Auto Attendant Article
Porting a Toll-Free Number: RespOrgs, Somos, Timing
How a toll-free number moves to a new provider: what a RespOrg is, the Somos ROC process, the 4-element LOA, 2-business-day windows and why requests stall.

Summary
- 01Porting a toll-free number moves control of its central database record from the current RespOrg to a new RespOrg. Your phone provider may not be your RespOrg.
- 02No FCC rule sets a toll-free porting interval. Somos process windows apply, and your provider's paperwork time comes on top of those windows.
- 03The LOA must name the new RespOrg, list the numbers, carry an accepted signature and be dated within 30 days of the change date.
- 04A Help Desk change updates the RespOrg field only. The new RespOrg must set routing; keep the old service active until test calls land.
- 05Canadian toll-free numbers use the same shared database and RespOrg change and LOA process. The guide does not state Canadian regulatory deadlines or obligations.
Inside this article
- 01The short answer
- 02Toll-free numbers are not ported the way local numbers are
- 03What a Responsible Organization does
- 04Who Somos is
- 05The RespOrg change (ROC) process, step by step
- 06The Letter of Agency for a toll-free change
- 07Timing and scheduling the cut-over
- 08Why toll-free requests get held up
- 09Toll-free numbers in Canada
- 10Warehousing, hoarding and brokering: why you cannot buy and sell a number
- 11FAQ
- 12Sources
The short answer
A toll-free number (800, 888, 877, 866, 855, 844 or 833) is not held by your phone company the way a local number is. It is a record in a central database, and a company called a Responsible Organization, or RespOrg, controls that record for you. "Porting" a toll-free number means moving control of that record from your current RespOrg to a new one. The FCC requires toll-free numbers to be portable in exactly that sense: a subscriber can "port, or move, their number to a new RespOrg when changing service providers" [1].
In practice:
- Your new provider (or the RespOrg it works with) submits a Resp Org Change request in the Somos ROC System, backed by a Letter of Agency (LOA) you sign.
- Your current RespOrg either releases the number ("friendly port") or does not respond.
- If it has not responded or has declined within 2 business days, the new RespOrg can escalate to the Somos Help Desk with your LOA [2].
- The new RespOrg then controls the record, including where calls route.
There is no FCC interval for toll-free ports like the one-business-day rule for ordinary ports. The deadlines that exist are Somos process windows, and provider quotes sit on top of those. This guide reflects the rules as of October 2026. It is educational, not legal advice.
Toll-free numbers are not ported the way local numbers are
Local numbers move between carriers under the FCC's number portability rules in Part 52, Subpart C. Toll-free numbers sit in Subpart D, which has six sections: definitions, lag times, warehousing, hoarding, a cap on reservations and number assignment [3]. None of them sets a porting interval.
The definitions in 47 CFR 52.101 explain how the system is built:
| Term | What 52.101 says | What it means for you |
|---|---|---|
| Toll Free Subscriber | "The entity that has been assigned a toll free number." | You (the business). |
| Responsible Organization (RespOrg) | "The entity chosen by a toll free subscriber to manage and administer the appropriate records in the toll free Service Management System for the toll free subscriber." | The company that controls your number's record. |
| Service Management System (SMS) database | The system that "enables Responsible Organizations to enter and amend the data about toll free numbers within their control" and shares it with the Service Control Points. | Where routing for your number is set. |
| Toll Free Numbering Administrator (TFNA) | The entity appointed by the FCC that administers the SMS database day to day. | The neutral administrator (Somos). |
The FCC "is not involved in the actual assignment of toll free numbers and cannot access the number database" [1]. Questions about your number go to your RespOrg.
What a Responsible Organization does
A RespOrg reserves numbers for subscribers and manages their records in the database. The FCC notes that "many RespOrgs also provide toll free service," and that Somos, as administrator of the database, "certifies RespOrgs" [1].
Three practical points follow:
- Your phone provider may not be your RespOrg. Somos's LOA rules accept a letter on "letterhead from a reseller company" as long as the text appoints the actual RespOrg by name or ID [2]. Ask your new provider which RespOrg will hold your number.
