Earlier today, the New York City Department of Consumer and Worker Protection (DCWP) published a change to the effective date for the amended New York City Debt Collection Rules that were adopted on August 12, 2024. The new effective date will be April 1, 2025. Previously, the amendments were set to go into effect on December 1, 2024.
This change is consistent with the industry’s request for additional time for implementation given the significant changes to the rule. However, RMAI remains concerned that several provisions within the rule may not be able to be operationalized given statutory conflicts with state and federal laws not to mention what we feel to be a constitutional violation of the First Amendment on speech. RMAI is hopeful that this delay is a sign of DCWP’s willingness to resolve industry’s concerns in light of the lawsuit against the City of New York.
Please see related RMAI Member Alerts from August 16, 2024 and October 21, 2024.
This Member Alert is intended for members of the Receivables Management Association International, is for informational purposes only, and is in no way intended to provide legal advice. Members are encouraged to consult with an attorney of their choice for legal advice concerning this matter.