How to remove reassigned numbers from your calling list

Last updated 2026-07-09

What is a reassigned number and why does it create TCPA liability?

A reassigned number is a phone number your contact legitimately gave you at some point, but which the carrier has since recycled and handed to a completely different person. The new subscriber never opted in to hear from you. Under 47 U.S.C. § 227, consent attaches to the person, not the digits. Once the number changes hands, your prior consent is gone. ^[1]

Carriers in the United States recycle millions of numbers a year. The FCC has said roughly 35 million numbers get disconnected and made available for reassignment annually, though the real pace of reassignment varies by carrier and region. ^[2] That churn is fast. A list you scrubbed six months ago can already hold a meaningful chunk of numbers that moved to new subscribers.

The TCPA gives you no free pass for believing in good faith that you were still calling your original contact. Courts treat the statute as close to strict liability for wrong-number calls, so your intent counts for almost nothing. The Eleventh Circuit's decision in Sartori v. Susan C. Little & Associates is one of many that make this plain. If the number has a new owner, you likely owe damages. ^[3]

This is one of the fastest-growing categories of TCPA class actions. Plaintiffs' attorneys hunt for bulk callers with stale lists because the math is simple. Ten thousand calls to reassigned numbers at $500 each is a $5 million case before you reach the trebled willful tier. If you run any outbound program, reassigned numbers are a real exposure, not a theory.

How does the FCC's Reassigned Numbers Database work?

The FCC built the Reassigned Numbers Database (RND) to solve exactly this problem. It went live for commercial use on November 1, 2021, after years of rulemaking. The database pulls disconnection data from every facilities-based voice provider in the country. Carriers report when a number is permanently disconnected, and the RND stores the most recent permanent disconnection date for each number. ^[2]

You query the RND by submitting a phone number plus the date you last had verified consent for it. The database returns one of three answers. "Yes" means the number was permanently disconnected after your consent date, so a new person may now have it. "No" means no permanent disconnection on record after your consent date. "No Data" means the number isn't in the database, which often means it was ported or otherwise isn't tracked. ^[2]

The FCC's rules, finalized in its 2018 order on reassigned numbers, set up a safe harbor for callers who query the RND before calling and get a "No" response. If you get a "No," call anyway, and the number turns out to have been reassigned through some data gap, the safe harbor gives you real protection. But it only applies if you actually queried the RND before the call. ^[3]

Access isn't free for commercial users. The FCC set a tiered fee schedule. Individual number queries cost $0.005 each (half a cent), and bulk monthly subscriptions cap at around $1,595 per month for very high volumes. For most small and mid-sized outbound teams, query-based pricing is the practical way in. You reach it through icnd.us, the official FCC-contracted portal. ^[4]

What does the TCPA actually say about calling wrong numbers?

The core prohibition sits in 47 U.S.C. § 227(b)(1)(A), which makes it unlawful to make any call using an automatic telephone dialing system or an artificial or prerecorded voice to any number assigned to a cellular telephone service without the prior express consent of the called party. ^[1] The phrase that matters is "called party." Courts read that as the current subscriber, not whoever gave you consent in the past.

The FCC reinforced this in its 2015 TCPA Omnibus Order. The Commission held that a caller relying on prior consent must stop calling a reassigned wireless number after learning of the reassignment, and it offered only a narrow one-call grace period. Leaning on old consent after you have reason to know a number may have changed hands is not a defense. ^[5]

Statutory damages under § 227(b)(3) run $500 per violation. If a court finds the violation was knowing or willful, damages climb to $1,500 per call. Class actions built on reassigned-number claims routinely chase the trebled amount, arguing the caller ignored known risk. For TCPA basics and how courts apply these numbers, it helps to see how settlements actually land, like the structure in the Credit One TCPA settlement and the Cash App TCPA class action settlement. ^[3]

What's the difference between the RND and the Do Not Call Registry?

These two tools solve different problems, and mixing them up is a common mistake.

The Do Not Call list is a registry of people who asked not to get telemarketing calls. It's a preference signal. A number on the DNC list belongs to a real person who doesn't want to hear from you. ^[6]

The RND has nothing to do with preferences. It tells you whether a number was disconnected and possibly reassigned to someone new. A number can be absent from the DNC list entirely and still be reassigned. The reverse is also true. A number can sit on the DNC list with no reassignment history at all.

