FCC commissioned Reassigned Telephone Number Database
Interactive Marketing Solutions (IMS) is a registered Callers Agent
The FCC’s designated Reassigned Telephone Number Database (RND) processor SomosGov has completed the design and testing of the RND and will begin to process Caller telephone numbers 11/1/2021. IMS, as a registered Callers agent, is authorized to submit telephone numbers to the FCC’s RND process on the behalf of Callers to determine if the number has been discontinued/reassigned since the last successful called date. Data is submitted in a text file and the reassigned status (see box below) is appended to each record.
Advantages of using IMS as your Caller Agent for RND processing are many and include:
· Ease of registration and data submission.
o There are several steps in the registration process that are confusing to the casual user
o IMS registration is simple just create a new account, or existing customers just log-in, and subscribe to our SmartClean service.
o Data files may be submitted from any workstation or terminal by any staff member
o No complicated forms to complete.
o IMS will complete the RND registration process for you and be sure to include your identification on each query submitted for “safe-harbor’’ protection.
· No requirement to purchase large blocks of queries.
o The RND requires the advance purchase of query packages in a predetermined size. The choice of query blocks can get confusing and expensive. Also, if you don’t use all the queries within a fixed timeframe, they are forfeited.
o For most IMS query submissions, pay only for the queries you submit, when you submit them.
· Flexible file and data formats.
o Files sizes of up to 6,500,000 records may be submitted (22 million record files will be accepted upon request). The RND maximum file size is 250,000 records, which we handle in a manner transparent to our clients.
o Telephone numbers may be in any standard format with or without dashes and other delimiters.
o Dates may be in any standard date format.
o Up to 3 optional fields of data may be included in each record.
o Each data field will be returned in the format it was received for ease of matching back to internal files and databases.
o Invalid data is flagged and returned consistent with the file format (RND separates and returns records containing validation errors in an inconsistent format).
· Identification of Wireless, Landline and VoIP telephone numbers.
o Subscribers to our Wireless Block Identifier®, Ported Number and VoIP Block Identifier® files will receive wireless, landline or VoIP identification for each telephone number submitted free of charge.
For Pricing and other questions, please email Solutions@ims-dm.com or call 203-653-2762
1. To take advantage of our services please send us the completed CallerAgent registration package which provides us with permission to register you as a client and upload data on your behalf. Email the registration packet to Solutions@ims-dm.com.
2. If you are not already an IMS customer, please click on the Subscribe link and register – Select SmartClean as the product. Completing the registration does not commit you to use IMS as your exclusive agent and you may, at any time, register with the RND service and submit data on your own.
3. When the registration process is complete you will receive a confirming email and telephone data may be uploaded via our SmartClean Link. After your data is submitted you will be provided with the upload count and asked to pay via credit card, you may accept or cancel the service at that time. If cancelled, all submitted data is removed from our servers.
4. When uploading a file, please include the following:
a. A delimited text file containing the 10-digit or 11-digit (with US country code) telephone number in any standard format, with or without dashes or other delimiters and date of last contact in fields 1 & 2 respectively, followed by up to 3 optional fields of your choosing.
b. The text file must contain between 1,000 and 6.5 million records. (Larger files may be submitted as a special request.)
c. Upload data via SmartClean - just log into www.ims-dm.com using your IMS credentials, click on the SmartClean link, check the TCPA and Reassigned number boxes, and upload your file.
5. Once the file has been uploaded, we will submit it for processing and return the data to you usually within 2 hours, but no later than 24 hours. The returned file will contain:
a. Columns 1 & 2 will be your original telephone number and date.
b. Column 3 will be the return code below.
c. Column 4 will identify the telephone number as Landline, Wireless or VoIP. This is an IMS premium feature free to subscribers of our Wireless Block Identifier(R), Ported Number and VoIp files only.
d. Columns 5,6 & 7 will contain any optional fields included with the submitted data.
Return Code Description
· Note: Query Validation criteria:
o Telephone Number - 10 or 11 (+1) digits and may include separators (e.g.,5555555555, 555-555-5555, (555)555-555, 15555555555, etc).
§ Area Code (NPA) 200 or greater.
§ Central Office Exchange (NXX) 200 or greater.
o Date - Valid Date Format (MM/DD/YYYY, YYYY-MM-DD, MM/DD/YY, etc).
