New York City — DCWP licensing + the SHIELD Rule (6 RCNY)

Municipal jurisdiction — the first in this KB. New York City is a third layer, not a substitute: federal law (FDCPA / Reg F) and New York State law (23 NYCRR Part 1, the CCFA, GBL art. 29-H) apply in full to NYC accounts, and the City's rules stack on top. Read state/ny.md with this page — the state page owns the SOL, revival, and DFS/CCFA analysis, and this page owns the City licence, the City conduct code, and City penalties. Where both speak, the stricter rule binds.

Authority

DCWP (Department of Consumer and Worker Protection, formerly DCA) regulates NYC debt collection on two tracks:

1. Licensing — the Debt Collection Agency (DCA) licence, N.Y.C. Admin. Code §§ 20-489 et seq., with DCWP's licensing rules at 6 RCNY ch. 2, subch. S (§§ 2-190 to 2-193).
2. Conduct — 6 RCNY ch. 5, subch. A, part 6 (§§ 5-76 definitions, 5-77 unconscionable and deceptive trade practices), comprehensively rewritten by the SHIELD Rule, plus the penalty schedule at 6 RCNY § 6-62.

DCWP's rulemaking authority, as recited in its own Notices of Adoption:

NOTICE IS HEREBY GIVEN PURSUANT TO THE AUTHORITY VESTED IN the Commissioner of the Department of Consumer and Worker Protection by sections 1043 and 2203(f) of the New York City Charter, and sections 20-104(b), 20-493(a) and 20-702 of the New York City Administrative Code … — DCWP Notice of Adoption, Rules relating to debt collectors (published in The City Record 2026-02-26), at 1

What this adds over state law

The only reason to read a municipal page is the delta. Each row is NYC measured against state/ny.md — the state analysis is not restated here.

Layer	NYC vs New York State
Licence / registration	ADDS. No statewide collection-agency licence was found in NY; NYC requires the DCWP Debt Collection Agency licence, triggered by the consumer's location, so an out-of-state agency collecting from an NYC resident needs it. Reaches debt buyers and collection law firms.
Bond	ADDS. $5,000 surety bond naming the City of New York as certificate holder. No state analogue.
Conduct rules stricter than state	ADDS. Frequency: 2-in-7 per consumer now, 3-in-7 per account with stop-on-response from 2027-01-01 — against no numeric state cap (GBL § 601(6) is a standard, not a number) and Reg F's telephone-only 7-in-7. E-communications require per-channel consent. Original creditors are covered once "debt collection procedures" begin, where 23 NYCRR 1 exempts them.
Disclosures	ADDS. Mailed validation notice within 5 days with NYC-specific content, a named natural-person callback, and a mandatory consumer-rights statement; the full mini-Miranda in EVERY communication plus a call-recording disclosure before any collection attempt (§ 5-77(d)(15), (20)) — broader than FDCPA § 1692e(11); a time-barred notice regime (mail first, 14-day wait); language-access duties keyed to the language actually used; website language disclosures.
Dispute / verification	ADDS. Dispute at any time (no 30-day federal window), 60-day verification deadline, and a Notice of Unverified Debt that binds downstream holders. State law's substantiation right (23 NYCRR 1.4) is a separate, parallel duty — satisfy both.
Credit reporting	ADDS. 14-day pre-furnishing notice and wait, layered on Reg F § 1006.30(a).
Medical debt	ADDS. Financial-assistance-policy screening bars collection outright; corrective measures triggered by the consumer without documentation.
Fees / rate caps	N/A. No NYC collection-fee or rate cap identified in the sources reviewed.
SOL / revival	SAME AS STATE — do not answer from this page. CPLR 214-i (3y consumer credit, no revival) and CPLR 213 govern; NYC adds only procedure around time-barred accounts.
Private right of action	UNVERIFIED. DCWP enforces via the § 6-62 penalty schedule; whether the Admin. Code affords a private action was not established, because the Code text could not be retrieved (below). Do not assert either way.

⚠ Administrative Code text not retrieved. The NYC Administrative Code is published at codelibrary.amlegal.com, which Cloudflare-403s both automated fetch and an ordinary browser request. No Admin. Code language is quoted verbatim on this page; §§ 20-489, 20-493(a), 20-493.2, 20-702 appear only as cites carried in official DCWP documents that were retrieved. Do not quote Admin. Code wording from this page — pull it first.