You run both checks, in a specific order. Query the RND first to learn whether you're still reaching your intended contact. Then run DNC suppression to confirm that contact hasn't opted out. Skip either one and you leave a gap. Plenty of small teams know the do not call telemarketer list process cold but have never heard of the RND until a complaint arrives.

Check	What it catches	Source	Timing
FCC Reassigned Numbers Database	Numbers recycled to new subscribers	icnd.us (FCC-contracted)	Before each campaign send
National DNC Registry	Numbers of people who opted out of telemarketing	donotcall.gov	Before each campaign send
Internal suppression list	Prior opt-outs, complaints, litigators	Your CRM / compliance system	Ongoing, real-time
Carrier lookup / line type	Cell vs. landline, active vs. inactive	Third-party data vendors	At list acquisition

How often should you scrub your list against the RND?

The FCC's safe harbor requires you to query the RND before placing the call, not before building the campaign. That distinction matters a lot. Querying your list once at acquisition and then dialing it for four months does not preserve the safe harbor for calls made in month four. The query has to tie to the actual call date.

Most compliance teams batch their RND queries 24 to 72 hours before dialing starts for a given run. That window gives the data time to settle while keeping the query close enough to the call that the result still means something. Query more than a week out and your protection weakens, because numbers can flip in that gap.

For ongoing relationship programs, where you dial the same pool of contacts over months, re-query every 30 days at minimum. Some teams tie re-queries to a monthly hygiene cycle. Others bake it into the dialer so the system auto-flags any number that hasn't been queried in the last 30 days before the call goes out. The dialer approach wins because it removes the human step that gets forgotten under pressure.

If your cold calling operation runs on purchased lists or aged leads, your reassignment risk sits above average, because you don't know when consent was actually collected or verified. In that case, query every number before every call. Full stop.

What's the step-by-step process for removing reassigned numbers?

Here's how a working reassigned-number scrub runs for a small outbound team.

Step 1: Record your consent date. For every number, you need the date the person gave consent or was last verified as the subscriber. Without that date, you can't query the RND correctly, because the database uses it to decide whether a disconnection happened after your consent was established. No consent date means treat the number as high-risk.

Step 2: Export your dial list with consent dates. Pull the list from your CRM in a format that carries the phone number and its matching consent date. Most modern CRMs handle this with a custom export field.

Step 3: Query the RND via icnd.us. You can query numbers one at a time or in bulk. For teams dialing more than a few hundred numbers, bulk is the only realistic path. The file format lives in the icnd.us portal docs. You submit the file, get a response file back, and for each number the response tells you whether a disconnection shows up after your consent date. ^[4]

Step 4: Suppress all "Yes" responses. A "Yes" means a permanent disconnection hit after your consent date. Pull it from the dial list right away. Don't call it. Add it to your internal suppression list so it can't sneak back in on a future import.

Step 5: Handle "No Data" conservatively. "No Data" numbers are not confirmed safe. They may belong to carriers not fully integrated with the RND, or the number may have been ported rather than disconnected. The safe harbor does not cover "No Data." Treat these as moderate-risk and weigh whether the rest of your data on that record supports the call.

Step 6: Log your query. Keep a dated record of the query run, the consent dates you used, and the results. If a TCPA complaint ever lands, this log is what shows you followed the process. FCC rules require records sufficient to support a safe harbor claim. ^[10]

Tools like LeadCompliant's compliance kit can help you wire this query-and-log workflow into your existing list management, which is where most teams drop the ball. The process itself is simple. What breaks is documentation and consistency.

Are there third-party tools that help with reassigned number scrubbing?

Yes. Beyond querying the RND directly through icnd.us, a small industry of compliance data vendors has built APIs and batch services on top of the RND and other carrier data. These vendors usually add a few signals past the raw RND result: carrier-level line status, number portability data, and sometimes a composite risk score.

Ask vendors three specific questions. Do they query the official FCC RND, or lean on a proprietary database that may be stale? Only a query to the official RND through an authorized access provider supports the FCC safe harbor. What is their query timestamp? A vendor who batches queries weekly and sells you "fresh" results is not giving you safe-harbor-quality data. And how do they treat "No Data" responses? A vendor who quietly flips those to "safe" is hiding your risk.

