NYC Quietly Publishes Guidance That Helps to Reconcile Its Debt Collection Rules with Those of New York State

In response to many inquiries regarding its out-of-statute requirements, the New York City Department of Consumer Affairs (NYC) issued this letter on July 31, 2015. The requirements have caused confusion because of their apparent conflict with those issued by the New York State Department of Financial Services (NYDFS).

NYC says that the disclosure language provided in § 1.3(c) of Title 23 of the New York Code of Rules and Regulations (“NYCRR”) DOES SATISFY the disclosure required by § 20-493.2(b) of the Administrative Code of the City of New York (the “Code”) and § 2-191 of Title 6 of the Rules of the City of New York (the “Rules” or “6 RCNY”), with one caveat.

According to the letter:

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