Quick Guide to Reassigned Numbers

“All the human and animal manure which the world wastes, if returned to the land, instead of being thrown into the sea, would suffice to nourish the world.”
- Victor Hugo, Les Misérables

Just as nature’s ecosystems rely on waste becoming fertilizer, telephonic ecosystems rely on a dead or inactive phone number being recycled into an active one. And as farmers must understand their ecosystems in order to succeed, telemarketers must understand theirs.

Recycled or reassigned numbers are a significant source of potential liability for telemarketers under the Telephone Consumer Protection Act (TCPA). For example, a major investment bank once paid a $3.75 million TCPA settlement stemming from 675,000 phone calls to reassigned numbers. Avoiding these sorts of violations is a complicated but essential element of TCPA compliance.

This guide will answer the following questions:
• What are reassigned numbers?
• Why are they especially dangerous for marketers?
• Do marketers have any resources or recourse—such as a safe harbor—for good-faith mistakes?

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