⚠ Effective date — the single most important fact on this page

The SHIELD Rule is not yet in force. It was adopted 2026-02-26 with a 2026-09-01 effective date, and that date was moved by an official notice:

NOTICE OF CHANGE OF EFFECTIVE DATE

NOTICE IS HEREBY GIVEN that the final rules of the Department of Consumer and Worker Protection relating to debt collectors published in the City Record on February 26, 2026 will go into effect on January 1, 2027, not September 1, 2026, the date contained in the publication. — The City Record, Vol. CLIII No. 139 (Wed., July 22, 2026), at 3099

The City's rulemaking portal entry for the rule now reads "Rule status: Adopted · Effective date: January 1, 2027" (rules.cityofnewyork.us, Further Amendments of Debt Collector Rules, retrieved 2026-08-21), and DCWP's own FAQ says the same:

On February 26, 2026, the Department of Consumer and Worker Protection (DCWP) published the final amendments to its rules relating to debt collectors in The City Record. Called the Stopping Harassment and Intimidation and Ensuring Lawful Debt Collection Rule (SHIELD Rule), the amendments will take effect on January 1, 2027. — DCWP, Frequently Asked Questions: New Rule for Debt Collectors, at 1 (dated 08/04/2026 on the document footer)

DCWP published a Notice of Change of Effective Date in The City Record that the SHIELD Rule goes into effect on January 1, 2027, not September 1, 2026. DCWP will be proposing an amendment to the SHIELD Rule for the sole purpose of aligning the text of the Rule with the new effective date. — ibid., n.2

That conforming amendment is now pending. DCWP published a Notice of Public Hearing on 2026-08-18 proposing to replace every "September 1, 2026" in the rule text with "January 1, 2027":

The Department of Consumer and Worker Protection ("DCWP" or "Department") is amending its rules to change the effective date of the Stopping Harassment and Intimidation and Ensuring Lawful Debt Collection ("SHIELD") Rule, which was published in the City Record on February 26, 2026. Specifically, DCWP is moving the effective date of the SHIELD Rule from September 1, 2026 to January 1, 2027, to provide additional time for the Department to answer questions and for the regulated community to make operational changes. Because the effective date of September 1, 2026, appears in the text of the rule itself, the Department is publishing an updated version of the rule changing that date to January 1, 2027 throughout.

This proposed rule does not otherwise make any substantive changes to the SHIELD Rule. — The City Record (Tue., Aug. 18, 2026), DCWP Notice of Public Hearing and Opportunity to Comment, Statement of Basis and Purpose; public hearing 2026-09-17, 11:00 A.M.; Law Dep't certification signed 2026-08-05; reference numbers 2026 RG 059 / DCWP-82

Consequence for anything automated: the adopted rule text still says "September 1, 2026" in its own transition triggers (the (f)(6)/(7)/(8) account-scoping clauses quoted below), while the operative effective date is 2027-01-01 and DCWP's FAQ answers every scoping question using 2027-01-01. Encode 2027-01-01, and re-verify after the September hearing that the conforming amendment was adopted as proposed.

What governs until 2027-01-01

The pre-SHIELD 6 RCNY § 5-77 — which is stricter than Reg F on frequency. DCWP's own description of the status quo, in the SHIELD Rule's Statement of Basis and Purpose:

A fact that industry commenters largely seemed to have overlooked is that the communications requirements currently in effect—and which have been in effect for over 45 years in New York City — unequivocally provide that more than two collection communications per week via any medium are considered excessively frequent. Consequently, the status quo for debt collectors pursuing debts from New York City consumers is a maximum of two communications within seven days per consumer, regardless of federal law. — DCWP NOA (2026-02-26), at 8

The pre-amendment rule text itself (shown as deleted matter in the NOA redline):

(iv) with excessive frequency. In the absence of knowledge of circumstances to the contrary, a debt collector shall assume that more than twice during a seven-calendar-day period is excessively frequent. — 6 RCNY § 5-77(b)(1)(iv) (pre-SHIELD text, in force through 2026-12-31)

Note the counting difference: the current rule is per consumer, the SHIELD rule is per account (see below).

Licensing — the DCA licence

Official DCWP statement of who needs one (nyc.gov licence checklist, retrieved 2026-08-21):

Businesses whose principal purpose is to regularly collect or to attempt to collect personal or household debts from New York City residents must have a Debt Collection Agency license no matter where the agency is located, including outside of New York State. — DCWP, Debt Collection Agency License Application Checklist

The same checklist states the requirement reaches attorneys and law firms "who regularly engage in activities traditionally performed by debt collectors" (citing Eric M. Berman P.C. v. City of New York, No. 09-cv-3017 (E.D.N.Y. Feb. 3, 2016) (order dismissing the case)) and debt buyers, "businesses that buy debt and then try to collect money directly or through the services of another," and refers the reader to Admin. Code § 20-489 for the complete definition.

