{
  "id": "OPS-088",
  "slug": "ops-088",
  "title": "Some states make reassigned-number screening mandatory",
  "statement": "Where a state requires it, reassigned-number screening is an obligation rather than a safe-harbour option.",
  "rationale": "Maine converts the federal safe harbour into a duty, which changes the calculus completely: skipping the lookup is no longer accepting a risk, it is a violation on its own terms. National programmes miss it because the federal framing — screen if you want the defence — is the one everybody read.",
  "layer": "OPERATIONAL",
  "layerSlug": "operational",
  "object": "reassigned-number screening policy",
  "severity": "HIGH",
  "detectability": [
    "EXTERNAL_DATA"
  ],
  "failureClass": "TERMINAL_EXTERNAL",
  "authorities": [
    "state law (ME)"
  ],
  "applicabilityText": "Applies to every 10DLC registration.",
  "universal": true,
  "remediation": "Screen every number rather than maintaining a state-conditional policy — the lookup is the same one the safe harbour needs, so doing it universally satisfies both. Done when screening is unconditional rather than triggered by a state field you may not hold.",
  "notes": "Needs the recipient state, which we do not hold and which is not the area code. What the user has to decide is whether to screen universally or to build state-conditional logic on top of location data they can defend — the first is cheaper than it looks.",
  "phase": "post",
  "automated": false,
  "attestation": {
    "question": "Is reassigned-number screening unconditional, rather than triggered by a state field you may not hold?",
    "howToCheck": [
      "Decide between screening every number and building state-conditional logic on location data you can defend. The first is cheaper than it looks.",
      "It is the same lookup the federal safe harbour needs, so doing it universally satisfies both."
    ],
    "failureLooksLike": "Maine converts the federal safe harbour into a duty. National programmes miss it because the federal framing — screen if you want the defence — is the one everybody read."
  },
  "url": "https://ekas.io/rules/10dlc/operational/ops-088/",
  "markdown": "https://ekas.io/rules/10dlc/operational/ops-088.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}