I walked about hours trough every street, alley, buildings and roofs. But didn't found the missing ones.
@ShimaWolf then you're missing one Dragov Comm that's actual a found one. I guess its the comm at the very end of the Wallstreet mission (just at the exit after finishing the mission).
https://division2map.com/nyc?locationIds=25387
I only can guess that the missing comms are missing in the game like the New Echo. We just have to wait till they respond to this or if they drop in a new Content update (Maybe a BTSU invasion in New York lol)