Did the FCC's New Order Get the Wrong-Number Problem Right?


February 7, 2019

No one likes to receive a wrong-number call, and no one likes making them, either—especially businesses that may be liable for up to $1,500 in damages for each call.

Businesses have tried for years at great expense to design systems that detect when a customer or prospect has changed a cellular number, but there is no public cellular telephone number directory. And data vendors that purport to sell information identifying people that are “associated” with cellular numbers are only making educated guesses. Wrong-number class action cases continue to be filed at a rapid pace and can strike fear into the hearts of businesses like credit card issuers that may make tens of millions of calls in a year.

To address this, the Federal Communications Commission in December 2018 issued a report and adopted new rules establishing a single comprehensive database with assignment information provided by telephone carriers, which will advise when a telephone number has been disconnected and is eligible for reassignment. To encourage callers to use the database, the FCC announced a safe harbor from liability for calls to reassigned numbers caused by database error.

This webinar discussed the wrong-number problem and whether the FCC’s new database will provide businesses with the information they need to help prevent wrong-number calls. Topics included:

  • Overview of the TCPA’s application to wrong-number calls
  • Current state of wrong-number class action litigation
  • Strategies businesses employ to avoid wrong-number calls
  • Overview of the proposed FCC report and the proposed Reassigned Numbers Database
  • Overview of the safe harbor provision and how call center operations may change

Speakers included David Kalat from BRG; Debra Bernard, a partner at Perkins Coie; and Ryan Thurman, director of Sales and Marketing at Contact Center Compliance.

View the on-demand webinar.

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David Kalat