New York City Releases FAQ and Announces Webinar for SHIELD Rule

As we previously discussed here, the New York City Department of Consumer and Worker Protection (DCWP) delayed the effective date of its amended debt collection regulations, known as the SHIELD Rule, from September 1, 2026 to January 1, 2027, to provide regulated entities additional time to make operational adjustments and to allow the agency to address outstanding questions from industry stakeholders.

To further that goal, the DCWP has now published a lengthy set of FAQs and announced an upcoming compliance webinar to help debt collectors prepare for the rule’s January 1, 2027 effective date.

Link to Webinar and Questions Webinar and Questions

The DCWP will host a “DCWP 101” webinar on the SHIELD Rule at 2 p.m. ET on October 5, 2026. Regulated entities with general compliance and operational questions may submit them directly to debtfaqteam@dcwp.nyc.gov. Follow-up questions regarding the FAQ should be submitted before October 5 to be considered for inclusion in the webinar presentation.

Link to FAQ Highlights FAQ Highlights

The FAQ addresses fifteen topic areas. Key clarifications include the following:

• Scope. The SHIELD Rule applies to all debt collectors, including creditors, licensed agencies, third-party collectors, debt buyers, and collection attorneys, engaged in collection activity with NYC consumers once debt collection procedures have begun. Day-to-day billing and customer service are not covered.
• Communication Limits. The rule caps contacts with NYC consumers at three per distinct account within any seven-day period across all media, excluding only mailed letters from the 3 contact limitation calculation. The limit is per-account, not per-consumer.
• Electronic Communications. Debt collectors must obtain direct written consumer consent for each specific debt account and communication medium before collecting electronically. Every electronic communication must disclose the consumer’s right to revoke consent.
• Validation Notices. Within five days of the initial communication on a debt account, collectors must mail a hard copy validation notice containing required NYC content, including debt itemization, consumer rights disclosures, and, where applicable, time-barred debt notices. A specific natural person must be designated as the call-back contact for each account.
• Disputes and Verification. As discussed in our prior coverage (here), consumers may dispute a debt or request verification at any time. Upon receiving a dispute, collectors must cease collection activity and provide written verification within 60 days, or issue a Notice of Unverified Debt. The FAQ clarifies that simply closing an account after receiving a dispute does not eliminate the obligation to send the Notice of Unverified Debt. Failure to do so is a separate SHIELD Rule violation.
• Medical Debt. All validation notices must disclose that medical debt cannot be reported to a consumer reporting agency, regardless of whether the collector is collecting a medical debt. A consumer’s indication that insurance or financial assistance should have covered charges must be treated as a dispute triggering verification obligations.
• Time-Barred Debt. Collectors must mail a Notice of Time-Barred Debt and wait at least 14 consecutive days before contacting a consumer about time-barred debt. Failure to comply prohibits the collector from entering into a settlement or accepting payment on the debt.
• Recordkeeping and Transfers. Collectors must maintain monthly logs of consumer complaints, disputes, and cease-communication requests. When transferring or selling a debt, collectors must transfer notices of any unverified or time-barred debt status along with the account.

Link to Our Take Our Take

In a number of instances, the FAQs do provide additional clarity as to the rule’s key requirements, such as: confirming that the mere use of language lines if requested by a consumer do not trigger any obligation of the collector to comply with the rule’s broader language access requirement; clarifying who is the originating creditor in indirect financing arrangements and that there can be multiple original creditors; and explaining how the timing of the rule’s requirements apply to accounts that were already being collected prior to the January 2027 effective date. But various operational and interpretive challenges remain. For instance, in discussing the requirement to provide the name and number of a person the consumer can call back about their account, NYC specifically states it envisions having a specific representative “assigned” and that some organizations may develop NYC-specific teams to handle such accounts. With January 1, 2027 now less than five months away, debt collectors and their counsel should use the October 5 webinar as an opportunity to raise outstanding compliance questions with the DCWP before the rule takes effect.