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Compliance & consent

Reassigned Numbers Database — RND

What is Reassigned Numbers Database?

The Reassigned Numbers Database (RND) is the FCC's centralized registry for checking whether a US phone number has been reassigned to a new subscriber since a business originally captured consent for it. Before placing a call or sending a text, a sender submits the number together with the date consent was captured and receives back a verdict — yes, no, or no_data — that tells it whether the consent it holds still belongs to the person now on that number.

More detail

Phone numbers in the US are recycled constantly, and consent travels with the person, not the number. A sender who texts a reassigned number on stale consent is contacting a stranger, and accepts the TCPA exposure that comes with it — statutory damages of $500 to $1,500 per call or text, with no upper aggregate cap in a class action.

Orbit runs the RND check as a send gate on the messaging and dialer pipeline: each outbound request carries the recipient's recorded consent date, the registry returns a yes/no/no_data verdict, and a hit (reassigned since consent date, treated as 'no') or unresolvable verdict drops the contact from the batch before dispatch. The gate is tenant-owned — you enable it per campaign, and the consent-date verdict falls back open where a sending stack has no consent date recorded.

The verdict is a snapshot of a moving database. Carriers report reassignment events into the FCC registry on their own lag, so the cleanest practice is to gate immediately before dispatch rather than as a weekly list-washing pass.

Frequently asked

What do the RND verdicts yes, no, and no_data actually mean?
'Yes' means the registry believes the number was NOT reassigned since the consent date you submitted, so your existing consent still reaches the same subscriber. 'No' means the number has been reassigned after that date — consent is no longer valid and the send must be stopped. 'no_data' means the registry can't confirm either way, which compliant senders treat as a hold, not a proceed.
Is querying the RND mandatory before every call or text?
Querying isn't itself mandated with the same force as the federal TCPA consent rule, but the TCPA assigns liability per wrong-party message and the FCC positions the RND as the primary mechanism to avoid it. Most senders gate on it as standard practice — it's cheap to query and expensive to skip.
Does the RND apply only to marketing?
No — reassignment affects consent for any message to a given number, including purely transactional or informational ones. The safest implementation checks every outbound destination against the date of the consent you hold for it, whatever the message category.

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