Checklist requirements, verbatim figures (same source, retrieved 2026-08-21):

• $5,000 surety bond — "Copy of your $5,000 Surety Bond, properly signed … The copy of the bond must name the City of New York as the Certificate Holder."
• Licence period: 2 years, "Expiration Date: January 31 in odd years." Confirmed independently by DCWP's licence-expiry table as amended 2026-08-06: "Debt Collection Agency — January 31 of Odd Years" (The City Record, Thu., Aug. 6, 2026, at 3296).
• Prorated fee schedule: $150 (filed Feb 1–Jul 31 of an odd year, licence to Jan 31 of the next odd year); $113 (Aug 1 odd year–Jan 31 even year); $75 (Feb 1–Jul 31 even year); $38 or $188 (Aug 1 even year–Jan 31 odd year, 6-month or 30-month option).
• Child-support debt: a business collecting child-support debt in NYC must also file its disclosure form (terms required by Admin. Code § 20-494.1(e)) and its standard contract (terms required by Admin. Code § 20-492(c)).
• A Non-Resident Form is required if the business is not located within NYC.

Local Law 183 of 2025 did NOT eliminate the DCA bond. DCWP's 2026-08-06 Notice of Adoption implementing LL 183 (eff. 2026-09-08) describes "eliminating bond and fingerprinting requirements for certain license categories," and the rule text repeals bond rules for process servers (6 RCNY §§ 2-232a, 2-232b) and discusses Secondhand Dealer General licences. No provision in that rulemaking touches debt collection agencies, and the DCA checklist still required the $5,000 bond when retrieved 2026-08-21.

Who is covered — the definitions that do the work (SHIELD, eff. 2027-01-01)

The SHIELD Rule's reach is set by two defined terms, both quoted verbatim from the NOA (new material shown as adopted; bracketed matter in the NOA is deleted text):

Debt collection procedures. The term "debt collection procedures" means any attempt by any person, including an original creditor, to collect a debt after any of the following: (1) with respect to accounts for which creditors are required to send periodic statements, the creditor has ceased sending those statements, or taken or threatened to take legal action against the consumer; (2) with respect to 30-day accounts for which periodic statements are not required, the creditor has ceased sending bills for the debt or taken or threatened to take legal action against the consumer; or, (3) with respect to all other types of credit, the creditor has accelerated the unpaid balance of the debt or demanded the full balance due. — 6 RCNY § 5-76 (SHIELD)

Debt collector. The term "debt collector" means any person, including any natural person or organization, including a debt collection agency, who: (A) is engaged in any business the principal purpose of which is the collection of any debts, or (B) regularly collects, or attempts to collect, directly or indirectly, debts owed or due or asserted to be owed or due to another person, or debts owed or due or asserted to be owed or due to the person collecting or attempting to collect the debts. (C) The term also includes a buyer of debts who seeks to collect on such debts either directly or indirectly, as well as any creditor that, at any time, in collecting its own debts, uses any name other than its own that would suggest or indicate that someone other than such creditor is collecting or attempting to collect such debts. — 6 RCNY § 5-76 (SHIELD). Exclusions (D)(1)–(5): government officers acting officially; persons performing an action required by law or regulation, or required in order to institute or pursue a legal remedy; nonprofit credit counsellors; employees of utilities regulated under the Public Service Law to the extent of inconsistency; and process servers / persons serving or filing formal legal pleadings who are not a party or counsel.

And the counting rule that defeats the "different employee, different counter" argument:

Where a provision of this part limits the number of times an action may be taken by the debt collector, or establishes as a prerequisite to taking an action that the debt collector has received or done something, or prohibits an action if the debt collector has knowledge of or reason to know something, the term "debt collector" includes any debt collector employed by the same employer. — 6 RCNY § 5-76 (SHIELD)

DCWP's own scope summary:

The SHIELD Rule governs all debt collection activity conducted on NYC consumer accounts, on or after January 1, 2027, when a debt collector is engaged in debt collection procedures. … Important: These rules do not apply to day-to-day business transactions, billing, or customer service on accounts that are not subject to debt collection procedures. — DCWP FAQ (08/04/2026), Q1, at 2

