On July 28, The New York City Department of Consumer and Worker Protection (DCWP) announced that its amended debt-collection rule, scheduled to take effect on October 1, 2025, has been postponed, leaving the industry in limbo for the third time since the rules were finalized in August 2024. DCWP will set a new effective date with at least three months' advance notice.
DCWP's amendments, which sit atop the CFPB's Regulation F, significantly expand disclosure, language access, and record-retention duties for anyone collecting consumer debt in the five boroughs. While the latest delay offers extra implementation time, the substance of the rule remains unchanged.
Key provisions of the amendments include:
- Contact frequency limits. Collectors may not contact or attempt to contact a consumer more than three times in any seven-day period across all channels, unless collecting for multiple non-affiliated creditors.
- Opt-in electronic outreach. Email, text, or social-media contact require written, revocable consent and must include a no-cost, one-word opt-out (e.g., "STOP").
- Enhanced validation & verification. A detailed validation notice must be mailed within five days of first contact, and collection must pause upon a consumer dispute or verification request and may not resume until written verification is provided within 45 days.
- Time-barred debt safeguards. For debts beyond the statute of limitations, collectors must first send a written notice disclosing the debt is time-barred and wait 14 days before initiating further contact.
- Medical-debt credit-reporting ban. Medical debts are prohibited from being furnished to consumer reporting agencies. Disputes on one account extend to related accounts from the same provider within a six-month period.
- Three-year record-keeping mandate. Agencies must retain searchable logs of all consumer contacts, disputes, complaints, and call recordings for three years after the last collection activity.
Putting It Into Practice: DCWP's open-ended postponement gives collectors a brief reprieve, but the compliance lift remains steep. Market participants face a moving target and must keep programs designed to meet the rule's contact caps, consent mechanics, verification timelines, and record-retention duties.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
