation and verification increasingly matter alongside intent.

In that sense, the proposal reads less like a restriction on outreach and more like a refinement of how outreach is expected to be validated and supported.

What Teams Might Want to Revisit Now

Without offering legal advice, this bill should create a moment for internal review and conversation. Depending on your role, that might include discussions around:

1. How reassigned numbers are handled today
2. Whether referral-based outreach is documented differently than other lead sources
3. How consent is captured, stored, and refreshed over time
4. Whether dialing and texting workflows rely on protections that could narrow if this bill advances
5. How vendors and data partners validate number ownership

For many teams, this bill should nudge a review around existing practices against where the law, carriers, and regulators appear to be headed.

Those conversations are best had with internal compliance teams and legal counsel, especially as the legislative process continues.

Why HB 2658 Matters Even If It Never Passes

Whether HB 2658 becomes law in its current form or not, it reflects a broader trend we’re already seeing across regulators, carriers, and enforcement bodies:

Outreach is increasingly evaluated based on what can be verified not what was assumed, nor what the intent was.

From that lens, this bill is less of a surprise and more of a signal.

And signals like these are often worth paying attention to.

Keeping Track of State & Federal Changes Without the Manual Work

Bills like HB 2658 can be a reminder of just how challenging it is to stay current.

Tracking proposed legislation, monitoring when it changes, and understanding how it interacts with existing state and federal rules takes time, especially when those changes don’t happen all at once.

For teams looking for a simpler way to stay informed, the Compliance Guide™ is designed to help centralize that work. It tracks state and federal calling and texting regulations, distinguishes between what’s currently enforceable and what’s proposed, and notifies users as laws move through the legislative process or officially take effect.

It also includes AI-assisted support that makes it even easier and faster to find answers you can trust. Instead of digging through pages of statutes or guidance to find what’s relevant, it helps surface the information you need with the original source material still there if you want to review it directly.

The Compliance Guide isn’t a replacement for legal counsel, but it is kept up to date with input from some of the best attorneys in the industry. For many teams, it’s simply a practical way to stay organized, informed, and prepared as regulations continue to evolve.