Cost runs across a wide band. Direct RND queries through icnd.us cost $0.005 per number for low-volume users. Third-party pass-through services often charge $0.01 to $0.05 per number, with the premium buying API convenience and extra data layers. For a team dialing 10,000 numbers a month, that's $100 to $500 a month in scrubbing. Set against one TCPA settlement, it's a rounding error.

If you also want to understand what the mobile phone do not call list rules add on top of this, and how they shift for wireless numbers, that's a separate but related step worth folding into the same workflow.

What is the FCC safe harbor for reassigned numbers and what does it actually protect you from?

The safe harbor, set in the FCC's 2018 RND order and codified in 47 C.F.R. § 64.1200, works like this. Query the RND before calling a number, get a "No" (no permanent disconnection after your consent date), call that number, and if it turns out the number was reassigned through some gap in the database, the FCC will not find you liable for that call. ^[10]

Here's what the safe harbor does not cover: calls made without querying the RND at all, calls made after a "Yes" response, calls where the query is stale (the FCC hasn't fixed an exact staleness threshold in days, but the rule's intent is that the query relates to the specific call, not a campaign that kicked off weeks ago), and calls to numbers that came back "No Data."

The safe harbor is a regulatory one. It cuts your exposure to FCC enforcement. It does not automatically win a private lawsuit. Plaintiffs in TCPA class actions sue directly under § 227, and courts have sometimes found the safe harbor framework doesn't fully immunize callers from private rights of action. Even so, documented RND compliance is your strongest factual defense in private litigation. Any competent plaintiff's attorney will demand your scrubbing logs in discovery. If you can't produce them, expect the case to get expensive. ^[5]

For how these cases actually settle, look at the patterns in the Cash App TCPA class action settlement. Seven-figure outcomes are common precisely because callers couldn't document their process.

How do you handle numbers where you're not sure when consent was obtained?

This is where most small teams get into trouble. They bought a list from a broker, or imported leads from a years-old CRM migration, and the consent date field is blank or garbage.

With no credible consent date, you have two options. First, treat the consent date as the earliest plausible date. For most purchased lists that means the acquisition date, or the lead's original creation date if you know it. This is conservative and flags more numbers as possibly reassigned, which means more suppression and a smaller dial list. That's the right tradeoff.

Second, run a broader data validation pass before the RND query. Services that check whether a number is currently active, which carrier holds it, and whether it's wireless or landline can help you spot obvious dead numbers before you query the RND. A disconnected number that reads inactive in carrier data is a strong signal to suppress no matter what the RND says.

The how do I get the Do Not Call list question comes up a lot, and the answer is simple: you subscribe through the FTC's portal. The RND answer is just as simple once you know the tool exists. Both tools need a documented process around them to actually protect you. Access without logged queries is a seatbelt you never buckle.

What happens if you call a reassigned number and the new subscriber sues you?

The new subscriber, who never consented, has a private right of action under 47 U.S.C. § 227(b)(3). They can sue in federal or state court for $500 per violation, or up to $1,500 if the court finds the violation willful or knowing. Each call or text counts as a separate violation. ^[1]

Class actions are the real exposure. One plaintiff is a nuisance. A class of 50,000 people who all got calls to their newly assigned numbers from your dialer is a $25 million case at the base rate, before trebling. The plaintiff's bar has industrialized this claim. They watch PACER for patterns, they work with technical experts who pull call detail records, and they know exactly which discovery questions expose a missing RND query process.

FCC enforcement is a separate channel. The Commission can issue forfeiture orders, administrative fines that reach $10,000 per violation under 47 U.S.C. § 503(b), with a standard cap of $100,000 per day per continuing violation and $1 million total for a single act or failure to act. ^[7] The FCC tends to go after the largest-volume violators, but an active complaint from a new subscriber can still trigger a look.

State AGs can pile on too. Many states run their own TCPA-style or unfair-practice statutes alongside the federal claim. ^[8] Run a multi-state outbound program and the exposure stacks fast.

What records do you need to keep to defend yourself if a complaint comes in?

Documentation is your defense. Here's what you need to be able to produce when a complaint lands.

Consent records: the original consent capture, including the date, the exact phone number consented, the mechanism (web form, verbal, signed document), and the language the person saw or heard. Without the original record, you're arguing with a sticky note against a lawyer.

