As discussed in our June 12th and August 7th posts, The New York City Department of Consumer Affairs (“DCA”) issued new debt collection rules related to limited English proficiency servicing, which took effect June 27, 2020. Due to the COVID-19 crisis, the DCA provided the industry with a 60-day enforcement grace period until August 26, 2020. The DCA has now extended this enforcement grace period until October 1, 2020.
While this extension is helpful in providing debt collectors additional time to comply with these rules, many unanswered questions remain. The DCA previously noted in its August 7th guidance that it intends to modify the rules to align with the interpretations provided in its FAQs. We are still awaiting these modifications.