Communications — the 3-in-7 cap (SHIELD, eff. 2027-01-01)

(A) Excessive frequency means any communication or attempted communication, except communications or attempted communications set forth in item (D) of this subparagraph, made by the debt collector to a consumer by any medium of communication, in connection with the collection of debt within a seven-consecutive-calendar-day period, either 1) more than three times in total during such period or 2) any time after the consumer responded to a prior communication within such period. (B) Where a debt collector is attempting to collect on multiple debts from the same consumer, excessive frequency shall be calculated separately for each distinct account belonging to the consumer. (C) The seven-day consecutive calendar-day period shall start on the date of the first communication or attempted communication including limited content-messages. — 6 RCNY § 5-77(b)(1)(iv) (SHIELD)

Item (D) excludes from the count: hard-copy communications sent by U.S. mail or other delivery service; communications initiated by the consumer; and an initial communication made in response to a consumer's request for communication (the NOA lists further exclusions in (D)(IV) et seq., including undeliverable attempts and legally required or litigation communications).

Two definitions make this counter much broader than Reg F's:

Attempted communication. The term "attempted communication" means any act to initiate a communication or other contact about a debt with any person through any medium, including by soliciting a response from such person. … A limited-content message is an attempted communication. — 6 RCNY § 5-76 (SHIELD)

Electronic communications — consent first (SHIELD, eff. 2027-01-01)

A debt collector may use a specific email address, text number, social-media account or other electronic medium only if the channel is private and direct to the consumer and one of three conditions is met (6 RCNY § 5-77(b)(5)(i)):

(A) the debt collector obtains revocable consent from the consumer in writing, given directly to such debt collector, to use such email address, text message number, social media account, or another electronic medium of communication to communicate about the specific debt, and the consumer has not since revoked the consent, provided that a debt collector may correspond with a consumer through electronic communications solely to satisfy the requirements of this paragraph and to obtain written consent, but the debt collector may not collect or attempt to collect debt by electronic communications until the requirements in this paragraph are satisfied; (B) the debt collector is the original creditor and obtained consent from the consumer, given directly to the debt collector, … prior to the institution of debt collection procedures, and the consumer has not since revoked such consent; or (C) the consumer used such email address, text message number, social media account, or another electronic medium of communication to communicate with the debt collector about a debt within the past 60 days and the consumer has not since opted out … — 6 RCNY § 5-77(b)(5)(i) (SHIELD)

An electronic signature counts as written consent (ESRA / E-SIGN), the consent record must be retained "until the debt is discharged, sold, or transferred," and every electronic communication must carry an opt-out that is honoured in the same language as the communication (§ 5-77(b)(5)(ii)–(v)).

Disclosures in EVERY communication (SHIELD, eff. 2027-01-01)

Two duties attach to every communication, not just the first — both framed as false or misleading practices under § 5-77(d):

(15) except for limited-content messages and where otherwise expressly permitted by federal, state, or local law, the failure to disclose clearly and conspicuously in all communications, in the same language used by the debt collector to collect the debt, that the debt collector is attempting to collect a debt and that any information obtained will be used for that purpose; — 6 RCNY § 5-77(d)(15) (SHIELD; emphasis added)

(20) except where expressly permitted by federal, state, or local law, the failure to clearly and conspicuously disclose, before any attempt to collect a debt, that the communication is being recorded and the recording may be used in connection with the collection of the debt; or — 6 RCNY § 5-77(d)(20) (SHIELD; emphasis added)

DCWP reads (d)(15) broadly: the warning applies "to all communications where the debt collector conveys information about the debt, whether directly or indirectly, through any medium. This includes, but is not limited to, response letters sent to consumers about verification, debt assignment notices, and payment receipts." Placement is policed — front page, or a bold uppercase pointer to it in the body of the reverse side; "[p]lacing the 5-77(d)(15) mini-Miranda warning alongside other disclosures on the back, outside the body of the letter, or on a separate page of the communication does not satisfy the 'clear and conspicuous' requirement." On calls, the (d)(20) recording disclosure comes "at the start of the call … before discussing the alleged debt amount, regardless of who initiated the call." (DCWP FAQ, 08/04/2026, § VI, at 8 — agency guidance, not authority.)

Related: § 5-77(d)(21) makes it a violation to represent falsely "that the consumer cannot dispute the debt or request verification of the debt … by oral communication or by any medium of communication used by the debt collector," and § 5-77(d)(16) permits an assumed name only if the collector uses it consistently, is its only user, and it is on file.

vs federal: FDCPA § 1692e(11) requires the full warning in the initial communication and a "this is from a debt collector" line thereafter. NYC requires the full warning in every communication, in the language used with the consumer, and adds a recording disclosure with no federal analogue.

