State Attorneys General

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New York City is moving aggressively into consumer protection territory that federal regulators have largely stepped back from. In January 2026, Mayor Zohran Mamdani signed two executive orders directing the Department of Consumer and Worker Protection (DCWP) to crack down on hidden fees and subscription tricks and traps. DCWP has now followed through, finalizing a first-of-its-kind municipal click-to-cancel rule (previously discussed here and here) and publishing a proposed citywide “junk fee” ban.

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.

On June 25, Illinois Governor JB Pritzker signed into law the Buy-Now-Pay-Later Loan Consumer Protection Act, establishing a licensing and regulatory framework for buy-now-pay-later (BNPL) lenders operating in Illinois. The Act, which the legislature passed unanimously, took effect immediately upon becoming law, though compliance is not required until January 1, 2028.

Louisiana and Massachusetts have each recently issued guidance addressing motor vehicle dealer advertising practices, particularly around the disclosure of fees in advertised vehicle prices. Both actions follow the Federal Trade Commission’s March 13, 2026 “Notorious 97” warning letters to auto dealership groups nationwide (discussed here) and reflect ongoing efforts at the state and federal level to ensure that advertised prices accurately reflect the total cost consumers will be required to pay.

The New York City Department of Consumer and Worker Protection (DCWP) recently published new compliance resources for its amended debt collection regulations, known as the SHIELD Rule, which are scheduled to take effect on September 1, 2026.

On June 16, Vermont Governor Phil Scott signed H.648, a wide‑ranging financial services bill that, among other changes, brings sales‑based financing and certain factoring arrangements squarely within the state’s regulated financial services framework. The sales‑based financing provisions were added late in the process, borrowing heavily from the most controversial elements of Texas’s 2025 HB 700 (discussed here) and other state commercial financing disclosure laws, and layering Vermont‑specific requirements on top of existing licensed lender rules. The commercial financing portions of the law are to take effect July 1, 2027.

On June 2, Louisiana Governor Jeff Landry signed SB 254 into law as Act 751, prohibiting retail businesses from imposing surcharges on customers who pay with a debit card. The law takes effect August 1, 2026.

Virginia is implementing a new Business Screening Services (BSS) program that will significantly change how private background screening companies handle Virginia criminal and traffic history records.

On April 8, Virginia Governor Abigail Spanberger signed HB 444, the Uniform Consumer Debt Default Judgments Act, into law. The Act establishes pleading and notice requirements in certain consumer debt collection actions that must be met for a creditor to obtain a default judgment against a consumer. This Act is based on a model drafted by the Uniform Law Commission, similar versions of which have been enacted in Washington and introduced in Pennsylvania. HB 444 will take effect on July 1, 2027.

On May 19, Virginia Governor Abigail Spanberger (D) indicated that she intends to veto SB 229, a pending bill which would have created a Virginia state court class action mechanism and would have modified the Virginia Consumer Protection Act (VCPA) in critical ways. Governor Spanberger initially noted that she “approve[d] the general purpose of this bill,” but returned it to the legislature with proposed amendments.