§ Today’s date or earlier (no future dates).
GENERAL REASSIGNED NUMBER DATABASE (RND) OVERVIEW
The information provided on this page in not intended to be a legal interpretation of the rules surrounding the development of the database. It is intended as an overview only. We recommend all callers and providers seek legal counsel to review TCPA related rules and regulations.
The FCC completed the specifications for the Reassigned Number Database and its operation. It will identify telephone numbers that have been discontinued and/or reassigned, preventing TCPA violations and reducing unproductive calls. It is scheduled to be available 11/1/2021 and will be administered and operated by SomosGov (also the NANPA and PA administrator). Testing of the database and its operation has begun on 7/1/2021 and IMS is registered to participate in the test.
The FCC Report and Order is available on our website and the following is an overview of the operation and testing of the system for providers and callers.
Providers – Telephone number providers (telephone companies) will be required to submit a list of All permanently disconnected wireless, wireline and Voip telephone numbers by the 15th of each month. The numbers will be added to the database and are expected to be available for query on the 17th. It is estimated that 25 million telephone numbers are disconnected each year.
Callers – Telephone number and date of last successful contact will be uploaded to SomosGov who will query the database and return a NO - the number has not been discontinued since the last contact, Yes - The number has been disconnected since the last contact or No Data - no disconnect data has been received since the start of data collection. There will be a 45-day grace calling period from the date the number is disconnected and considering the update is accomplished once-a-month, the safe grace period may be as little as 15 days. The FCC will offer a safe harbor to good-faith users of the database, protecting them from TCPA liability due to a database error (see table below).
Return Code Safe Harbor Status
No Safe Harbor - The number has been permanently disconnected after the date provided and may not be called.
Safe Harbor may apply – The number queried has not been permanently disconnected after the date provided and may be called.
No Safe Harbor – The date provided is prior to the start of data collection and/or there is insufficient information available to determine disconnect status.
Specifically for Debt Collectors
The pending final rule from Consumer Financial Protection Bureau due to go into effect November 30, 2021, and apparently referred to as Regulation F, references use of the RND. From the RND perspective, the relevant sections have been summarized and highlighted below. The entire rule is lengthy and may be found by clicking the link: https://www.federalregister.gov/documents/2020/11/30/2020-24463/debt-collection-practices-regulation-f
Summarized and Highlighted Sections
The 12 CFR Sec. 1066.6 (d)(5) reads (or will when the rule goes into effect) as follows:
(5) Procedures for telephone numbers for text messages. For purposes of paragraph (d)(3)(i) of this section, a debt collector may send a text message to a telephone number if:
(i) The consumer used the telephone number to communicate with the debt collector about the debt by text message, the consumer has not since opted out of text message communications to that telephone number, and within the past 60 days either:
(A) The consumer sent the text message described in paragraph (d)(5)(i) of this section or a new text message to the debt collector from that telephone number; or
(B) The debt collector confirmed, using a complete and accurate database, that the telephone number has not been reassigned from the consumer to another user since the date of the consumer’s most recent text message to the debt collector from that telephone number; or
(ii) The debt collector received directly from the consumer prior consent to use the telephone number to communicate with the consumer about the debt by text message, the consumer has not since withdrawn that consent, and within the past 60 days the debt collector either:
(A) Obtained the prior consent described in paragraph (d)(5)(ii) of this section or renewed consent from the consumer; or
(B) Confirmed, using a complete and accurate database, that the telephone number has not been reassigned from the consumer to another user since the date of the consumer’s most recent consent to use that telephone number to communicate about the debt by text message.
In addition to discussion about this point in the 653 page ruling, there is a section that clarifies the rules.
“6(d)(5) Procedures for telephone numbers for text messages. 1. Complete and accurate database. Section 1006.6(d)(5)(i) and (ii) provides that, for purposes of § 1006.6(d)(3)(i), a debt collector may send a text message to a telephone number if, among other things, the debt collector confirms, using a complete and accurate database, that the telephone number has not been reassigned from the consumer to another user. For purposes of § 1006.6(d)(5)(i) and (ii), the database established by the FCC in In re Advanced Methods to Target & Eliminate Unlawful Robocalls (33 FCC Rcd. 12024 (Dec. 12, 2018)) qualifies as a complete and accurate database, as does any commercially available database that is substantially similar in terms of completeness and accuracy to the FCC’s database.