Today, the New York City Department of Consumer and Worker Protection (NYC DCWP) announced another delay in the effective date of its amended debt collection rules. This marks the second postponement. As discussed here, the rules were initially set to take effect on December 1, 2024. Then the enforcement date was first postponed to April 1, 2025, following industry concerns and legal challenges, and then to October 1, 2025. However, the NYC DCWP has now stated that the rules will not go into effect on October 1, 2025, and has committed to providing an update at least three months prior to the new effective date.
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. Engaging with the NYC DCWP during this period will be crucial for stakeholders to ensure that their concerns are adequately addressed and that the final rules strike a balance between consumer protection and industry viability.
We will continue to monitor these developments closely and provide updates as they become available.