- Each RespOrg has a 5-character ID. The change request names the "Old Resp Org" (the controlling one) and the "New Resp Org," each by its 5-character ID. The new RespOrg can look up the current controlling ID in the TFNRegistry before filing [2].
- The RespOrg sets your routing. In the SMS, the RespOrg enters "specific subscriber routing information" for a number [4]. Whoever controls the record controls where calls go.
Who Somos is
Somos is the toll-free database administrator. The FCC calls it "administrator of the toll free number database" [1], and Somos lists Toll-Free Numbers (TFNA) among the registries it manages [5]. It runs the TFNRegistry, the ROC System inside it, and a Help Desk that handles escalated RespOrg changes. Use of the ROC System has been mandatory since June 30, 2017, under the TFNRegistry Functions Tariff on file with the FCC [2].
RespOrgs file the requests, not you. If you need help locating a RespOrg, the FCC points to the Somos Help Desk at 1-844-439-7666 [1].
- Reserves numbers for subscribers and manages their records in the database.
- Controls where calls go by setting routing for the number.
- Files change requests on the subscriber's behalf.
- Administers the toll-free database.
- Runs the TFNRegistry, the ROC System and the Help Desk for escalated changes.
- A Help Desk change updates only the RespOrg field and does not modify routing.
The change of control is not the same as calls arriving on your new service.
The RespOrg change (ROC) process, step by step
Somos describes two ways to move a number between RespOrgs [2]:
- Friendly port. The controlling (current) RespOrg completes the change after the new RespOrg submits a request through the ROC System.
- Help Desk escalation (ROC HDI). If the controlling RespOrg "has not responded to the Resp Org Change request or declined it within 2 business days," the submitting RespOrg can escalate to the Help Desk.
The sequence from your side:
| Step | Who acts | What happens | Rule or window |
|---|---|---|---|
| 1. Confirm current details | You | Gather the exact toll-free number(s), your current provider's account, and if possible the current RespOrg. | None |
| 2. Sign the LOA | You | Sign a Letter of Agency naming the new RespOrg. | Must be dated within 30 days of the change date |
| 3. Submit in ROC | New RespOrg | Files the request in the ROC System with the LOA. | Mandatory for LOA-based changes |
| 4. Response | Current RespOrg | Releases the number or declines. | 2 business days, counted from the day after submission; weekends and specific holidays excluded |
| 5. Escalation if needed | New RespOrg, then Help Desk | Help Desk audits the LOA and processes the change. | Under normal conditions, done by the end of the second business day [6] |
| 6. Routing set | New RespOrg | Points the number at your new service. | Set by the new RespOrg |
A 2019 Somos overview says the same: LOA-based requests "must be submitted through ROC and all requests must be addressed within 2 business days" [7].
Two details matter if you have several numbers:
- One Help Desk request takes up to 15 typed numbers; more go in a CSV [2].
- Numbers under different controlling RespOrgs need separate requests.
Cost. Somos says the tariff fee "per TFN changed" applies to Help Desk requests [6]. As of October 2026 the Somos tariff sets that Resp Org Change Charge at $14.30 per toll-free number changed (rates effective February 15, 2026, expiring February 14, 2027) [8]. The fee is billed to the submitting RespOrg; whether and how your provider passes it on is up to them. Ask for the total in writing.
- 01Confirm current details
Gather the exact toll-free numbers, your current provider's account and, if possible, the current RespOrg.
- 02Sign the LOA
Sign a Letter of Agency naming the new RespOrg, dated within 30 days of the change date.
- 03Submit through ROC
The new RespOrg files the request in the ROC System with the LOA.
- 04Current RespOrg responds
The current RespOrg releases the number or declines. The response window is 2 business days, counted from the day after submission.
- 05Escalate if needed
The new RespOrg can escalate after no response or a decline within 2 business days. The Help Desk audits the LOA and processes the change.
- 06Set routing and test calls
The new RespOrg enters routing. Keep the old service active until the change is confirmed and test calls land.
