New York Rules Could Strengthen the Relationship Between Collection Agencies and Creditors

Lauren Rosenfeld,
FMA Alliance

On November 14, 2014, the New York Department of Financial Services (NYDFS) published comprehensive regulations impacting the practices of third-party debt collectors and debt buyers collecting in the state.

Although several sections of the regulation became effective March 3, 2015, the most onerous sections will become enforceable August 30, 2015. Sections pending implementation, including the substantiation and itemization of charged-off debts under Section 1.4 and 1.2 (b), pose unique challenges as they require regulated collection agencies and technically non-regulated creditors to work together to expeditiously exchange significant amounts  of confidential data.

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