The meeting with ACA International and the New York State Department of Financial Services focused on proposed rules for the ARM industry and their impact on small businesses.
ACA International and the New York State Collectors Association sought clarity on recent proposed rules and a shortened comment period on those rules in a meeting with the New York State Department of Financial Services (NYDFS) Monday.
On Nov. 1, the NYDFS posted draft proposed amendments to part one of the Regulations of the Superintendent of Financial Services (23 New York Codes, Rules, and Regulations Part 1, Debt Collection by Third-Party Debt Collectors and Debt Buyers) for comment and set a deadline for those comments a week later, Nov. 8, ACA previously reported.
The early small-business comment period was a new procedure the department is required to undergo before publishing a formal notice of proposed rulemaking (NPRM) in the New York State Register.
If the department publishes a formal NPRM, a new 60-day comment period will commence.
ACA is also seeking clarity from the NYDFS on why it is moving forward with the draft proposed amended debt collection rules and requirements on the statute of limitations when Gov. Kathy Hochul signed the Consumer Credit Fairness Act, including similar requirements, into law on Monday and the Reg F deadline at the federal level approaching Nov. 30.
For more advocacy updates, ACA recommends members join the weekly ACA Huddle webinar at 11 a.m. CDT Wednesdays. The ACA Huddle features advocacy, compliance and education updates as well as guest speakers and one-time registration is available through the ACA events calendar.