The reassigned-numbers database is the only route to the safe harbour

The requirementstatement

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

Severityseverity: HighHIGHRejected by at least one carrier or provider, and a common cause of failure at the rest.
When it bitesphase: After you are livepostFalls due once you are sending: STOP handling, quiet hours, suppression, record retention.
What is checkedobject: reassigned-numbers query, keyed on the consent date
Where it liveslayer: OperationalOPERATIONAL
How Ekas settles itdetectability: External recordEXTERNAL_DATA; The fact that settles it lives in a register we cannot query, such as the IRS file, a postal database, or another provider’s tenant. Reported as a warning with the evidence to check, not as a pass.
What the fix involvesfailureClass: Wait on someone elseTERMINAL_EXTERNAL; Needs an external system or a waiting period, such as IRS propagation, a vetting result, or a carrier queue.
Who requires itauthorities: FCC
When it appliesapplicabilityText: Applies to every 10DLC registration.

Why this rule existsrationale

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 itremediation

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.

A compliant exampleexample

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

Check this yourselfattestation

No tool can settle this one for you. Here is the check, and what wrong looks like.

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?

1Register for access to the FCC database and budget the per-query cost.
2Query with each number and the date its consent was recorded, and keep the response.
3Re-query at least every 30 days for numbers still on the list.
4Check 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.

Notesnotes

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.

Rules you will hit next

Other operational rules at the same severity. A registration is judged as a whole, not rule by rule.

OPS-034A programme in another language still owes the English keywordHighHIGH OPS-035The mandatory keywords must work over MMS tooHighHIGH OPS-044Suppression is brand-wide, not per numberHighHIGH OPS-047A state may give you less time than the federal limitHighHIGH OPS-052Silence after a scope question revokes everythingHighHIGH OPS-053A STOP answering a scope question must not be answered with anotherHighHIGH

All operational rules

OPS-087 is one of 139 operational rules in the 915-rule 10DLC registry. Free to cite under CC BY 4.0.