Concora Credit TCPA Settlement: Why Reassigned Numbers Need Ongoing Checks 

A phone number can be correct when a customer opens an account and wrong months or years later.

The customer may disconnect the line or stop using the number. After a period of time, that number can be reassigned to someone else. The lender, card issuer, or collection agency may still have the old number attached to the original customer record.

That creates a problem for automated outreach. The business may have a record showing that the original customer provided the number, but the person receiving the call now may have no relationship with the company.

The preliminary settlement in Seals v. Concora Credit Inc. shows why lenders, collectors, and servicing teams should not treat phone verification as a one-time onboarding step. Phone-number records can change, so reassignment checks may need to be part of ongoing outbound workflows.

TL;DR    

• A customer phone number can be valid when collected and later be reassigned to another person.
• The preliminary Concora Credit settlement package totals $9.375 million, including an $8.375 million settlement fund and $1 million in required TCPA compliance spending.
• Court records identify approximately 147,083 affected phone numbers, not 147,083 total calls.
• Concora’s required compliance spending includes heightened reassigned-number procedures and use of the FCC’s Reassigned Numbers Database.
• Lenders, collectors, and servicing teams should consider reassignment checks before applicable outbound activity, especially when working with older customer records.

What Happened in the Seals v. Concora Credit TCPA Settlement    

The proposed settlement covers a class of people in the United States whose cell phone numbers received an artificial or prerecorded voice call placed or caused by Concora Credit between May 2, 2021 and May 31, 2026, when the number was not assigned to a Concora account holder.

The court granted preliminary approval on August 5, 2026. Final approval has not yet been granted. A final fairness hearing is scheduled for November 24, 2026.

The court’s preliminary approval order states that the plaintiff identified approximately 147,083 affected cell phone numbers. That figure should not be described as 147,083 robocalls because one number may have received more than one call.

The total proposed settlement package is $9.375 million, but that amount is not one cash payment to class members. It consists of:

• $8.375 million placed into a settlement fund
• $1 million in mandatory TCPA compliance spending over three years

The $8.375 million fund will be used for approved claimant payments and certain settlement expenses. These expenses may include administration, attorneys’ fees, litigation costs, and a proposed incentive award.

Approved claimants are estimated to receive $250 to $650 each. The actual payment may be higher or lower depending on the number of approved claims and the amounts deducted from the settlement fund. The deadline to submit a claim is October 19, 2026.

The settlement resolves disputed allegations and is not a final court finding that Concora violated the TCPA. Concora has not admitted wrongdoing by agreeing to the proposed settlement.

Why the $1 Million Compliance Requirement Matters    

The cash portion of the settlement may receive most of the attention, but the required compliance spending is especially relevant for financial services companies.

According to the official settlement FAQ, Concora must spend at least $1 million within three years on TCPA compliance measures. The spending will focus on stronger procedures involving reassigned telephone numbers, including use of the Federal Communications Commission’s Reassigned Numbers Database. It will also cover periodic internal audits, employee training, and related TCPA compliance policies.

Use of the FCC database is not simply an outside recommendation. The settlement itself requires it.

That requirement directly addresses an operational problem that can cause wrong-number calls.

A business may collect a valid phone number from a customer and record when the customer provided it. That information can become outdated when the customer disconnects the number and it is later assigned to someone else.

The company must then consider more than whether the number was valid when it was collected. It must also consider whether the number may have been reassigned since the relevant consent date.

Why Reassigned Numbers Create TCPA Risk    

Consider a common account lifecycle.

A borrower applies for credit and provides a mobile number. The lender saves the number with the customer account.

The customer later disconnects the line, but the lender may not receive notice of that change. The provider can eventually make the number available to another subscriber.

Months later, the original account enters a servicing or collections workflow. The stored number remains in the system, so automated calls may be placed to the new subscriber.

The original contact record can remain unchanged inside a customer relationship management system or collections platform even though the number is now assigned to someone else. The current recipient may never have provided the number or consented to the calls.

This risk can affect:

• Credit card servicing
• Payment reminders
• Account-management calls
• Collections outreach
• Prerecorded messages
• Automated calling campaigns
• Older accounts returning to active collections

A database showing that a number exists does not answer whether it still belongs to the person associated with the consent record. That requires a different type of review.

Why Onboarding Checks Alone Are Not Enough    

Checking a phone number when a customer opens an account is useful, but the result describes the number at that point in time. It does not establish that the same customer will control the number months or years later.

Several operational gaps can develop after onboarding.

A lender may validate the number during an application but never review it again. A collection agency may receive an older portfolio containing numbers collected years earlier. A servicing team may restart outreach after a long period without successful customer contact.

In each case, the dialing system may continue using the last number stored with the account.

Reassigned-number review should therefore be connected to the outbound workflow instead of being limited to account opening. Possible review points include:

• Before applicable automated calls
• Before prerecorded voice campaigns
• When older accounts return to active outreach
• Before working aged collection portfolios
• After a long period without successful customer contact
• Before processing older calling lists

Each organization should determine when these checks are appropriate based on its calling methods, consent records, policies, and legal requirements.

