How Reassigned Numbers Create TCPA Risk: A $1.5M Lesson 

A customer gave your company permission to call a phone number three years ago. Your CRM still shows the consent record, and the number may still connect. That does not mean the same customer still uses it.

Phone numbers can be permanently disconnected and later reassigned. Your CRM may still show the original customer’s consent even after that customer stops using the number.

An outbound campaign that relies only on the old consent record can send an artificial or prerecorded call to the wrong person.

Lewis v. Register.com shows this risk. The proposed settlement creates a $1.5 million fund for claims tied to artificial or prerecorded calls that allegedly reached cellular numbers after permanent disconnection and availability for reassignment. The final fairness hearing took place on July 7, 2026. As of August 1, 2026, the official settlement website had not posted a final approval order, and a legal tracker still listed the ruling as pending. Register.com denied wrongdoing.

The case does not show that every call to an old number violates the TCPA. It does show why your consent record and the number’s disconnect history need to be reviewed together.

What the Register.com Settlement Shows Outbound Teams  

The proposed settlement class covers artificial or prerecorded voice calls allegedly placed from February 12, 2021, through November 24, 2025, after the cellular numbers had been permanently disconnected and made available for reassignment.

The court’s preliminary approval order states that Register placed 1,652 calls using artificial or prerecorded voice to 453 telephone numbers found in the FCC’s Reassigned Numbers Database. A small group of reassigned numbers can produce many wrong-party calls across one or more campaigns.

Register.com agreed to the proposed settlement without admitting wrongdoing. The court had not entered final approval as of August 1, 2026. Your team should treat the case as a compliance lesson, not as a final finding that Register.com violated the TCPA.

A consent record shows that a specific person agreed to certain outreach at a certain time. It does not show who uses the number today. Older records deserve another check when your team has not recently confirmed the phone number.

Why the Consent Date Matters  

The FCC’s Reassigned Numbers Database needs a phone number and a date. The date gives the database a point for comparison.

Your team may use the date when the customer gave consent or another date when you reasonably believed the intended person could still be reached at that number. Counsel should approve the date rule for each campaign type.

The RND checks whether the number was permanently disconnected on or after the submitted date. A later permanent disconnection can show that your team should not rely on the original consent without another review.  

This problem often appears in:

• Dormant lead and reactivation lists
• Collection accounts with long periods of inactivity
• Insurance renewal and quote follow-up campaigns
• Former-customer retention lists
• Records moved between CRMs, dialers, agencies, or vendors

Use a date from a reliable consent or contact field. A CRM creation date, file upload date, campaign date, or general record update does not prove when the customer gave permission.

What an RND Check Can and Cannot Tell You  

The FCC says the database answers whether a number was reassigned, or more accurately, permanently disconnected, since the date supplied. The RND returns one of three responses.

• Yes: The number was permanently disconnected on or after the submitted date.
• No: The database does not show a permanent disconnection on or after the submitted date.
• No data: The database lacks enough relevant data to answer the query.

A “yes” result does not identify a current subscriber or confirm that the number has already been reassigned. It only confirms a permanent disconnection on or after the submitted date.

A “no” result does not prove the intended customer still controls the number. It means the RND does not show a later permanent disconnection for that query. A caller may qualify for the FCC safe harbor after a “no” response if all applicable requirements are met.

A “no data” result is not permission to call. Send that record to another review step or suppress it under your written policy.

The RND does not replace consent records, DNC screening, internal suppression lists, revocation records, campaign rules, or legal review. It answers one question about permanent disconnection and time.

A Pre-Campaign Workflow for Consent and Reassigned Numbers  

1. Review the Phone Number  

Check validity and available connection-status, carrier, and line-type data. Remove clearly invalid or disconnected records before later checks.

Phone validation can flag invalid or disconnected numbers, but it does not identify the current subscriber or confirm whether the original consent still supports the call.  

2. Locate the Correct Consent Date  

Pull the date tied to the customer’s permission or another approved last-known-contact event. Confirm that the field comes from the system that stores the supporting record.

