Welcome to the Research Assistant Weekly Newsletter - a subscriber-only resource for insight into emerging compliance challenges, details on peer calls, and links to new Research Assistant reports, documents, tools, and more.
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All RA members can participate in the conversation by joining the peer call on Mondays at 4 pm EST/1 pm PST; just look for the invite from Sara. Our next Research Assistant Call will be Monday, January 6, 2025.
In this week’s Research Assistant Peer Group Call, a member asked how everyone is proceeding with the amended New York City debt collection rules?
Even though there is a lawsuit pending filed by ACA International on this issue and that suit created the extension of the effective date from December 2024 to April 1, 2025, there is no guarantee anything will change. To comply with the NYC rule, some believe it is better to begin the process for the changes now, instead of being caught without enough time to implement the new requirements. Some members said they are being proactive and making a few tweaks to prepare.
One member indicated that they proactively created the “Not able to verify” letter to comply with the unverified debt provisions of the rule, even though the NYC DCWP said they will provide a template form prior to the effective date. Regardless of whether you wait for the template or create your own letter, make sure to consider how this letter will be used and how it’ll be tracked to ensure a smooth implementation when the time comes. It is a good idea to start small and be ready.
Another thing to consider is that you will have to pull complaints, disputes, request for verification, and cease notifications specific to NYC consumers. You may need to add zip codes or other ways to locate accounts for consumers living in specific areas when tracking these. See NYC’s safe harbor activity report here: Debt Collection Report: Record of Consumer Activity.
Other members shared they decided to stop collecting in NYC since their volume of accounts didn’t warrant the resource investment. This is a business decision that you need to make one way or the other. Maybe it is worth avoiding collections in this highly regulated state. Not because you have a problem with the debt itself, but it may be close to impossible to meet all the requirements, making the risk not worth the reward.
Bottom line, it was recommended to continue as if the rule is going into effect as is. Allow yourself time to get things in place to avoid last minute scrambling.
Documents and Crowdsourced Materials:
Top Reads:
Upcoming Webinars/ Other Announcements:
- Happy Holidays! Our next Research Assistant Call will be Monday, January 6, 2025.
- Important Announcement: All AI Notetaking Bots will be removed from Research Assistant Peer Group Meetings. This is to maintain the confidentiality of our peer members.
- Have topics you want to discuss during the peer call? Please send them to Sara_Consultant@roundtables.us by Thursday to ensure it makes it on our agenda!
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