RND query logs: a dated record showing you queried the RND for this specific number before calling it, the consent date you fed the query, and the response you got. The query timestamp has to pre-date the call. If your vendor can't export query logs, get a different vendor.

DNC scrub logs: proof the number was checked against the National DNC Registry before the call, with the date of the check. The FTC requires you to access registry data no more than 31 days before calling a number. ^[6]

Call records: your outbound call detail records, including the date, time, number dialed, and result. These get requested in discovery and compared against the plaintiff's records and carrier data.

Suppression list history: a record of when numbers hit your internal suppression list and why. If someone complained or asked not to be called, the date of that request and proof you honored it belongs in the file.

Keep all of it for at least four years. The TCPA statute of limitations is four years in most courts, and some state claims run longer.

What's a realistic compliance budget for reassigned number scrubbing at a small outbound team?

Let's put real numbers on this. A small outbound team dialing around 10,000 numbers a month is a reasonable baseline to estimate from.

Direct RND queries via icnd.us: 10,000 queries at $0.005 each is $50 a month. That's the floor if you have the internal bandwidth to manage file submission yourself. ^[4]

Third-party API vendor with RND plus carrier data: $0.01 to $0.05 per number, so $100 to $500 a month for the same volume. The premium buys API integration with your dialer or CRM plus extra data points like line type and portability status.

National DNC Registry subscription: $90 per area code per year, or a flat annual fee for the full national file starting at around $20,000 per year for all area codes (check the FTC's current published fee schedule, which the agency adjusts annually). For small teams calling a limited geography, the per-area-code model is cheaper. ^[6]

Internal staff time for list hygiene: somewhere between 2 and 8 hours a month for a 10,000-number program if the process is well-defined. If it's chaotic and manual, double that.

A single TCPA settlement routinely runs six or seven figures even for small defendants, and legal fees alone often hit $50,000 to $150,000 before a case resolves. Against that, spending $200 to $600 a month on scrubbing is the obvious call. The math is not close.

Frequently asked questions

How often does the FCC Reassigned Numbers Database get updated?

Carriers must report disconnected numbers to the FCC's Reassigned Numbers Database monthly, and some report more often. The FCC designed the system for near-real-time reporting, but the practical update lag varies by carrier. This is one reason compliance teams query the RND as close to the call date as possible, ideally within 24 to 72 hours before dialing, rather than at list acquisition.

Does the RND safe harbor protect me from private TCPA lawsuits, or just FCC enforcement?

The safe harbor came from FCC rulemaking and mainly shields you from FCC enforcement actions. In private litigation under 47 U.S.C. § 227, plaintiffs sue directly under the statute, and courts are not uniformly bound by the FCC's safe harbor framework. Even so, documented RND compliance is your strongest factual defense in any proceeding. Courts and juries respond well to evidence that you ran a real scrubbing process.

What does 'No Data' mean when I query a number against the RND?

A 'No Data' response means the RND has no permanent disconnection record for that number. That can happen because the number belongs to a carrier not fully integrated with the RND, or because the number was ported rather than disconnected. The FCC safe harbor does not cover 'No Data' results. Treat these numbers as moderate-risk and layer in carrier lookup data before deciding to call.

Can I still call a number if the RND returns 'Yes' in some circumstances?

No. A 'Yes' response means the number was permanently disconnected after your consent date, so a new person may now hold it. The FCC's rules provide no grace period or exception for 'Yes' results. Suppress the number right away, add it to your internal do-not-call list, and don't call it. Calling after a 'Yes' response wipes out any safe harbor protection you had.

Is reassigned number scrubbing required for landline calls, or just cell phones?

TCPA's strict consent rules and the RND safe harbor apply most directly to calls made to wireless numbers using an autodialer or prerecorded voice. Landline calls placed by a live agent without prerecorded content carry a different liability profile. Carriers do reassign landline numbers too, though, and reaching the wrong person on a landline can still spark nuisance and state-law claims. Scrub both, but the legal urgency runs highest for wireless numbers.

What consent date should I use if I bought a lead list and don't know when the lead opted in?

Use the list acquisition date as a conservative proxy, or the earliest plausible lead creation date if the vendor provides it. This approach flags more numbers as possibly reassigned, which means a smaller dial list. That's the right outcome when you're uncertain. You can also treat all numbers from undated lists as high-risk and run them through both the RND and a carrier active-status check before calling.