How the FCC Reassigned Numbers Database Works    

The FCC created the Reassigned Numbers Database, or RND, to help callers determine whether a telephone number was permanently disconnected after the caller obtained consent or otherwise confirmed the customer could be reached at that number.

For a query, the caller provides a phone number and a relevant date. According to the FCC, that date may be when consent was obtained or another date when the caller could reasonably be certain that the consumer could still be reached at the number.

The database can return three responses:

• YES: The number was permanently disconnected on or after the submitted date.
• NO: Under the FCC’s response rules, the database does not show that the number was permanently disconnected after the submitted date.
• NO DATA: The database does not contain enough information to return YES or NO.

These responses should not be treated as interchangeable.

A YES response indicates that the number was permanently disconnected after the submitted date. The record should then follow the organization’s procedures for potential reassignment rather than automatically continuing through the calling workflow.

A NO DATA response should not automatically be treated as NO. The organization should decide how incomplete results are handled before calls are placed.

The FCC also created a TCPA safe harbor for certain good-faith callers when the database incorrectly returns NO. The requirements are specific, so businesses should not assume that submitting any RND query automatically provides safe-harbor protection.

How Searchbug Supports Reassigned-Number Review    

Searchbug offers two tools that can support different parts of a phone-data review. The RND API addresses possible reassignment after a relevant date, while Phone Validator provides additional information about the number.

Reassigned Numbers Database API    

For teams managing repeated outbound activity, checking numbers one at a time may not fit normal servicing or collections operations.

Searchbug’s Reassigned Numbers Database API allows RND checks to be added to existing business workflows.

A business submits the phone number and relevant date. The query returns YES, NO, or NO DATA, which the business can handle according to its compliance procedures.

For lenders and collectors, the check can be placed before applicable outbound activity rather than being limited to account opening. A lender could add an RND check when an older account returns to an automated calling campaign. A collection agency could review eligible numbers before loading an aged portfolio into a dialer.

The result does not confirm who currently owns or controls the phone number. It also does not make the final compliance decision.

Its purpose is narrower. It helps determine whether the number was permanently disconnected after the relevant date so the organization can decide what action its procedures require.

Phone Validator    

The RND addresses a specific reassignment question. Other phone data can support a broader review of the contact record.

Phone Validator can provide phone status, carrier, and line-type information. Line-type data can indicate whether a number is associated with wireless, landline, or VoIP service. Status and carrier information can provide more context when a team reviews an older phone record.

These fields do not prove that a particular person owns or controls the number. They also do not replace an RND query when the question is whether the number was permanently disconnected after the relevant consent date.

The two tools answer different questions:

• Phone Validator: What confirmed information is available about this phone number?
• RND: Was the number permanently disconnected after the relevant date?

For older customer records, the results can support different parts of the review process.

A Practical Workflow for Lenders, Collectors, and Servicing Teams    

Reassigned-number controls can begin with a documented workflow:

1. Capture the phone number. Store the number connected with the customer account.
2. Record the relevant consent date. An RND query requires a meaningful date to compare with disconnect data.
3. Keep the consent record connected with the phone record. Separating the two can make future reviews difficult.
4. Review older numbers before applicable outbound activity. This is particularly important when an account has been inactive or the organization has not reached the customer for a long period.
5. Use the RND where appropriate. Submit the number and relevant date before the call enters the applicable automated workflow.
6. Create procedures for YES, NO, and NO DATA. Employees should not have to decide what each result means without an established process.
7. Update suppression and customer records. If a number should no longer be used, that decision must reach the systems controlling future outreach.
8. Keep records of completed checks. Compliance teams should be able to determine when a check occurred and what response was returned.

A documented process can be especially useful for small lenders and independent collection agencies that do not have large compliance departments. It helps teams apply the same checks across accounts instead of relying on a different manual decision each time.

Legal and compliance teams should determine how RND responses, consent records, suppression procedures, and dialing rules apply to the organization’s specific operations.

Conclusion    

Phone information does not remain accurate simply because it was accurate when an account was opened.

For lenders, collectors, and financial services call centers, ongoing phone-data maintenance can help identify records that need review before applicable automated outreach. RND checks address the specific question of permanent disconnection after a relevant date, while Phone Validator provides additional information about the number.

These checks do not replace legal review or internal compliance procedures. They provide data that teams can use when deciding whether a number should move forward in an outbound workflow.

Create a free Searchbug API Test Account and get $10 in credits to test phone validation and reassigned-number checks in your workflow. Teams working with larger datasets can also use Searchbug Bulk Processing for high-volume phone-data review.

Editorial note: This article is for general informational purposes only and is not legal advice. The Seals v. Concora Credit settlement had received preliminary approval as of publication and remained subject to final court approval.