Reassigned Numbers Database: Checking Older Leads

The short answer

If you call or text older leads, some of those phone numbers may now belong to someone else. The FCC's Reassigned Numbers Database (RND) lets callers check whether a number has been permanently disconnected since the date they got consent. Under 47 CFR 64.1200(m), a caller is not liable for reaching a reassigned number if it queried the database, received a “no” (not disconnected since consent), and the database's answer turned out to be wrong. The caller carries the burden of proof, so the query has to happen and be recorded before the call.

Why reassigned numbers matter for lead buyers

Consent attaches to a person and a number at a point in time. When that person gives up the number and the carrier reassigns it, your old consent doesn't cover the new subscriber. That matters most for:

Aged or re-worked leads pulled back into a calling or texting campaign.
Leads that sat unanswered for weeks before follow-up.
Numbers saved in a CRM for long-term nurturing.

How the RND works

The FCC rule has two parts:

Carriers report disconnections. Under 64.1200(l), reporting carriers must keep records of the most recent date each number was permanently disconnected and report it to the database administrator monthly, on the 15th. A number that is ported to another provider is not treated as permanently disconnected.
Callers can query. The RND site lets registered callers research specific numbers before calling to see whether they've been permanently disconnected. Subscriptions are paid, and agents can query on a caller's behalf.

A query uses the number plus the date you obtained consent. The database answers whether the number has been permanently disconnected since that date.

What the safe harbor covers, and what it doesn't

From the text of 64.1200(m), the protection applies when:

You had prior express consent for calls covered by 64.1200(a)(1), (2), or (3);
You queried the database with the number and the consent date, using the most recent data, and got a “no”; and
The call reached a new subscriber because the database erroneously returned “no.”

What it doesn't do:

It doesn't create consent you never had.
It doesn't help if you skipped the query or can't show it.
It doesn't replace Do Not Call, calling-hours, or opt-out rules. See our posts on Do Not Call rules, lead calling hours in Texas, and FCC opt-out changes.

A simple workflow for older leads

Store the consent date with every lead, not just the lead date.
Set an age threshold (for example, anything older than your normal follow-up window) that triggers an RND check before the next call or text campaign. That threshold is a business choice, not an FCC number.
Log the query result with the lead record.
Fresh consent beats old consent. If a lead is stale, a new opt-in is cleaner than relying on an old one.
Speed still matters. Most of these problems shrink when leads are contacted promptly; see after-hours response gaps.

This is general information, not legal advice. Talk to counsel about how the TCPA applies to your specific campaigns.

Who should prioritize this

RND checks are most useful for teams that:

Buy or recycle aged leads.
Run text or autodial campaigns that need prior express consent.
Keep phone numbers in a CRM for months after the first enquiry.

If every lead is called the same day it arrives and never reused, your reassignment risk is lower — but it doesn't go to zero, because a number can be disconnected and reassigned after the lead comes in. Fresh consent and clean records still matter.

How TX Lead Forge fits in

Automotive seller enquiries through TX Lead Forge are competing offers: a seller may hear from more than one dealer, so contact promptly and respectfully. Roofing and real-estate leads are exclusive. Lead-quality issues are reviewed case by case, and we don't promise credits or replacements for any category. Learn more about automotive leads.

Bottom line

Old consent can point to a new person. Querying the FCC's Reassigned Numbers Database with the consent date before you re-contact older leads gives you a documented check and, if the database is wrong, a defined safe harbor under 64.1200(m).

Looking at lead sources? Ask about competing auto seller enquiries, or exclusive roofing and real-estate leads, through TX Lead Forge.