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TCPA Reassigned ID℠ | TCPA Reassigned Numbers & Verification Scrubbing

old phones

Are you accidentally marketing to the wrong person?

You could be at serious risk of violating the Telephone Consumer Protection Act (TCPA). At $500 - $1500 per call or text, these violations add up fast and can be used to fuel a multi-million dollar class-action lawsuit. To make things worse, there is no more Safe Harbor provision under the TCPA, meaning that there is now a zero-tolerance for calling the wrong person.

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"Numerous TCPA lawsuits today involve the accidental calling [or texting] of wrong or reassigned numbers, creating a significant challenge in the industry. A brand may have consent from Person A and be calling [or texting[ to reach Person A, but if Person B now owns the number and answers, Person B is allowed to sue you for your innocent mistake. Reassigned number and call/text verification scrubbing are absolutely essential to mitigating risk in this regulatory environment."

Eric Allen, Partner at Allen, Mitchell & Allen PLLC
 
45
Million telephone numbers
are disconnected each year
 
100,000
approximate mobile phone numbers
reassigned by wireless carriers
every day
 
20
percent of data in an average
customer contact list could be
reassigned numbers

We Can Help Reduce Your Risk of a TCPA Violation

TCPA Reassigned ID℠ is an enhanced scrub process that scores and verifies the phone owner and owner’s address and identifies wireless phones. This solution is intended for TCPA compliance purposes, where verification of phone owner (for verification of called party prior consent) and wireless identification are critical.

 

Is the Consumer That Provided TCPA Consent
Verifiable at the Carrier Level?

The TCPA mandates that you must prove prior express written consent to market to mobile numbers.
 
 

Has the Phone Number Been Reassigned
to Another Party?

If so, you could be calling the wrong person and risk a TCPA violation of up to $1500 per unlawful contact attempt.
 

TCPA Reassigned ID Product Benefits:

  • Accesses the most comprehensive and accurate telephone network data
  • Authenticates name, telephone number and type of phone plus consent date
  • Scrub for reassigned numbers via batch, API or through one of our partner integrations.
  • Monitors CRM to identify changes to consumer data and provides automated updates
  • Assigns lead score

Frequently Asked Questions

How long before a cell phone number is reassigned?

Cell phone numbers are typically recycled within 90 days. However, in some high demand area codes a cell phone number could be reassigned in under 30 days.

How does the TCPA handle reassigned numbers?

The TCPA is a strict liability statute meaning there is no forgiveness, even for honest, good-faith mistakes. For reassigned numbers, this means callers can be held liable for contacting cell phone numbers for which they had previously had proper consent but have since been reassigned.

Is there a TCPA reassigned number Safe Harbor?

In 2015, the Federal Communications Commission (FCC) created a “one-call” safe harbor for reassigned numbers. In 2018, the D.C. Circuit Court invalidated this safe harbor, finding it to be “arbitrary and capricious.” As a result, there is currently no recycled numbers safe harbor.

Is there an official reassigned numbers database?

The FCC has announced a plan to construct a reassigned numbers database that will be a centralized resource for every contact center. Included in this plan is a new safe harbor rule for dealing with reassigned numbers, replacing the old one-call rule that had been vacated by D.C. Circuit.

Why are reassigned numbers especially dangerous for marketers?

Reassigned numbers are a dangerous potential source of TCPA litigation because consent under the TCPA is associated with the called party rather than the phone number.

How can I avoid contacting reassigned numbers?

The best way to maintain TCPA compliance and avoid liability for calls and texts to reassigned numbers is to conduct a TCPA scrub to identify recycled numbers in your call lists. Making use of a reassigned number identification solution should be part of your overall TCPA wrong number procedure.

Is there a TCPA reassigned numbers guide?

We offer a range of guides and checklists including our Quick Guide to Reassigned Numbers which will teach you how to best protect yourself from the pitfalls of accidentally calling reassigned numbers.


Want to learn more?

Schedule a meeting with us.

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