How do I access the FCC Reassigned Numbers Database?

The official access portal is icnd.us, contracted and operated on behalf of the FCC. You create an account, agree to the terms of service, and then submit individual queries or bulk batch files. Pricing is $0.005 per number for query-based access, with monthly subscription tiers for very high volumes. Some third-party compliance vendors offer API access to RND data as part of a broader list hygiene package.

How long do I need to keep records of my RND queries?

Keep your RND query logs, consent records, DNC scrub logs, and call records for at least four years. The TCPA's statute of limitations is four years in most courts, and some state law claims that run alongside TCPA claims carry longer windows. If a complaint arrives, you need to reconstruct exactly what checks you ran before a specific call went out.

Does running the RND scrub replace the need to check the National Do Not Call Registry?

No. These are separate checks. The RND tells you whether a number was reassigned to a new subscriber. The National DNC Registry tells you whether the number's owner asked to skip telemarketing calls. You need both. Run the RND query first to confirm you're still reaching your intended contact, then run the DNC check to confirm that contact hasn't opted out. Skip either and you leave a real gap.

What is the per-call TCPA penalty for calling a reassigned number?

The base statutory damage is $500 per call under 47 U.S.C. § 227(b)(3). If a court finds the violation knowing or willful, that jumps to $1,500 per call. Each individual call or text is a separate violation. In a class action covering thousands of calls to reassigned numbers, these per-call amounts stack into eight-figure exposure before the case ever reaches trial.

What if someone changes their phone number but keeps using the old number for a while before it gets reassigned?

While the original subscriber still holds the number, your prior consent stays valid, assuming it was properly obtained and not revoked. The reassignment risk begins when the original subscriber disconnects and the carrier recycles the number to a new person. The RND tracks the permanent disconnection date, which is the dividing line. Querying the RND with your original consent date tells you whether a disconnection happened in the window that matters.

Are text messages subject to the same reassigned number rules as phone calls?

Yes. The TCPA's consent requirement covers both calls and text messages sent using an automatic telephone dialing system. The FCC has confirmed that texts to reassigned wireless numbers carry the same liability as voice calls. So your RND scrubbing process needs to cover SMS campaigns as well as dialing campaigns. The text message marketing rules and reassigned number rules run in parallel.

How can I tell if a number I'm about to call is currently active before querying the RND?

Third-party carrier lookup services, often called real-time number validation or line type lookup, can tell you whether a number is active, which carrier holds it, and whether it's wireless or landline. These services query carrier data directly and can flag obviously dead numbers before you spend your RND query budget on them. Running a carrier lookup before your RND query is a useful first filter for large, older lists.

Sources

1. Cornell LII, 47 U.S.C. § 227 (Telephone Consumer Protection Act): TCPA prohibits calls to cellular numbers using an autodialer or prerecorded voice without prior express consent of the 'called party'; statutory damages are $500 per violation, up to $1,500 for willful violations
2. FCC, Reassigned Numbers Database consumer and industry information page: The FCC RND aggregates disconnection data from all facilities-based voice providers; approximately 35 million numbers are disconnected and made available for reassignment annually
3. ICND, icnd.us Official Reassigned Numbers Database Portal terms and fee schedule: Individual number queries cost $0.005 each; bulk monthly subscriptions cap at approximately $1,595/month; callers must log queries to support safe harbor claims
4. FTC, National Do Not Call Registry, business compliance information: Businesses must access DNC Registry data no more than 31 days before calling a number; annual subscription fees start at $90 per area code
5. Cornell LII, 47 U.S.C. § 503(b) (FCC forfeiture penalties): FCC forfeiture orders for TCPA violations can reach $10,000 per violation, $100,000 per day for continuing violations, and $1 million total for a single act
6. National Conference of State Legislatures, State Laws on Robocalls and Telemarketing: Many states have enacted their own robocall and telemarketing statutes that run parallel to federal TCPA claims, creating stacked liability for multi-state outbound programs
7. FTC, National Do Not Call Registry Data Book (annual report): The National DNC Registry contains over 249 million registered phone numbers as reported in the FTC's annual Data Book
8. eCFR, 47 C.F.R. § 64.1200 (telephone solicitation rules): FCC codified the RND safe harbor in 47 C.F.R. § 64.1200, requiring callers to query the RND before calling to claim protection from liability for calls to reassigned numbers