Written by: Matt Beucler, CEO, Plura AI
Updated September 2026
Key Takeaways
- The Reassigned Numbers Database (RND) is the FCC-mandated registry that lets callers check if a number has been permanently disconnected and reassigned, which can provide safe harbor from TCPA liability when queried before calling.2
- Approximately 35 million U.S. mobile numbers are reassigned each year, so RND scrubbing helps reduce exposure to $500–$1,500 statutory damages per unauthorized call or text.3
- Safe harbor protection requires valid prior consent, a pre-call query against the most recent monthly RND data, and reliance on an erroneous “no” response. “No Data” answers do not provide protection.
- Manual portal queries are slow and error-prone. API integration into dialing systems enables real-time, automated checks that close the gap between batch scrubs and actual dialing.
- Plura AI’s compliance engine automates RND screening alongside DNC and litigator filtering before every outbound contact, helping teams support compliance at scale.
Why the RND Matters for TCPA Compliance
TCPA consent attaches to the person, not the phone number. When a number is reassigned, any prior consent becomes worthless, and the caller is exposed to liability for every subsequent contact.
The scale of the problem is significant. Approximately 35 million U.S. mobile numbers are disconnected and made available for reassignment each year, according to the FCC. After a 45-day aging period following disconnection, a relinquished number can be issued to a new subscriber.
Each call or text to a reassigned number without fresh consent is a separate TCPA violation carrying $500 in statutory damages, trebled to $1,500 for knowing or willful violations under 47 U.S.C. § 227(b)(3).2 A campaign dialing 50,000 numbers can generate 50,000 individual claims.
That scale is why the RND matters. The RND is the only government-sourced registry that answers whether a number has been permanently disconnected since a specific date. Commercial substitutes do not carry the same regulatory weight for safe harbor purposes.
See automated RND integration in a live Plura demo and review how it fits into a carrier-grade compliance engine.

How the RND Works: Data Sources and Monthly Updates
To use the RND effectively, leaders need a clear view of where its data comes from and how often it refreshes. Wireless and wireline carriers submit permanent disconnection records to the RND monthly, covering data through at least the 10th of each month, no later than the 15th. The database refreshes once monthly, and operators maintaining safe harbor should run checks after each mid-month update.
Every RND query requires two data points:
- The 10-digit phone number
- The date of last verified consent, which is the later of the date consent was obtained or the last date the consumer was confirmed on that number
The RND returns one of three responses, and only one of them preserves safe harbor protection:
- “Yes”: The number was permanently disconnected after the consent date. Reassignment is likely. Suppress immediately and add to your internal do-not-call list. Safe harbor does not apply.
- “No”: No permanent disconnection on record since the consent date. Safe harbor can apply if the response later proves incorrect, provided all other conditions are met.
- “No Data”: Insufficient records to determine status. No safe harbor applies in either direction. Treat conservatively or layer commercial phone-intelligence data on top.
The RND does not reveal the new subscriber’s identity. It only answers whether a permanent disconnection occurred after the supplied date.
RND Safe Harbor: What It Protects and What It Does
The FCC’s safe harbor rule, codified at 47 C.F.R. § 64.1200(l), protects callers who query the RND before calling and receive a “no” response, even if that response turns out to be wrong.2
To qualify for safe harbor, a caller must establish all four elements:
- Valid prior express consent to call the number before reassignment
- The call was made after reassignment occurred
- The number was checked against the most recent RND data before calling and returned a “no” response
- The call happened because the database erroneously returned that “no”
Safe harbor coverage excludes several common scenarios:
- Calls made without querying the RND
- Calls placed after a “yes” response
- Queries that are stale and not against the most recent data
- “No Data” responses
- Calls where consent never existed
The safe harbor is one call deep. If the new subscriber signals a wrong number, the caller cannot place another call and still claim protection.
Step-By-Step RND Check: Verifying If a Number Was Reassigned
Manual Reassigned Numbers Database lookup through the official portal follows this sequence:
- Create an account at reassigned.us, the FCC-contracted administrator.
- Purchase a subscription tier matching your query volume.
- Submit the phone number and the date of last verified consent.
- Upload lists in batches of up to 50 numbers via the web interface, or use SFTP or API for bulk queries of up to 250,000 numbers per batch.
- Interpret responses: “Yes” means suppress immediately. “No” means safe harbor can apply if the answer proves wrong. “No Data” means no safe harbor and conservative handling is warranted.
