# OPS-087 — The reassigned-numbers database is the only route to the safe harbour

> The FCC Reassigned Numbers Database must be queried using the date of consent, and re-queried at least every 30 days.

- **Rule ID:** OPS-087
- **Layer:** Operational (`OPERATIONAL`)
- **Checks:** `reassigned-numbers query, keyed on the consent date`
- **Severity:** HIGH — Rejected by at least one carrier or provider, and a common cause of failure at the rest.
- **When it bites:** Falls due after approval, once you are live and sending
- **How it is detected:** External record we cannot query — reported as a warning to verify
- **Fix type:** Wait on an external system or a required interval
- **Required by:** FCC
- **Applies:** Applies to every 10DLC registration.
- **Canonical URL:** https://ekas.io/rules/10dlc/operational/ops-087/

## Why this rule exists

The database is the one mechanism that converts "we messaged the wrong person" from strict liability into a defence, and the defence turns entirely on querying with the date consent was obtained — a query without that date proves nothing about whether the number had already moved on. Brands skip it because it is a paid lookup that returns nothing useful most of the time, which is exactly what an insurance policy looks like.

## How to fix it

Query the database with each number and the date its consent was recorded, keep the response, and re-query at least monthly for numbers still on the list. Done when you can produce, for any number you messaged, the query that said it had not been reassigned since consent.

## Example of a compliant value

```text
Monthly: submit (msisdn, consent_date) for every active subscriber; retain the response as the safe-harbour record.
```

## Check this yourself

**For any number you messaged, can you produce a Reassigned Numbers Database query, made with the real consent date, saying it had not been reassigned?**

1. Register for access to the FCC database and budget the per-query cost.
2. Query with each number and the date its consent was recorded, and keep the response.
3. Re-query at least every 30 days for numbers still on the list.
4. Check the consent date you submit is the real one — the safe harbour is only as good as that field.

*What wrong looks like:* The lookup is skipped because it is paid and returns nothing useful most of the time, which is exactly what an insurance policy looks like. Without it, messaging the wrong person is strict liability rather than a defence.

## Notes

A paid federal lookup we cannot make on the brand's behalf. What the user has to do is register for access, budget the per-query cost, and — the part most often missed — make sure the consent date they submit is the real one, because the safe harbour is only as good as that field. OPS-199 covers keeping the date in the first place.