CFA has joined National Consumer Law Center, Consumer Action, Consumers Union, National Association of Consumer Advocates, Public Citizen, Public Knowledge, and U.S. PIRG to support the Federal Communications Commission's proposal to form a reassigned numbers database. In these comments, we make specific recommendations regarding the salient details of such a database. We recommend that the Commission incorporate a number of principles in its implementation, including requiring that all providers of telephone service participate; that information be reported on a timely basis to the database; and that the calling industry should be responsible for bearing the costs of the database. We encourage the Commission to ensure incentives for compliance with the Telephone Consumer Protection Act are built into the structure of the database. We do not dispute that a short and finite grace period for users of the database may be appropriate, but we oppose a safe harbor protecting callers from liability simply for using the database.

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