Do not use the CRM creation date, campaign upload date, or last file update unless that date reflects actual consent. Missing consent data should trigger review or suppression under your policy.

3. Run the RND Query  

Submit the phone number and approved date before campaign launch. Use the same date rule for records that share the same consent source and campaign purpose.

4. Route the Result  

Yes: Suppress the number or request new consent through an approved channel.

No: Continue with DNC, internal suppression, revocation, line-type, and campaign checks.

No data: Use a documented review path. Do not treat an unknown result as approval.

5. Keep the Audit Trail  

Store the queried number, submitted date, result, query timestamp, campaign name, consent source, and final action. These records help compliance staff review complaints and confirm whether campaign rules were followed.

Where Reassigned Phone Number Risk Affects Outbound Teams 

Call Centers 

Reactivation campaigns often use records without a recent phone update. Transfers between clients, lead vendors, and dialers can also remove consent details or change date formats.

Collections Teams 

A consumer’s number may change while an account remains open or inactive. A working number does not prove that it still reaches the consumer named in the file. Wrong-party contact can raise TCPA, FDCPA, privacy, and complaint-handling concerns.

 Insurance Marketers 

Quote follow-ups, policy renewals, cross-sell campaigns, and win-back lists often rely on older contact records. Each campaign needs a clear consent source, approved date field, and RND rule.

Customer-retention Teams 

Former customers may keep the same email address while changing phone numbers. A successful email interaction does not confirm control of the phone number in the same record.

TCPA Counsel and Compliance Teams 

Written policy should define the date used for RND queries, the schedule for repeat checks, the handling of “no data” results, and the records kept for each campaign.

Three Reassigned Number Compliance Mistakes to Avoid 

1. Treating Consent as Permanent Permission for the Number  : Consent comes from a person. It does not remain attached to a phone number after that person gives it up.

2. Checking Whether the Number Works Without Checking the Timeline  : A number can be active today even if it was permanently disconnected after the consent date. Current activity does not confirm that the intended customer still uses it.

3. Running RND Checks Without Keeping the Result  : A team may complete the query but fail to store the submitted date, result, or timestamp. That makes it harder to show what the team knew before the call and which policy it followed.

How Searchbug Tools Help Check Reassigned Phone Numbers 

Phone Validator  

Searchbug’s Phone Validator checks data such as phone-number validity, carrier, line type, and available connection indicators, depending on the selected API. Use it before the RND query to remove bad records and organize numbers for the correct outreach channel.

Phone Validator does not identify the current subscriber, prove consent, or show whether a permanent disconnection occurred after the consent date.

RND API  

Searchbug’s Reassigned Numbers Database API submits the phone number and approved consent or last-known-contact date to the FCC’s RND. It returns “yes,” “no,” or “no data” so your team can apply its campaign policy before outreach.

The RND API checks permanent disconnection after a date. It does not name the current subscriber or confirm who controls the number.

Conclusion  

Never check a consent record on its own. Check what happened to the number after that date, too. When teams skip this step, they risk calling someone who never gave consent and has no connection to the original customer.

The proposed Register.com settlement shows the cost that can follow when artificial or prerecorded calls reach numbers with a post-consent permanent disconnection. The case remains an allegation-based settlement unless the court grants final approval, and Register.com denied wrongdoing.

Your pre-campaign process should connect the phone number, consent source, approved date, and RND result. Other TCPA controls still apply, including revocation processing, DNC screening, internal suppression, calling-hour rules, and campaign-specific legal review.

TL;DR  

A consent record does not prove that the same person still uses the phone number. Use the consent or approved last-known-contact date with an RND query to check for a later permanent disconnection. Handle “yes” and “no data” results under a written policy, and keep the full audit trail. Use Phone Validator for number-quality data and the RND API for the date-based permanent-disconnection check.

Create your Free API Test Account with $10 credits today. Need to review phone numbers and consent-date records in bulk? Searchbug also supports Bulk Data Processing.

Editorial Note: This article provides general information only and does not constitute legal advice. Organizations should consult qualified counsel when setting TCPA compliance rules, selecting consent dates, or using the FCC Reassigned Numbers Database.