Alert

August 11, 2026

NYC Releases FAQs on Revised Debt Collection Rule

On August 10, 2026, the New York City Department of Consumer and Worker Protection released a "Frequently Asked Questions" document intended to provide guidance to regulated entities on its revised debt collection rule (the "SHIELD Rule"). The revised SHIELD Rule takes effect January 1, 2027. (Originally, it was scheduled to go into effect on September 1, 2026, but the DCWP delayed implementation earlier this summer.)

The FAQs address the scope of the SHIELD Rule and clarify that the entire SHIELD Rule does not apply unless and until a person engages in "debt collection procedures." The FAQs also:

  • provide guidance on how to deliver the mini-Miranda warning;
  • include examples of how to comply with the SHIELD Rule around the effective date (in particular, whether the revised debt validation notice is required if the initial communication occurs at the very end of 2026 and whether the debt collector must comply with the SHIELD Rule's verification requirements if the validation notice was provide before the effective date);
  • clarify that closing an account is not an appropriate response to a dispute or request for verification and that debt collectors must send the Notice of Unverified Debt (see template: https://www.nyc.gov/site/dca/businesses/templates.page#debt);
  • attempt to distinguish between the "front-end itemization" provided in the validation notice and the expanded itemization required if the debtor disputes any item in the front-end itemization. (Based upon the FAQs, it appears that for creditors that accrue interest and other charges on the account, there is little difference between the front-end itemization and the expanded itemization.); and
  • reiterate that a debt collector is not required to conduct collection communications in the consumer's preferred language except in very specific circumstances.

The list above is not exhaustive but highlights some of the more useful guidance in the FAQs (which, in certain places, simply re-state the SHIELD Rule).

The FAQs released yesterday may be subject to further revision. The FAQs note, in the third footnote, that the DCWP will update the document as appropriate. Creditors and third-party debt collectors should periodically check the DCWP Business / Licenses - Debt Collector Tab to ensure they have the most current version (indicated by the date in the lower left-hand corner of each page).