{"version":1,"type":"rich","provider_name":"Libsyn","provider_url":"https:\/\/www.libsyn.com","height":90,"width":600,"title":"NYC DCWP at the Forefront of Consumer Protection: A Conversation with Commissioner Sam Levine","description":"In this episode of the Consumer Finance Monitor Podcast, host Alan Kaplinsky (founder, former chair for 25 years and now Senior Counsel) had the pleasure of speaking with Sam Levine, Commissioner of the New York City Department of Consumer and Worker Protection (DCWP), about the agency\u2019s evolving role as one of the most active local consumer protection regulators in the country. Important note: This podcast was recorded prior to DCWP\u2019s April 8, 2026 release of its proposed \u201cclick-to-cancel\u201d rule addressing subscription practices. Alan recorded a description of the proposed rule which is at the end of the recording. We also wrote a separate blog about that significant development. A Local Regulator with National Influence From the outset, Commissioner Levine emphasized that DCWP is not simply a municipal agency focused on traditional licensing and enforcement, but rather a modern regulator tackling complex consumer protection issues that increasingly mirror those addressed at the federal level. \u201cLocal enforcement can be incredibly impactful\u2014we\u2019re often closest to consumers and can move quickly to address emerging harms.\u201d He noted that New York City\u2019s scale and diversity make it a uniquely important testing ground for innovative consumer protection strategies. Executive Orders Driving Enforcement Priorities A key backdrop to DCWP\u2019s current activity is a pair of mayoral directives\u2014Executive Order 9 and Executive Order 10\u2014issued by New York City Mayor Zohran Mamdani on January 5, 2026 (shortly after he took office) which we have discussed in a prior blog post. These Executive Orders signal a clear policy direction to fulfill his campaign promise to make life more affordable for everyday New Yorkers: an intensified focus on consumer protection, particularly in areas involving deceptive practices, hidden or \u201cjunk\u201d fees, and recurring payment models. Executive Order 10, in particular, directs DCWP to prioritize enforcement against \u201csubscription traps\u201d and misleading recurring charge practices\u2014laying the groundwork for the Department\u2019s subsequent proposed \u201cclick-to-cancel\u201d rule published on April 8, 2026. Commissioner Levine made clear that these directives are not merely aspirational, but are actively shaping the agency\u2019s enforcement and rulemaking agenda: \u201cWe\u2019re aligning our work with the Mayor\u2019s directive to go after practices that frustrate consumers and undermine fair competition.\u201d Enforcement Priorities: Targeting Deceptive Practices A central theme of our discussion was DCWP\u2019s aggressive focus on deceptive and unconscionable trade practices, particularly in areas where consumers are most vulnerable. Commissioner Levine highlighted the agency\u2019s 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 \u201cWe\u2019re focused on conduct that distorts consumer choice\u2014where people think they\u2019re getting one thing but end up locked into something very different.\u201d He underscored that transparency and fairness are guiding principles behind DCWP\u2019s enforcement agenda. Final Debt Collection Rules: A Significant Regulatory Development We also discussed DCWP\u2019s 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\u2019s 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. \u201cThe goal is to ensure that debt collection practices keep pace with how consumers actually communicate today, while maintaining strong protections against harassment and abuse.\u201d 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. \u201cThere\u2019s a real opportunity for federal, state, and local regulators to work together and reinforce one another\u2019s efforts.\u201d He explained that DCWP frequently collaborates with the FTC, the New York State Attorney General\u2019s 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: \u201cWe don\u2019t have to wait. If we see harm affecting New Yorkers, we\u2019re going to act.\u201d Rulemaking as a Strategic Tool In addition to enforcement, Levine emphasized DCWP\u2019s increasing use of rulemaking to shape market behavior proactively. \u201cRules give clarity to businesses and protections to consumers\u2014they\u2019re an important complement to case-by-case enforcement.\u201d 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\u2019s 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 \u201cInnovation can be a good thing\u2014but it can\u2019t come at the expense of transparency or fairness.\u201d 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 \u201cOur goal is straightforward: markets should work for consumers, not against them.\u201d 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\u2014further underscoring the agency\u2019s commitment to addressing modern consumer risks and reflecting the policy direction set by Executive Order 10. Given Commissioner Levine\u2019s 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. ","author_name":"Consumer Finance Monitor","author_url":"https:\/\/www.ballardspahr.com\/","html":"