Log every query date, consent date, and result. FCC rules require records sufficient to support a safe harbor claim, and those logs are often the first documents a plaintiff’s attorney or regulator will request.
Scrubbing Frequency and Practical RND Habits
The FCC’s safe harbor framework requires querying the RND against the most recent available data before a call. Since carriers update data monthly by the 15th, operators maintaining safe harbor should run checks after each mid-month refresh.
Practical scrubbing guidelines for ongoing programs include the following:
- Scrub new lists before the first call.
- Re-scrub at least monthly for ongoing programs, after the 15th.
- Log every query date, consent date, and result for audit readiness.
- For consents older than 90 days, reassignment risk compounds and the RND becomes essential.
- For fresh leads contacted within days of opt-in, reassignment risk is lower, so teams often prioritize validation and litigator screening.
- Automate RND checks inside the dialing system to reduce manual error and close the gap between batch scrubs and actual dialing.
These guidelines apply to voice calls, but they are equally important for SMS. Text messages are subject to the same reassigned number rules as phone calls. The TCPA’s consent requirement covers both calls and texts sent using an automatic telephone dialing system, so RND scrubbing should cover SMS campaigns as well.
RND Costs and Subscription Tiers
Once you have a scrubbing cadence, the next practical question is what this compliance step costs. The RND is not free. It operates on a paid subscription model priced by query volume. In April 2025, the FCC reduced every pricing tier by 20% and added two new lower-volume tiers.
Effective per-query costs range from approximately $0.0025 at high-volume tiers to $0.05 for low-volume Extra Small subscriptions.3 Third-party pass-through services that offer API access to RND data typically charge $0.01 to $0.05 per number, with the premium covering API convenience and additional data layers.
For a small outbound team dialing approximately 10,000 numbers monthly, direct RND queries cost roughly $50 per month3, which is modest compared to a single $500-per-call TCPA violation. A typical TCPA settlement routinely runs six or seven figures even for small defendants.
API Integration and Automation: Manual vs Automated RND Querying
The RND offers API access for automated queries, which enables real-time scrubbing integrated directly into dialing systems. Automated RND checks integrated into the scrubbing workflow remove the need for manual queries and help reduce calls to numbers that no longer belong to the intended recipient.
The table below contrasts manual portal queries with automated API integration across the factors that matter most for compliance leaders: speed, error risk, scalability, audit trail, and safe harbor consistency.
Platforms like Plura AI include built-in RND integration as part of their compliance engine. This setup enforces checks before every outbound contact. Built on Plura’s own FCC-licensed carrier infrastructure, compliance controls operate at the network level rather than as an afterthought.

Watch real-time RND screening in action alongside DNC scrubbing and TCPA-litigator filtering.

Common RND Compliance Mistakes and How to Avoid Them
Even well-intentioned programs can lose safe harbor protection through avoidable errors. The most frequent mistakes follow a few recurring patterns, and each has a clear fix.
- Failing to query within 30 days of the call. Avoid this by re-querying monthly after the 15th, since safe harbor requires checking against the most recent RND data.
- Relying on outdated lists. A list scrubbed once at acquisition and dialed for months does not protect later calls, so build recurring scrubs into your workflow.
- Ignoring “No Data” responses. These carry no safe harbor. Treat them conservatively or layer commercial phone-intelligence data on top before proceeding.
- Not documenting queries. FCC rules require records sufficient to support a safe harbor claim, so log query dates, consent dates, and results.
- Using non-compliant third-party data. Verify that your vendor actually queries the RND, and confirm this during the walkthrough.
- Calling after a “Yes” response. Suppress the number immediately and add it to your internal do-not-call list, since the FCC does not extend safe harbor to those calls.
- Confusing the RND with the National DNC Registry. The RND and the National Do Not Call Registry address different risks, so teams typically run both checks in sequence, with RND first and then DNC suppression.
Frequently Asked Questions
How Long Before Phone Numbers Are Reassigned?
After a 45-day aging period following disconnection, a relinquished number can be issued to a new subscriber. The 35 million reassigned numbers mentioned earlier mean a contact list that was accurate at acquisition can contain reassigned numbers within weeks, especially for programs with long sales cycles or dormant lead pools.
Is the RND Free?
