Last week the New York State Department of Financial Services (NYDFS) released some FAQs on their new debt collection regulations. You can get them here.
Those of you who participated in my DBA International webinar last month know the FAQs don’t address several open issues.
I know there are still issues of concern and questions like:
- How can a section 1.3(b) disclosure be made in the same “medium” by which the payment is to be received if we don’t know how the consumer will be making the payment?
- When the regulations use the word “provide” in the context of a disclosure, does it mean the disclosure is effective upon sending?
- Can we require consumers to provide certain information to verify their identity as part of our written substantiation instructions?
There are plenty more picky matters I have with the regulations. I’m sure you have some too.
I’m happy to tell you that DBA International has teamed with the New York State Department of Financial Services (DFS) for a one-day symposium looking at the regulations and giving us a chance to get answers before the March 3 effective date.
The symposium is Thursday, February 26 in Manhattan. You can register at the DBA website or by calling (916) 482-2462. The cost is $320 for DBA International members and $420 for everyone else.
In addition to DFS, the NYC Department of Consumer Affairs and the New York Office of Court Administration will be discussing their debt collection rules and regulations.
This is unique opportunity to get all of your New York state compliance issues addressed and share best practices with industry leaders
See you on Thursday.