2022 CAI-NJ September LAC Issue

social media “friends” with delinquent unit owners. The LAC does not oppose the gen eral intent behind A3131 as it applies outside the CIC industry. It makes sense and is reasonable in the context of a tra ditional creditor (such as a bank, store, etc.) where the relationship between the creditor and debtor is distant and at arm’s length. In the context of CIC debtors/creditors, however, there is a much closer and personal relationship which will result in A3131’s restrictions being more difficult to follow. While the restrictions in A3131 themselves are reasonable (and large ly follow FDCPA), the fact that A3131 seeks to impose them directly onto CIC associations (and not just their attorneys) will be onerous on much of CAI members. For this reason, the LAC will be seeking a carve out of CIC associations. n

Dean Barber, Executive Vice President & COO

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