Validation notice + the NYC rights statement (SHIELD, eff. 2027-01-01)

(1) Validation notice. Within five days after the initial communication with a consumer in connection with the collection of any debt, a debt collector … must send the consumer a written notice containing any and all information required by federal and state law, as well as the following information in a clear and conspicuous manner, unless the consumer paid the debt or such information was contained, clearly and conspicuously, in an initial written communication sent by U.S. mail or other delivery service … — 6 RCNY § 5-77(f)(1) (SHIELD; the trailing clause carries the transition date discussed above — "September 1, 2026" in the adopted text, being conformed to January 1, 2027)

The notice must go by mail: "If a debt collector only delivers a validation notice electronically or orally, it does not satisfy the requirement" (§ 5-77(f)(2)(i)). Its NYC content includes the DCWP licence number where applicable, a named natural-person contact answering during business hours, a NYC itemization keyed to the defined "itemization reference date," the time-barred disclosure where applicable (§ 5-77(f)(1)(ix)), and this mandatory statement:

PLEASE READ: Information About Your Rights as a New York City Consumer

• There is no time limit for a New York City consumer to dispute the debt in collection under New York City Law. You can let collectors know you dispute the debt using any of the ways they contact you, including by phone.

• You must get a response to the disputed debt in 60 days. Once you dispute the debt, the collector must stop collection. Within 60 days after receiving your dispute, a debt collector must give you either 1) verification of the debt, or 2) a "Notice of Unverified Debt" stating it can't verify the debt or continue collection. Be sure to keep a copy of all letters.

• Inform the debt collector if any charges arise from medical debt. … — 6 RCNY § 5-77(f)(1) (SHIELD)

Disputes and verification — no 30-day window, and a hard 60-day cliff

(i) A consumer may dispute or request a verification of the debt orally, in writing, or electronically (if the debt collector uses electronic communications to collect debt) at any time during the period in which the debt collector owns or has the right to collect the debt. … a debt collector must cease collection on such disputed debt after receiving the first dispute or the first request for verification by a consumer, unless and until the consumer receives verification of the debt … — 6 RCNY § 5-77(f)(6)(i) (SHIELD; emphasis added)

(i) A debt collector must send the consumer written verification of the debt within the time period permitted by state law, but no later than 60 days after receiving the first dispute or first request for verification of the debt made by the consumer. … (ii) A debt collector must cease collection activity until the consumer is deemed to have received the written verification information. The debt collector may assume that a consumer received the verification information five business days … after the debt collector sent it; (iii) If a debt collector, other than an original creditor, does not send the consumer verification of the debt within the required period, it cannot resume collection activity on the debt and must mail a notice of unverified debt to the consumer … (iv) If a debt collector that is an original creditor does not send the consumer verification … it must mail a notice of unverified debt … and may not resume collection unless and until it sends the consumer verification of the debt; — 6 RCNY § 5-77(f)(7) (SHIELD; emphasis added)

Verification must include the originating creditor's debt document or original written confirmation of the transaction (for a revolving account, the charge-off statement or the most recent monthly statement recording a purchase, payment or balance transfer), records of any prior settlement agreement, and the final/charge-off statement — and: "Documents created or generated after the time of charge-off of the debt or institution of debt collection procedures shall not qualify as such confirmation" (§ 5-77(f)(7)(v)(A)). A default judgment does not verify a debt; a judgment after adjudication on the merits creates a rebuttable presumption of compliance (§ 5-77(f)(7)(vi)).

The Notice of Unverified Debt (§ 5-77(f)(8)) travels with the account. It must state that collection will cease, be noted in the account records, disclose prior CRA furnishing, tell the consumer to keep it and give it to any other collector, and state:

(vi) … that under the laws of the City of New York, any other debt collector with the information on the Notice of Unverified Debt cannot resume collection activity in New York City unless and until the verification of the disputed debt is provided to the consumer; (vii) clearly and conspicuously provide that such information and the Notice of Unverified Debt will transfer if the account is sold, assigned, placed with an attorney to sue on the debt or is part of any litigation to recover on the debt by the debt collector, or if it is returned to a creditor, debt owner, or the entity that placed the account with the debt collector … — 6 RCNY § 5-77(f)(8) (SHIELD)

Separately, on request the collector must give the originating creditor's address within 30 days, and must cease collection until it does (§ 5-77(f)(9)).