The Letter of Agency for a toll-free change
Most of the Help Desk rules are about the LOA. For Help Desk requests, Somos requires a valid LOA "signed by the end user" for every number, and each LOA must include four elements [2]:
| Element | Somos requirement | Common mistake |
|---|---|---|
| Signature | Wet signature, eSignature or PIN (third-party verification). Stamped signatures are not accepted. | Using a signature stamp |
| Date | Within the last 30 days from the change date on the request. For a future-dated change, the LOA must be dated within 30 days of that date. | Reusing an LOA signed weeks earlier |
| Toll-free number(s) | Each number being changed. With a CSV of more than 15 numbers, write "see attached" plus the beginning and ending numbers. | Missing one number from a list |
| New RespOrg information | Letterhead of the new RespOrg, or a reseller's letterhead whose text appoints the RespOrg, or plain paper whose text appoints the RespOrg. A line "New Resp Org: [name or ID]" is accepted. | Naming only the reseller, not the RespOrg |
Somos adds format rules: no movable text boxes, nothing editable, and everything on one page unless each number gets its own LOA [2]. The new RespOrg must validate your LOA, so sign its template rather than drafting your own.
LOA checklist before you sign
- Every toll-free number you want to move is listed (and none you want to keep elsewhere).
- The new RespOrg is named by company name or 5-character ID.
- Your signature is wet or a real eSignature, not a stamp.
- The date is today, and the change is planned within 30 days.
- The document is one page, locked, with no editable fields left.
Timing and scheduling the cut-over
For Help Desk requests, Somos offers two effective-date options [2]:
- Emergency Resp Org Change: completed on the date the request is submitted.
- Non-Emergency Resp Org Change: completed on a future date you choose, "any date within the next 30 days."
Somos does not set how long your provider takes to collect paperwork and file; provider quotes cover that span. Twilio, for example, quotes 5 to 15 days for standard US ports once all required information is in, and up to 4 weeks or longer, without giving a separate toll-free figure [9]. Treat any quote as a quote, not a regulated maximum.
The change of control is not the same as calls arriving on your new service. When the Help Desk performs a change, the Somos tariff says it updates only the RespOrg field: "No routing or other service data will be modified" (Somos TFNRegistry Functions Tariff, section 3.6.2). The new RespOrg then has to enter routing for the number. Before the date, ask your new provider:
- Will routing be entered at the moment control changes?
- Who places test calls right after the change?
- Who do I call if it does not ring through?
Keep the old service active until the change is confirmed and test calls land. The same rule applies to local ports; see how long number porting takes.
Why toll-free requests get held up
| Cause | Source | What to do |
|---|---|---|
| Invalid LOA (missing element, stamp, stale date, movable text) | Somos support: incomplete or invalid LOAs "will not be processed" [6] | Use the new RespOrg's template; re-sign if the date drifts past 30 days |
| Wrong controlling RespOrg ID | Help Desk request names the old RespOrg by 5-character ID; numbers under different IDs need separate requests | Have the new RespOrg look up each number before filing |
| Request filed as "out of service" | The Help Desk makes test calls; if it reaches a subscriber on the number, the request is rejected [6] | Use the normal ROC route while the number is live |
| Number already disconnected | A disconnected number stays in disconnect status for at least 45 days and at most 4 months, then goes to spare or unavailable; it may not be returned directly to working status at the end of that interval [4] | Act quickly; a lapsed number can be lost |
| Billing dispute | Numbers in billing disputes may sit in suspend status for up to 8 months [4] | Settle or document the balance before you start |
Cancel the old service first and the number can leave your control. Move the number, then cancel.
Toll-free numbers in Canada
Canadian toll-free numbers can be moved between providers. Twilio's Canada guideline lists toll-free numbers as portable and says Canadian toll-free requests are submitted through its console, separately from Canadian local and mobile numbers, which use a different porting form [10]. That is one provider's process.
Canadian toll-free numbers sit in the same shared North American toll-free database that Somos administers. The Somos tariff describes the TFN Registry as keeping track of "the availability of all toll-free numbers", and RespOrgs may be based in the United States, Canada or another country in the North American Numbering Plan (Somos TFNRegistry Functions Tariff, sections 2.1.4 and 2.3.2). So the same RespOrg change and LOA process applies to a Canadian toll-free number.
