In our previous post, we discussed the New York City Department of Consumer and Worker Protection’s (NYC DCWP) decision to delay the enforcement of the amended debt collection rules from December 1, 2024, to April 1, 2025. This postponement was in response to industry concerns and a legal challenge filed by ACA International, Inc. and Independent, Inc. NYC DCWP then announced it would delay the effective date for the amended rules to April 1, 2025, to align with the enforcement date.
This week, the NYC DCWP issued a Notice of Change of Effective Date, further delaying the effective date for the final rules relating to debt collectors. The new effective date is now October 1, 2025.
Our Take
The further delay in the effective date suggests that the NYC DCWP is considering additional revisions to the amended debt collection rules. This could be in response to ongoing industry feedback and legal challenges. The potential for substantive changes means that stakeholders should stay vigilant and be prepared to participate in a new notice and comment period.
We will continue to monitor these developments closely and provide updates as they become available.
