Comments on the Proposed Rulemaking by the NYS Department of Financial Services Regarding Debt Collection by Third Party Debt Collectors and Buyers

SUMMARY

The Committees on Consumer Affairs and Civil Court jointly submitted comments on the second publication of proposed rules by the New York State Department of Financial Services (“DFS”) to 23 NYCRR 1 regarding debt collection by third-party debt collectors and debt buyers. The report applauded DFS for undertaking this initiative and generally expressed support for the proposed rules subject to the suggestions and comments advanced by the committees, as they would enhance oversight and enforcement of debt collection—both by original creditors and third-party debt collectors— and would help protect all New Yorkers, but especially those most vulnerable to abusive, deceptive, and misleading practices. Debt collection, the report notes, consistently ranks as a top sector for consumer complaints by New Yorkers with federal, state, and local consumer protection agencies.