Medical debt — subdivision (j), the first-of-its-kind layer

Medical debt means an alleged obligation of a consumer to pay any amount whatsoever related to the receipt of health care services, products, or devices provided to a person by a hospital, a health care professional or an ambulance service licensed, authorized, or certified under New York State law. Medical debt does not include debt charged to a credit card unless the credit card is issued under an open-ended or closed-end plan offered specifically for the payment of health care services, products, or devices provided to a person. — 6 RCNY § 5-77(f)(10) (SHIELD)

Covered medical entity. The term "covered medical entity" means a health care entity that is tax-exempt under federal or New York State law or qualifies for distributions from the Indigent Care Pool from the State of New York or any other such fund or distribution allocated to reduce the charges of medical services to consumers by granting financial assistance, through a financial assistance policy, to patients based on need or an inability to pay. — 6 RCNY § 5-76 (SHIELD)

For debt from a covered medical entity, the collector is:

(1) prohibited from collecting or attempting to collect on such medical debt if the debt collector knows or should know that: (i) To do so violates federal, state, or local law, or the financial assistance policy of the covered medical entity. (ii) The person has an open application for financial assistance with the covered medical entity. (iii) The financial assistance policy should have provided financial assistance to the person to cover all, or a portion, of the medical debt. (iv) A misrepresentation was made to the person about the financial assistance policy or payment options regarding the medical debt, including … (A) The person was wrongly denied, or not given proper and timely notice of, available financial assistance; (B) The person was discouraged from applying for financial assistance; (C) The person was induced to agree to pay … with misinformation about payment options or the financial assistance policy; or (D) The person was only presented with options to pay or to agree to pay for all or part of the medical debt regardless of income level. — 6 RCNY § 5-77(j)(1) (SHIELD)

And on notice of a problem the collector must run corrective measures — the consumer may trigger them "by any means of communication or in any language used by the debt collector to collect debt, without the debt collector requiring the consumer to submit any supporting documentation" (§ 5-77(j)(2)):

(i) Inform the entity that placed the account with the debt collector within one business day that the debt may be subject to the covered medical entity's financial assistance policy. (ii) Provide and record in plain language the following statement: "A FINANCIAL ASSISTANCE POLICY MAY APPLY TO THIS MEDICAL DEBT," in a manner readily noticeable and searchable, in the following records: (A) all of the consumer's accounts arising from medical debt from the covered medical entity, from one discrete hospitalization, or related treatments of one general health condition within a six-month period; (B) a written notification that must be sent by U.S. mail or other delivery service to the consumer along with the verification of the debt …; and (C) a written notification that must be sent to any receiving party upon transferring any of the consumer's accounts with medical debt from the same covered medical entity. (iii) Provide any disclosure to the consumer regarding the financial assistance policy, by U.S. mail or other delivery service, clearly and conspicuously on the first page of any written communication … Any written notification to a consumer regarding the financial assistance policy may not be delivered exclusively by the debt collector through electronic means. (iv) Maintain a monthly log or record of all consumer accounts in which the debt collector took corrective measures … — 6 RCNY § 5-77(j)(2) (SHIELD)

A medical-debt dispute also drags in sibling accounts: on a dispute or verification request the collector must verify related accounts (the NOA describes this as all accounts from the same or affiliated medical providers within a three-month period — § 5-77(f)(10)(iv)).

Credit reporting — 14-day pre-furnishing gate

(10) furnishing to a consumer reporting agency, as defined in section 603(f) of the Fair Credit Reporting Act (15 U.S.C. § 1681a(f)), information about a debt unless the debt collector has sent to the consumer in at least one medium of communication used to collect the debt, and sent a written copy to the consumer via U.S. mail or other delivery service, a notice that states, clearly and conspicuously, that the information about the debt will be reported to a consumer reporting agency and has waited 14 consecutive days after sending such notice. During the waiting period, the debt collector must permit receipt of, and monitor for, notifications of undeliverability from communications providers. If the debt collector receives such notification during the waiting period, the debt collector must not furnish information about the debt to a consumer reporting agency until the debt collector satisfies this paragraph. — 6 RCNY § 5-77(e)(10) (SHIELD; listed as an unfair/unconscionable practice)

