For at least the third time, the New York City Department of Consumer and Worker Protection has delayed the effective date of its debt collection regulation, this time providing no update other than to say the regulation will not go into effect on October 1 as originally planned and that it will provide three months’ notice before putting the rule into effect.
The DCWP yesterday issued a Notice of Change of Effective Date confirming that the amended debt collection rules published in the City Record will not take effect on October 1. No new effective date was provided, but DCWP pledged to give at least three months’ notice before enforcing the rules.
This latest delay marks the third postponement of a rulemaking process that has drawn intense scrutiny from the credit and collection industry. Initially slated to go into effect on December 1, 2024, the rules were first pushed to April 1, 2025, then to October 1, 2025, and now are indefinitely on hold.
The regulations in question are sweeping in scope and created concern across the credit and collection industry. Among their many provisions, the rules include:
- Expanded language access and recordkeeping requirements.
- Tighter restrictions on communication frequency, including a hard cap on the number of consumer contacts per week.
- Rules specific to time-barred debt, medical debt, and electronic communication channels, including voicemail, text, email, and even social media.
- Enhanced dispute and verification requirements, and a new required notice — the “Notice of Unverified Debt” — that must be issued if a collector cannot validate a disputed debt.
The city was sued by ACA International to prevent the rule from going into effect. ACA voluntarily dismissed the suit earlier this year.