Scope limit: the FCC rules cited in this guide (Part 52, Subpart D) are US regulations, and we could not load a primary CRTC source on Canadian toll-free rules, so this guide does not state any Canadian regulatory deadlines or obligations. If your business is in Canada, ask the gaining provider who will act as RespOrg and what paperwork it needs. For Canadian local numbers, see the Canada page.
Warehousing, hoarding and brokering: why you cannot buy and sell a number
Toll-free numbers are treated as a shared resource, and the rules limit how they can be held or traded:
- Warehousing (RespOrgs). A RespOrg may not reserve numbers "without having an actual toll free subscriber for whom those numbers are being reserved" [11].
- Hoarding (subscribers). A subscriber may not acquire more toll-free numbers than it intends to use [12].
- Brokering. "No person or entity shall acquire a toll free number for the purpose of selling the toll free number to another entity or to a person for a fee" [12]. Routing multiple toll-free numbers to a single subscriber creates a rebuttable presumption of hoarding or brokering.
The exception is numbers assigned through competitive bidding, such as the FCC's 833 auction [1][12].
So a vanity number offered "for sale" by a private party is a red flag, and if you buy a business, the toll-free number should be moved with a proper RespOrg change and LOA as part of the deal, not sold as a separate asset. The business-sale guide covers the paperwork side.
FAQ
How long does a toll-free port take? No FCC rule sets a toll-free porting interval. Somos gives the current RespOrg 2 business days to respond before escalation, and the Help Desk normally completes an escalated request by the end of the second business day, or on a future date you choose within 30 days [2]. Your provider's own paperwork time comes on top of that.
Does my number keep working during the change? Do not assume it does. Keep the current service active, ask how routing will be set, and test right after. Cancelling first can push the number into disconnect status [4].
What does it cost? A Somos tariff fee of $14.30 per number applies to Help Desk changes as of October 2026 [8], billed to the submitting RespOrg. Provider fees vary. Get the total in writing before you sign.
Can I turn my toll-free number into a local number? No. An 800-series number keeps its toll-free code; 800 and 888 versions of the same digits reach different subscribers [1]. You can point the toll-free number at a phone system that also has a local number, but they remain two numbers. For local numbers, see porting your existing number.
Auto Attendant accepts US and Canadian numbers for porting in through the app with an online LOA. Toll-free ports are handled by the team, and there is no charge until the number has moved.
Sources
- What Is a Toll Free Number and How Does It Work?, FCC. RespOrgs, Somos role, portability, FCC role, hoarding, 833 exception.
- 47 CFR Part 52, Subpart D, eCFR. Toll-free sections; no porting interval.
- 47 CFR 52.101, eCFR. Definitions (RespOrg, SMS, TFNA).
- 47 CFR 52.103, eCFR. Routing entry, disconnect and suspend status.
- 47 CFR 52.105, eCFR. Warehousing.
- 47 CFR 52.107, eCFR. Hoarding and brokering.
- How do I Submit a ROC HDI Request, Somos support. ROC process, 2 business days, dates, LOA elements.
- How does the Help Desk Handle Resp Org Changes?, Somos support. Completion time, per-number fee, rejections.
- Utilizing the ROC System, Somos Insights, 2019. ROC mandate.
- About Somos, Somos. TFNA registry.
- US porting guidelines, Twilio. Toll-free portable; port time quote.
- Canada porting guidelines, Twilio. Canadian toll-free portable.
- TFNRegistry Functions Tariff, Tariff F.C.C. No. 1, Somos (full text at https://www.somos.com/media/380; rates effective February 15, 2026). Resp Org Change Charge $14.30 per number (4.2(F)); Help Desk change does not modify routing (3.6.2); registry covers all toll-free numbers, RespOrgs in the US, Canada or other NANP countries (2.1.4, 2.3.2). Accessed 2026-10-28.
External Sources (12)
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Auto Attendant Editorial
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Researched and written by Auto Attendant Editorial with AI-assisted research tools; sources are cited inline and checked before publication. Report an error: https://autoattendant.io/contact/.