Time-barred debt — mail first, then wait

(1) A debt collector must maintain reasonable procedures for determining the statute of limitations applicable to a debt it is collecting and whether such statute of limitations has expired. (2) Notice of Time-Barred Debt. If a debt collector … seeks to collect on a debt for which the debt collector knows or has reason to know, that the statute of limitations for such debt has expired, the debt collector must, before contacting the consumer about the time-barred debt by any other means, deliver to the consumer by U.S. mail or other delivery service a written notice of time-barred debt that: (i) clearly and conspicuously discloses in English and any other language used by the debt collector to communicate with the consumer substantially the same time-barred-debt disclosure below, except for changes allowed to conform with New York State's disclosure:

• THE TIME TO SUE ON THIS DEBT HAS EXPIRED. — 6 RCNY § 5-77(i)(1)–(2) (SHIELD; emphasis added)

The disclosure continues with the "IF YOU ARE SUED ILLEGALLY" bullets (FDCPA violation, the SOL defence, no obligation to admit/promise/waive, the warning that a payment may restart the creditor's right to sue, and a referral to an attorney or legal aid). The regime then adds a 14-consecutive-day wait monitoring for undeliverability before other-medium contact, an oral-disclosure-before-amounts rule for phone contact, repetition of the disclosure in every permitted communication, and a bar on taking any settlement or payment until the notice requirements are satisfied (§ 5-77(i)(3)–(5)).

⚠ The state/city collision: the NYC script's "may start again" line is written for debts that can be revived, but CPLR 214-i forbids revival for New York consumer credit transactions — which is why the rule allows "changes allowed to conform with New York State's disclosure." Templates must branch on debt type; see state/ny.md for DFS's conforming language.

Language access

• Validation notices: if the collector offers non-English validation notices and the consumer asks, mail the notice "completely and accurately in the language requested within 30 days"; the federal Spanish-translation duty (12 C.F.R. § 1006.34(e)(2)) is restated (§ 5-77(f)(3)(i)).
• Trigger by contact: a collector "may not contact a consumer in a language other than English to collect debt without providing the consumer, by U.S. mail or other delivery service, a validation notice written accurately in the language used … within five days of the first contact" in that language (§ 5-77(f)(3)(ii)).
• Symmetry: having sent a non-English validation notice, the collector "must also accept and respond to disputes, complaints, requests for verification of the debt, requests to cease further communication, and other communications … completely and accurately in the same language" unless the consumer asks for another offered language (§ 5-77(f)(3)(iii)).
• Public websites: any public site relating to debts in collection must disclose available language access services and DCWP's glossary, "on the homepage … or on a page directly accessible from a hyperlink on the homepage labeled 'NYC Rules on Language Services and Rights'" (§ 5-77(h)).
• Recording language preference is mandatory: collecting "without recording the language preference of such consumer, except where the debt collector is not aware of such preference despite reasonable attempts to obtain it," is an unfair practice (§ 5-77(e)(9)).

Penalties — 6 RCNY § 6-62

DCWP adopted a rewritten Debt Collection Penalty Schedule on 2026-06-29 (proposed 2026-04-30; hearing 2026-06-01). The schedule now carries one row per SHIELD subdivision:

§ 6-62 Debt Collection [Agency] Penalty Schedule.

6 RCNY § 5-77(a) — Failure to comply with requirements pertaining to acquisition of location information — $525 · $525 · $1,050 · $1,050 · $3,500 · $3,500 — The City Record (Mon., June 29, 2026), DCWP Notice of Adoption, at 2766

The same six figures ($525 / $525 / $1,050 / $1,050 / $3,500 / $3,500) attach to each of § 5-77(a) location information, (b) communications, (c) harassment or abuse, (d) false or misleading representations, (e) unfair or unconscionable means, (f) validation notice and verification of debts, (h) public websites, (i) time-barred debts, (j) medical debt, and (k) record retention. The old row for the § 2-191 statute-of-limitations disclosure is struck (SHIELD repeals § 2-191 outright and moves that duty into § 5-77(i)).

UNVERIFIED — column headers. The amending text reproduces the six penalty columns without their header row, so which column is first/second/third offence and which is the default-vs-settled tier is not established by any official text retrieved. Do not encode the tiers; the amounts and their ordering are what is verified. DCWP's own note: "This rule does not modify any existing penalty amounts for violations, which are set by law."

