Several industry trade groups have sent a letter to the New York City Department of Consumer Affairs (DCA) in which they set forth proposed FAQs to assist compliance with the new requirements relating to consumers’ language proficiency that were recently added to NYC’s existing debt collection regulations and request that the effective date of the new requirements be extended until three months after the DCA publishes the FAQs. The new requirements are currently set to take effect on June 27, 2020.
In the letter, the trade groups also ask the DCA to reopen the comment period on the new requirements. The proposed FAQs reflect the DCA’s responses to questions posed by the trade groups during a June 17 call with the DCA as well as other issues of concern flagged by the trade groups.
Although we are not yet aware of a formal announcement from the DCA, we continue to understand that the DCA is expected to announce a 60-day enforcement grace period for the new requirements.