As of today, RMAI has still not seen an official statement posted on the New York City Department of Consumer Affair’s (DCA’s) website announcing that they are offering the “60-day enforcement grace period” on its foreign language rule which was promised the industry. Consequently, RMAI recommends that the members proceed under the assumption that full compliance is expected as of Saturday, June 27, 2020. One challenge is that DCA has not launched its own required web page that provides the translation and description of commonly used debt collection terms in multiple languages even though debt collectors under the rule are supposed to inform consumers of its existence starting on Saturday.

RMAI, working with a coalition of industry trade associations, submitted a letter to DCA on June 11, 2020, requesting that the implementation date be extended and the comment period be reopened to allow the industry and the public an opportunity to comment on the rules. The industry trade association coalition followed up with a letter dated June 22, 2020, reiterating the need for an extension to the effective date.

RMAI is planning an upcoming webinar to provide a deep dive into the DCA’s FAQs once they are issued. Additional guidance will be provided when we have new information to share.

Prior RMAI Member Alerts on DCA Foreign Language Rule:

 

This alert is intended for members of the Receivables Management Association International and 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.