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TCPA & Reassigned Numbers

In a number of scenarios the TCPA (Telephone Consumer Protection Act) requires businesses to have consent before calling consumers. When a phone number is reassigned to a new person, your previous consent is no longer valid as consent is tied to an individual, not a specific phone number. Our Reassigned Authority APIs help you identify reassigned phone numbers to maintain compliance.

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Why Reassigned Number Detection Matters

Calling a reassigned number without the new owner’s consent can result in TCPA violations with statutory damages of $500-$1,500 per call plus the consumer can file a private right of action lawsuit.
When a consumer gives you consent to call them, that consent is tied to:
  • That specific person
  • That specific phone number
If the number is later reassigned to someone else, you no longer have consent to call it.

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Available APIs

Reassigned Authority Plus

Enhanced reassigned number detection with additional data points. Uses both the FCC Reassigned Number Database plus more frequently updated carrier deactivation data. Goes further back than the FCC Reassigned Number Database.

Reassigned Authority

Reassigned number detection based on carrier deactivation data.

Basic RND

Basic reassigned number data using only the FCC’s Reassigned Number database.

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File Formats for SFTP or Web Portal

File Formats

Batch file processing formats for bulk reassignment checking doing via SFTP or Web Portal

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How It Works

  1. Store the consent date when a consumer gives you permission to call
  2. Before calling, check if the number has been reassigned since that date
  3. If reassigned, do not call - the number now belongs to someone else

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Example Workflow

// When consumer provides consent
const consentRecord = {
  phoneNumber: "7075276405",
  consentDate: "2023-06-15",
  consentType: "written",
};

// Before calling, check if reassigned
const response = await fetch(
  `https://dataapi.dncscrub.com/v1.4/Data/TCPAAuthority?phoneNumber=${consentRecord.phoneNumber}&date=${consentRecord.consentDate}`,
  {
    headers: { loginId: "YOUR_API_KEY" },
  }
);

const result = await response.json();

if (result.IsReassigned === true) {
  console.log("DO NOT CALL - Number has been reassigned");
} else if (result.IsReassigned === false) {
  console.log("Safe to call - Number has not been reassigned");
} else {
  console.log("Unable to determine - Proceed with caution");
}

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Key Response Values

IsReassignedMeaningAction
trueNumber was reassigned after the consent dateDo not call
falseNumber has not been reassignedSafe to call
nullInsufficient data to determineUse caution

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Additional Information Returned

The TCPA Authority API also returns useful phone number information:
  • Line Type - Wireless, VoIP, Landline, or Paging
  • Carrier - Original carrier assignment
  • Location - City, region, country
  • Timezone - For calling time compliance

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Example Use Case

The following diagram illustrates a common workflow for businesses collecting opt-in leads, showing how both the Litigator API and Reassigned Authority API work together to maintain TCPA compliance:
Opt-in Lead Scrubbing Workflow

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Workflow Summary

  1. At checkout - When a customer opts in to receive marketing messages, immediately scrub against the Litigator List to avoid known litigators
  2. Save the lead - Store the opt-in with the consent date
  3. Wait 30 days - Phone numbers can be reassigned at any time; waiting helps identify reassignments
  4. Scrub against Reassigned List - Before contacting, check if the number has been reassigned since consent was given
  5. Optional re-check - Scrub against the Litigator List again (litigator status can change)
  6. Repeat monthly - Continue this process every 30 days to maintain compliance