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.
Get a free test to identify reassigned numbers in your data.
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 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.
TCPA Reassigned ID Product Benefits:
- Accesses the most comprehensive and accurate telephone network data
- Flag whether a phone number has been reassigned since the consent date
- Identifies line type as well as whether a phone number is valid or not
- 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
“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
Frequently Asked Questions
How long before a cell phone number is reassigned?
Federal regulations (Title 47 CFR §52.15 (f)(1)(ii)) state that a phone number can be assigned to a new subscriber as soon as 45 days from being returned to the carrier.
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. Marketers can obtain safe harbor under certain circumstances by checking a qualified source for number reassignment before dialing.
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. Until they are reassigned, many returned phone numbers are being converted to honeypots. Carriers monitor traffic to these numbers to help assist in detecting non-compliant organizations, they use that data as a factor in determining if they should label a caller as SPAM or even potentially block their calls.
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.
Get a free test to identify how much of your data contains reassigned phone numbers.
Schedule a meeting with us.
