On April 2, Jonathan Pompan published, “NYC’s SHIELD Rule Reshapes Debt Collection Compliance—Original Creditors Now Squarely in Scope” in Collections & Recovery. The following is an excerpt:
New York City’s newly finalized Stopping Harassment and Intimidation and Ensuring Lawful Debt (SHIELD) Collection Rule materially tightens debt-collection requirements in the nation’s largest consumer market. This is not a technical adjustment to Regulation F. It is a structural compliance shift that expands dispute rights, caps communications at three per week across channels, and increases substantiation expectations—particularly for medical debt. The SHIELD Rule is effective September 1, 2026.
The rule is enforced by the New York City Department of Consumer and Worker Protection (DCWP), which licenses debt collection agencies, conducts investigations and audits, and has authority to bring administrative enforcement actions, impose penalties, and seek injunctive relief under the City’s Administrative Code. The SHIELD Rule does not create a new private right of action.
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