On March 13, following the declaration of a state of emergency by Nevada Governor Sisolak due to the COVID-19 outbreak, the state’s Department of Business and Industry (DBI) issued guidance that allowed collection agency employees to work from their residences even if a residence was not a location licensed with the DBI.  However, on March 20, in response to Governor Sisolak’s order requiring the closing of all businesses deemed “non-essential,” the DBI issued a letter that deemed all Nevada-licensed collection agencies to be “non-essential” and ordered all collection agencies holding a Nevada license located in the state “to close” effective midnight March 20 until April 6.  The DBI also directed all collection agencies holding a Nevada license or certificate (regardless of the whether the licensee is located in-state or out-of-state) to “cease collection efforts with Nevada consumers/residents” effective midnight March 20 until April 6.

We are currently working with collections industry clients to address the many questions that have arisen regarding what, if any, activities continue to be permissible while the DBI’s “cease collection efforts” directive remains in effect.