In reply comments filed with the Federal Communications Commission (FCC) in the matter of advanced methods to target and eliminate unlawful robocalls, CFA and other public interest groups strongly support the FCC’s consideration of the creation of a reassigned number database. If designed correctly, the database should provide an efficient means for callers to protect themselves from Telephone Consumer Protection Act (TCPA) liability by checking the database. But use of the database should not shield callers from liability for other violations of the TCPA. We propose a safe harbor that a caller could use to avoid liability for a call made to a reassigned number only when certain conditions apply.

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