What’s the difference between a Caller and a Caller Agent?

A Caller Agent is any third-party contractor that a Caller engages to query the RND on their behalf. PossibleNOW acts as a Caller Agent for DNCSolution clients.

Is the RND a list I can download and check against?

No. Unlike state or national DNC lists, there is no RND list. The RND is queried with two pieces of information: the telephone number and a date, either the date you received consent or the date you were last reasonably sure the number belonged to the party you are trying to reach.

What happens after I query a number?

You receive one of three responses. “Yes” means the number has been permanently disconnected since the date provided and should not be called. “No” means it has not and is callable. “No data” can occur when consent was given before July 2020, or because carriers with fewer than 100,000 subscribers were not required to report disconnects until January 2021.

Does checking the RND give me safe harbor?

The FCC allows a safe harbor for companies that check a telephone number, receive a response that the number is callable, and an error is made.

Do any states require RND checks?

Yes. As of July 16, 2024, Maine is the first state to require use of the RND before a telephone sales call. Other states may follow, which raises exposure at both the federal and state levels.

Do RND checks apply to calls placed by AI agents?

The TCPA applies to the call, not to who or what places it. DNCSolution runs the same RND check before an AI agent dials as it does for a rep or a dialer, so automated outreach doesn’t reach reassigned numbers.

Reassigned Numbers Database (RND) Compliance

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Overview

Reassigned Numbers Database Overview

In November 2021, the Reassigned Numbers Database, commissioned by the FCC, became available for production use. Callers and Caller Agents query it to learn whether a phone number has been permanently disconnected since the date of consent.

There has long been a good source of disconnected landlines, but not of wireless or VOIP numbers. As landline use falls and mobile use climbs, that gap became a real problem for anyone calling legally. The RND now tracks landlines, wireless, and VOIP.

Companies that don't check numbers against the RND are at risk of violating the TCPA. The FCC allows a safe harbor for companies that check a number, receive a response that it is callable, and an error is made.

State law

Maine Passes Law Requiring Use of the Reassigned Numbers Database

As of July 16, 2024, Maine is the first state to require use of the RND. It is now a violation to fail to use the RND to verify that a number has not been reassigned before a sales call, on top of the existing rule against calling numbers on a state or national DNC registry for at least three months.

A telephone solicitor is not liable if they can show routine business practices for DNC and RND, including:

As other states set their own requirements, your exposure grows at both the federal and state levels, and your processes have to evolve with them.

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Maine Passes Law Requiring Use of the Reassigned Numbers Database

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