It has been reported that the New York City Department of Consumer and Worker Protection (DCWP) has pushed back the effective date of its amended debt collection regulations, known as the SHIELD Rule, from September 1, 2026 to January 1, 2027. The delay, which has not yet been confirmed on the DCWP’s official website, was announced to provide regulated entities additional time to make operational adjustments and to allow the agency to address outstanding questions from industry stakeholders.

Background: The TCPA’s Private Right of Action for Unwanted Calls

Congress enacted the TCPA in 1991 to address the proliferation of unwanted telephone solicitations. The statute defines “telephone solicitation” as “the initiation of a telephone call or message for the purpose of encouraging the purchase or rental of, or investment in, property, goods, or services.” 47 U.S.C. § 227(a)(4) (emphasis added).

Yesterday, the federal banking regulators issued new interagency guidance directing supervised financial institutions to take a closer look at credit risk when lending to individuals who are not legally authorized to work in the U.S. The guidance, issued jointly by the Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and National Credit Union Administration (NCUA), follows a May 2026 Executive Order (discussed here) aimed at addressing perceived risks to the financial system arising from the extension of credit to the non-work authorized population.

On July 8, the New Jersey Supreme Court issued a unanimous opinion in Diana, delivering a decisive and long-awaited victory for debt buyers operating in New Jersey. The court’s ruling — affirming the dismissal of a putative class action brought by a borrower seeking to void his credit card debt — definitively closes the door on a theory of liability that has dogged the debt-buying industry in New Jersey for years.

On July 6, the Consumer Financial Protection Bureau (CFPB or Bureau) released its 2026 regulatory agenda, outlining its planned rulemaking initiatives across the pre-rule, proposed rule, and final rule stages. The agenda reflects the Bureau’s continued shift under the current administration toward deregulation, regulatory streamlining, and reconsideration of rules issued under prior leadership.

After years of pandemic-era forbearance programs, emergency moratoriums, and historically low foreclosure volumes, the mortgage market is undergoing a meaningful correction. Foreclosure activity is rising steadily across the country, and with it comes a familiar set of legal risks for servicers, lenders, and investors. The question is no longer whether foreclosure volumes will normalize — it is whether organizations are prepared for the compliance and litigation exposure that follows.

To keep you informed of recent activities, below are several of the most significant federal events that have influenced the Consumer Financial Services industry over the past week.

Federal Activities

State Activities


Federal Activities:

On July 2, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System…