In the Nick of Time: NYC DCA Releases Glossary and Translations of Commonly-Used Terms

As debt collectors began to wonder whether they'd be able to comply with New York City Department of Consumer Affair's (DCA) new Limited English Proficiency rule, the regulator has finally posted the final piece of the puzzle just as its enforcement grace period against debt collectors was about to expire. Yesterday, DCA at long last posted the glossary of commonly-used collection terms and their translations. 

Among several requirements, the new rule requires debt collectors to provide a link to DCA's website -- www.nyc.gov/dca -- and inform consumers that they can find such a glossary there.

The big concern for debt collectors was whether the glossary would be posted at all; and, until it was posted, there was a concern that it was impossible to properly comply with the rule and protect against legal risk. A debt collector could include the link to the website to comply with the rule, but if the glossary was not present, then it provided legal exposure to debt collectors for potentially providing misleading or deceptive communications to consumers.

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