The penalty schedule moved too:

NOTICE IS HEREBY GIVEN that the final rules of the Department of Consumer and Worker Protection relating to the penalty schedule applicable to debt collectors published in the City Record on June 29, 2026, will go into effect on January 1, 2027, not September 1, 2026, the date contained in the publication. — The City Record (Thu., Aug. 20, 2026), NOTICE OF CHANGE OF EFFECTIVE DATE

Records

SHIELD § 5-77(k) requires records "that are evidence of compliance or noncompliance with part 6 of subchapter A of chapter 5 of title 6 … starting on the date that the debt collector begins collection activity on the debt until three years after the debt collector's last collection activity on the debt." The licensing-side records rule (6 RCNY § 2-193) was amended in the same NOA and now expressly includes "A copy of all policies related to medical debt, including but not limited to any financial assistance policies addressing hospital financial assistance programs" and records of compliance with part 6.

Administration and enforcement posture (context — not authority)

DCWP under the Mamdani administration (Commissioner Samuel A.A. Levine) branded and announced the rule itself:

The Stopping Harassment and Intimidation and Ensuring Lawful Debt (SHIELD) Collection Rule goes beyond federal rules (Fair Debt Collection Practices Act and Regulation F) by allowing New Yorkers to dispute their debt at any time, further limiting the number of times debt collectors can contact individuals, and delivering first-of-its-kind protections related to the collection of medical debt. — DCWP press release 022-26 (2026-02-26)

DCWP's compliance materials are official agency guidance, not authority, but they are what the agency will measure against: the FAQ (08/04/2026), a SHIELD Rule presentation deck (DCWP101, dated 2026-08-12), and a DCWP webinar announced for 2026-10-05 on the licence checklist page. DCWP also has adjacent 2026 rulemakings in flight that touch collectors indirectly — a proposed "Unclaimed Restitution Fund" funded with unclaimed money from DCWP enforcement actions, and a proposed rule prohibiting hidden "junk fees" (both noticed in The City Record, July 2026) — not researched here; do not rely on them without pulling the text.

Plain English (interpretation — the quotes win)

• Nothing about NYC is optional if the consumer lives in the five boroughs. The licence requirement follows the consumer's location, not the agency's; an out-of-state agency collecting from an NYC resident needs the DCA licence.
• Two regimes in one calendar year. Through 2026-12-31: pre-SHIELD § 5-77 — two communications per seven days per consumer, any medium. From 2027-01-01: three per seven days per account, plus a stop-on-response rule that ends the window early, with limited-content messages and undelivered attempts counted as attempted communications.
• The dispute clock has no ceiling and the verification clock has a cliff. A consumer can dispute at any time while the collector holds the debt; a third-party collector that misses 60 days loses the account permanently, and the Notice of Unverified Debt follows the paper to every downstream buyer.
• Original creditors are inside the rule once debt collection procedures begin — but their day-to-day billing and servicing is not, and they keep a path back (verify, then resume) that third-party collectors do not.
• Medical debt is a different product. Financial-assistance-policy screening is a precondition to collecting, the consumer needs no documentation to trigger corrective measures, and the required record statement is a literal string that must be searchable.

Traps / edge cases

1. The rule text and the effective date disagree. Adopted text says "September 1, 2026"; the operative date is 2027-01-01, with a conforming amendment pending (hearing 2026-09-17). Anything reading dates out of the rule text will be wrong until that amendment lands.
2. "Three in seven" is not Reg F's "seven in seven." Different denominator (per account, not per person-per-debt), different media scope (all media except hard-copy mail, versus telephone calls only), and a response by the consumer closes the window rather than opening a fresh one.
3. Per-employer aggregation. § 5-76's closing paragraph folds every collector at the same employer into one "debt collector" for counting and knowledge purposes.
4. Validation notice must be mailed. Electronic-only or oral delivery does not satisfy § 5-77(f)(1)–(2), regardless of consent to e-communications.
5. Post-charge-off documents can't verify a debt. Anything generated after charge-off or after debt collection procedures began is disqualified as the confirming document, as is a default judgment.
6. The time-barred script conflicts with CPLR 214-i for consumer credit transactions — conform it, don't ship it verbatim.
7. Don't quote the Administrative Code from this page. amlegal blocks automated fetch; the Code sections here are cites carried in DCWP documents, not retrieved text.
8. Penalty tiers are not established. Amounts verified; column semantics are not.

Related

• New York State — SOL, revival, 23 NYCRR Part 1, CCFA, GBL art. 29-H
• Reg F call frequency — the federal floor NYC exceeds
• Reg F validation notice — NYC adds content and a mail-delivery requirement
• Reg F time-barred debt — federal suit bar; NYC adds a notice regime
• Reg F credit-reporting prerequisites — NYC layers a 14-day wait on top
• State matrix