NYC DCWP at the Forefront of Consumer Protection: A Conversation with Commissioner Sam Levine

Enforcement Priorities: Targeting Deceptive Practices

A central theme of our discussion was DCWP’s aggressive focus on deceptive and unconscionable trade practices, particularly in areas where consumers are most vulnerable.

Commissioner Levine highlighted the agency’s work in combatting:

1. Hidden fees and misleading pricing practices
2. Predatory lending and financial services abuses
3. Worker exploitation in the gig economy
4. Emerging digital marketplace risks

“We’re focused on conduct that distorts consumer choice—where people think they’re getting one thing but end up locked into something very different.”

He underscored that transparency and fairness are guiding principles behind DCWP’s enforcement agenda.

Final Debt Collection Rules: A Significant Regulatory Development

We also discussed DCWP’s recently finalized debt collection regulations, which we have analyzed in prior blog coverage. These rules represent one of the most significant updates to New York City’s debt collection framework in years.

Commissioner Levine emphasized that the rules are designed to modernize existing requirements and address evolving industry practices, including the increased use of digital communications.

“The goal is to ensure that debt collection practices keep pace with how consumers actually communicate today, while maintaining strong protections against harassment and abuse.”

Among other things, the rules clarify permissible communications, reinforce substantiation and disclosure requirements, and strengthen consumer protections in line with broader trends seen at the federal level.

These rules, which go effective later this year, apply not only to third-party collectors and buyers of consumer debt, but also to creditors of consumers whenever the debtor resides or is located in New York City.

Collaboration with Federal and State Regulators

Drawing on his prior experience at the Federal Trade Commission as Director of the Bureau of Consumer Protection, Levine discussed the importance of coordination across jurisdictions.

“There’s a real opportunity for federal, state, and local regulators to work together and reinforce one another’s efforts.”

He explained that DCWP frequently collaborates with the FTC, the New York State Attorney General’s Office, and other enforcement bodies, particularly in cases involving multi-state or national conduct.

At the same time, he made clear that local regulators can lead:

“We don’t have to wait. If we see harm affecting New Yorkers, we’re going to act.”

Rulemaking as a Strategic Tool

In addition to enforcement, Levine emphasized DCWP’s increasing use of rulemaking to shape market behavior proactively.

“Rules give clarity to businesses and protections to consumers—they’re an important complement to case-by-case enforcement.”

He noted that clear rules can help level the playing field for companies that are already trying to do the right thing.

Focus on Financial Services and Marketplace Innovation

The conversation also explored DCWP’s interest in financial services, particularly as new products and delivery models emerge.

Levine pointed to risks associated with:

1. Fintech innovations that may outpace regulatory frameworks
2. Online platforms that obscure key terms or pricing
3. Products that rely heavily on consumer inertia or behavioral biases

“Innovation can be a good thing—but it can’t come at the expense of transparency or fairness.”

Practical Takeaways for Industry

For companies operating in or serving New York City, the message from DCWP is clear:

1. Expect active enforcement of deceptive practices
2. Monitor local regulatory developments, including mayoral directives and rulemaking initiatives
3. Prioritize clear disclosures and consumer-friendly processes
4. Anticipate continued focus on digital and subscription-based business models

“Our goal is straightforward: markets should work for consumers, not against them.”

Looking Ahead

Although our discussion did not cover it because it happened after our podcast was recorded, DCWP has since proposed a significant new rule targeting subscription practices—further underscoring the agency’s commitment to addressing modern consumer risks and reflecting the policy direction set by Executive Order 10.

Given Commissioner Levine’s leadership and experience, including his prior role at the FTC, DCWP is likely to remain at the forefront of consumer protection innovation.

Consumer Finance Monitor is hosted by Alan Kaplinsky, Senior Counsel at Ballard Spahr, and the founder and former chair of the firm's Consumer Financial Services Group. We encourage listeners to subscribe to the podcast on their preferred platform for weekly insights into developments in the consumer finance industry.

View the recording transcript here.