The RND is subscription-based and priced by query volume. The FCC reduced all tiers by 20% in April 2025 and added two new lower-volume tiers. Per-query costs range from roughly $0.0025 at high-volume tiers to $0.05 for low-volume plans. Third-party pass-through services typically charge $0.01 to $0.05 per number. For a team dialing 10,000 numbers monthly, direct RND queries cost approximately $50 per month, which is a fraction of the exposure from a single TCPA violation.
What Is the RND Safe Harbor?
Under 47 C.F.R. § 64.1200(l), callers who query the RND before calling and receive a “no” response are protected from TCPA liability, even if the database response was incorrect. The protection requires valid prior consent, a pre-call query against the most recent data, and reliance on an erroneous “no.” The safe harbor is one call deep, so if the new subscriber signals a wrong number, the caller cannot place another call and still claim protection. Safe harbor does not extend to calls made without querying, calls after a “yes” response, stale queries, “No Data” responses, or calls where consent never existed.
How Do I Check If a Number Has Been Reassigned?
Create an account at reassigned.us, purchase a subscription tier matching your query volume, and submit the phone number plus your date of last verified consent. The database returns “Yes” for reassigned since your date, “No” for not reassigned since your date, or “No Data” for insufficient records. Batches of up to 50 numbers can be submitted through the web interface, and larger volumes use SFTP or API. For high-volume programs, API integration into the dialing system removes manual steps and closes the gap between batch scrubs and actual dial time.
How Often Should I Scrub Against the RND?
To maintain safe harbor, the RND should be queried against the most recent available data before each call. Since carriers update data monthly by the 15th, operators running ongoing programs often re-query after each mid-month refresh. For new lists, teams typically scrub before the first call. For consents older than 90 days, reassignment risk is elevated and the RND check becomes particularly important. Operators should consult qualified counsel to determine the appropriate cadence for their specific programs and risk profile.
What Are the Penalties for Calling a Reassigned Number?
Each call or text to a reassigned number without fresh consent is a separate TCPA violation carrying statutory damages of $500 to $1,500 per violation, as discussed earlier. The FCC can also issue forfeiture orders for TCPA violations. A single campaign dialing tens of thousands of numbers can generate tens of thousands of individual claims. Typical TCPA settlements routinely run six or seven figures even for smaller defendants, with legal fees alone often reaching $50,000 to $150,000 before resolution.
Automate RND Compliance with Plura AI
The RND is a foundational tool for TCPA compliance, and safe harbor depends on disciplined, documented, pre-call querying. Manual processes do not scale and leave gaps between batch scrubs and actual dialing, which is where reassignments often slip through.
Plura AI’s compliance engine includes real-time RND screening, DNC scrubbing, and TCPA-litigator filtering. All of these are enforced before dial. Built on Plura’s own FCC-licensed carrier infrastructure, compliance controls operate at the network level. The AI Predictive Dialer runs every outbound contact through this compliance layer automatically, with timestamped, audit-ready records available on demand. Consent records are immutable and exportable in one click.
Plura supports compliance by providing the tools. It does not absolve operators of their own regulatory obligations. Operators remain responsible for their consent practices, recordkeeping, and the claims they make to their own end users.
For high-volume operators placing thousands of calls or texts monthly, the math is straightforward. Automated RND integration costs fractions of a cent per query compared with $500 to $1,500 per violation. The ROI calculator shows how that arithmetic compounds across a full program.
1 Plura AI maintains SOC 2, HIPAA, ISO, and GDPR posture as part of its platform infrastructure. References to compliance frameworks in this article describe Plura’s platform capabilities and do not constitute a guarantee that any customer using Plura will themselves be compliant with applicable laws or standards. Customers remain solely responsible for their own regulatory obligations, certifications, consent management, recordkeeping, and the claims they make to their own end users. Consult qualified legal counsel for guidance specific to your use case.
2 This article describes regulatory frameworks at a general level and does not constitute legal advice. Laws and regulations vary by jurisdiction, change over time, and apply differently depending on facts and circumstances. Readers should consult qualified legal counsel before making compliance decisions.
3 Performance figures, customer outcomes, and industry statistics referenced in this article are drawn from cited third-party sources or Plura customer case studies. Individual results vary based on implementation, use case, industry, audience, and execution. Past or aggregate performance is not a guarantee of future results.
This article is provided for informational purposes only and reflects Plura AI’s understanding at the time of publication. Product capabilities, integrations, and specifications are subject to change. For the most current information, visit plura.ai.
This article was produced with the assistance of AI tools and reviewed by Plura AI prior to publication.