By the TSI Team
Correction, Nov 3, 2026: this post originally said the FCC’s TCPA opt-out rule would take effect Jan 31, 2027. The FCC adopted a revised rule on Sep 30, published it Oct 26, and it takes effect Nov 25, 2026. We’ve updated the TCPA section and the table below. For the full rule, read what the FCC’s consent revocation order changes, and when.
Three rules change how recovery work runs in January 2027: New York City’s SHIELD debt collection rule on Jan 1, Colorado’s replacement AI law (SB 26-189) on Jan 1, and, earlier than most calendars show, the FCC’s revised TCPA opt-out rule on Nov 25, 2026. Each needs build work, and October is when that work gets a budget line.
Why October
Changing a letter template takes a few weeks once legal review is counted. Changing a dialer rule across three agencies and a law firm network takes longer, because each vendor has its own release calendar. Training takes a cycle. Vendor contract amendments take whatever procurement takes. Work backward from January and most of those clocks start in November. The money for them gets set now.
Jan 1, 2027: New York City’s SHIELD rule
The Department of Consumer and Worker Protection announced the rule on Feb 26, 2026. It was due to take effect Sept 1, 2026, and DCWP pushed it to Jan 1, 2027 (Consumer Finance Monitor, Aug 17, 2026). Some summaries still show the September date. Use January. What it does, per DCWP’s release and its Aug 4 FAQ:
- Caps contact at 3 attempts per account in a rolling 7 days, across all channels.
- Lets a consumer dispute at any stage of collection.
- Sets a 60-day verification window. If the debt isn’t verified in time, a “Notice of Unverified Debt” ends collection.
- Requires medical debt collectors to promote financial assistance, and bars furnishing medical debt to credit bureaus.
- Adds a 14-day wait and disclosures before collecting time-barred debt.
Debt-buyer verification requirements don’t apply to debt purchased before Jan 1, 2027. Two details catch creditors. First, original creditors are in scope when they run collection procedures, beyond routine servicing. Second, the 3-contact cap counts every channel, and it counts per account. So the October question is operational. If a New York account touches your in-house team in month 1, an agency in month 3 and a law firm in month 6, who keeps the count? And when a customer disputes by text to one vendor, how fast does every other party holding that account stop? What to put on the October list:
- A single contact counter for NYC accounts, shared by every party that touches them.
- A dispute intake path that works from any channel and reaches every vendor the same day.
- A 60-day verification tracker, with the unverified-debt notice ready to send.
- A medical-debt flag that blocks bureau furnishing and triggers the financial assistance language.
The 3-contact cap counts every channel, per account. Someone has to own the count.
Jan 1, 2027: Colorado SB 26-189
Colorado repealed and replaced its AI Act in May 2026 with SB 26-189, effective Jan 1, 2027. Per law-firm and compliance summaries published this year, the replacement drops the general requirement to disclose AI interactions. That sounds like less work, and it may be. It’s still a date that changes what you’re required to do, so it belongs on the list. What to put on the October list:
- An inventory of every automated tool that touches Colorado consumers: voice, text, email, chat, scoring.
- A decision, made with counsel, on which disclosures you keep by choice after Jan 1.
- A check of every vendor’s scripts, since your agencies may run tools you haven’t inventoried.
Keep an eye on the neighbors too. Other states have their own AI-voice disclosure rules, and a federal proposal on AI-voice disclosure under the TCPA is still pending at the FCC.
Nov 25, 2026: the TCPA opt-out rule
The FCC adopted its revised consent revocation order (FCC 26-67) on Sep 30, 2026, and published it in the Federal Register on Oct 26 (91 FR 67214). It takes effect Nov 25, 2026, and replaces the revoke-all requirement that was waived until Jan 31, 2027. For informational calls and texts, an opt-out can now cover only the kind of message it answered, and callers can name an exclusive way to revoke as long as they disclose it clearly. The standard stop words still work by text, and opt-outs still have to be honored within 10 business days. The operational problem is the same as before. A revocation received by one party has to reach every party contacting that customer. What to put on the October list:
- A map of every channel where a customer can revoke consent, including replies to texts and requests made to live agents.
- A rule for how fast a revocation received by an agency reaches you and every other vendor.
- An update to vendor contracts that sets that timing in writing.
- A test: send a revocation through each channel and time how long it takes to stop contact everywhere.
One list of 2027 compliance dates, several owners
Most of the work above falls between teams. Compliance reads the rule, operations changes the dialer, vendor management changes the contracts, and IT moves the data. The October task is naming an owner for each line and putting a dollar figure next to it.
| Date | Rule | Budget line to add in October |
|---|---|---|
| Jan 1, 2027 | NYC SHIELD | Shared contact counter and dispute routing across vendors |
| Jan 1, 2027 | Colorado SB 26-189 | Automated-tool inventory and disclosure decisions |
| Nov 25, 2026 | TCPA opt-out rule (FCC 26-67) | Cross-vendor revocation routing and contract updates |
Where TSI fits
TSI’s collections licenses and registrations cover every state that requires them, and TSI is authorized to collect in all 50 states, DC and Puerto Rico. Our ARM teams work through state and city rule changes like these for creditor portfolios every January. If you’d like to compare your list with ours, the TSI ARM team will walk through it with you. In November we’ll publish the full January 1 calendar, covering every state and local date we’re tracking for 2027. Talk with the TSI ARM team about your January plan: tsico.com/arm/contact This post is general information about regulatory changes and isn’t legal advice. Talk with your counsel about how these rules apply to your portfolio.