Servicing + Collectors

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This article republished on insideARM on September 23, 2026.

If you needed a reminder that state attorneys general are treating unlicensed debt collection as a serious enforcement priority, Massachusetts just delivered one. On August 31, the Suffolk Superior Court entered a Final Judgment by Consent resolving the Massachusetts Attorney General’s long-running case against several debt buyers and their owner. Under the terms of the order, the defendants must pay roughly $52 million in debt relief for more than 6,000 Massachusetts consumers, and permanently cease all debt buying, selling, and collection activities involving Massachusetts consumers.

In this episode of The Consumer Finance Podcast, host Chris Willis sits down with Partners Joseph DeFazio and Joseph Froehlich to discuss the New Jersey Supreme Court’s ruling in Diana, a unanimous ruling and long-awaited victory for debt buyers operating in New Jersey. At the center of the conversation is a high-volume litigation campaign waged by the Kim Law Firm, which targeted the chain of title for consumer debts under the New Jersey Consumer Finance Licensing Act (NJCFLA). Kim’s core theory argued that any consumer debt under $50,000 — including personal loans, auto loans, and retail credit — that was ever touched, transferred, or assigned by an unlicensed entity is void and unenforceable as a matter of law, and that any attempt to collect on such a debt independently triggers statutory liability.

As we previously discussed here, the New York City Department of Consumer and Worker Protection (DCWP) delayed the effective date of its amended debt collection regulations, known as the SHIELD Rule, from September 1, 2026 to January 1, 2027, to provide regulated entities additional time to make operational adjustments and to allow the agency to address outstanding questions from industry stakeholders.

On July 21, 2026, the Federal Trade Commission (FTC) announced a proposed settlement order permanently banning Dennise Merdjanian — a key operator of a Nevada-based student loan debt relief scheme — from the debt relief industry and from telemarketing. The order resolves the FTC’s charges that Merdjanian and her co-defendants took more than $45.9 million from consumers by impersonating the U.S. Department of Education and making false promises of student loan forgiveness.

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 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.

Statistics for May 2026 consumer litigation filings are in, and the picture is essentially the reverse of April. After all three major consumer protection statutes posted month-over-month increases in April, the first time that had happened in over a year, all three declined in May.

The Consumer Data Industry Association (CDIA) and the Metro 2 Task Force announced that they have approved a new Special Comment Code, DS — Debt Settlement, in response to industry requests for clearer identification of consumer debt settlement activity in credit reporting. An implementation date has not yet been established, but CDIA anticipates that furnishers will be able to begin reporting the DS code in Q2 2027.

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.