NCLC’s comments focus on the relationship between New York City’s Department of Consumer and Worker Protections (“DCWP”) proposed debt collection amendments, the federal Fair Debt Collection Practices Act (“FDCPA”), and federal debt collection regulations issued to implement the FDCPA (“Regulation F”). Regulation F has many gaps and weaknesses, and we commend the DCWP’s proposal for its efforts to fill some of these gaps.
These comments respond to the 2023 proposed amendments to rules related to debt collection, updating the comments that NCLC previously submitted in response to the DCWP’s 2022 proposed amendments.