STIR/SHAKEN & TCPA Compliance: The Definitive Guide for 2025

TCPA Basics

The Telephone Consumer Protection Act (TCPA) restricts:

• Autodialed or prerecorded calls to wireless numbers without consent
• Text messages to wireless numbers without consent
• Calls to numbers on the Do Not Call registry
• Fax advertisements without prior consent

Violations can result in statutory damages of $500-$1,500 per call or text.

The Reassigned Number Problem

When someone disconnects their phone, carriers reassign that number to new customers. Your consent from the original owner does not transfer to the new owner.

• ~35 million numbers are reassigned annually in the US
• Each call to a reassigned number is a potential violation
• Class actions target businesses that call reassigned numbers at scale

How LRN Activation Date Helps

LRN Activation Date reveals when a phone number was last ported to its current carrier. By comparing this date against when you obtained consent, you can identify numbers that may have been reassigned:

# Before calling, check for potential reassignment
consent_date = record.consent_obtained_date
activation_date = lookup_result['lrn']['activation_date']

if activation_date > consent_date:
    # Number was ported/activated AFTER consent was obtained
    # It may belong to someone else now
    do_not_call_without_verification()

This supports the "reasonable procedures" defense under FCC safe harbor provisions.

FCC Safe Harbor

The FCC provides a safe harbor for callers who implement reasonable procedures to identify reassigned numbers. While requirements vary, phone intelligence supports this by:

1. Validating numbers before calling campaigns
2. Checking LRN Activation Date against consent date
3. Flagging potentially reassigned numbers
4. Documenting validation procedures

Note: Consult legal counsel for specific safe harbor requirements. Phone intelligence is one component of a compliance program, not a complete solution.

Compliance Workflow

Before Campaigns

1. Validate all phone numbers for validity and line type
2. Check LRN Activation Date against consent dates
3. Flag numbers activated after consent for review
4. Scrub against DNC lists (federal and state)
5. Document your validation procedures

During Calls

1. If someone says "wrong number," stop immediately
2. Document wrong-party contacts
3. Update your records

Ongoing

1. Re-validate periodically (numbers change)
2. Monitor for revoked consent
3. Maintain documentation

Line Type Considerations

TCPA rules differ by line type:

Line Type	TCPA Requirements
Wireless	Prior express consent required for autodialed/prerecorded calls
Landline	Less restrictive for autodialed calls (some exceptions)
VoIP	Generally treated as wireless if mobile VoIP

Use line type detection to apply appropriate compliance rules.

Frequently Asked Questions

What are TCPA penalties?

TCPA violations can result in $500 per violation for negligent violations and up to $1,500 per violation for willful violations. These add up quickly in class actions involving thousands of calls.

Does consent transfer when a number is reassigned?

No. Consent is given by a specific person, not attached to a phone number. When a number is reassigned to a new owner, you do not have their consent, even if the previous owner consented.

How does phone intelligence help with TCPA compliance?

Phone intelligence helps by detecting reassigned numbers before you call, identifying line types for appropriate consent levels, and documenting validation procedures. LRN Activation Date shows when numbers were last ported, helping identify potential reassignments.

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