Junk Fees

Online comments: 18

• Efstathios Georgiou

  I support DCWP’s proposed junk fee rule (§5-16). Hidden fees cost NYC families an estimated $3,200/year, and this rule is a needed step toward transparent pricing. I urge DCWP to: (1) strictly enforce the “mandatory fee” definition so businesses can’t disguise expected charges as “optional”; (2) apply total-price disclosure equally to third-party platforms and apps, not just company websites; (3) consider raising penalty amounts to deter high-volume businesses; and (4) keep the recordkeeping/burden-shifting provision, which is essential for real enforcement. Thank you for protecting consumers from hidden fees.

  —

  Comment added July 9, 2026 10:29am

• Jacob Quinn

  Love this, companies love to nickel and dime their customers nowadays. Any laws and protections from that I say Amen!

  Comment added July 9, 2026 6:16pm

• Anonymous

  As an NYC resident, consumer, and renter, I fully support DCWP’s efforts to prohibit junk fees. It’s increasingly common for renters to encounter mandatory amenity fees, unavoidable utility sub-metering fees, and even electronic ACH payment convenience fees that are not factored into the headline monthly rent figure (even if separately disclosed later) and thus discourage proper consumer price comparison against total monthly rent.
  Similarly, internet service providers service NYC will often tease a promo monthly rate for new customers, but then add a substantial installation fee at check-out to be able to continue. Much of these practices are the equivalent of a modern-day bait and switch.
  The proposed rules will hopefully put an end to these practices across all forms of applicable advertising in NYC. I will join other commenter(s) in suggesting that DCWP raise the proposed fines for Second/Third violations/defaults in pursuit of an appropriately effective deterrent effect.

  Comment added July 14, 2026 10:07am

• S

  Great idea and should definitely include bills from utilities and phone service, especially Verizon.

  Comment added July 15, 2026 12:24pm

• Anonymous

  I respectfully request clarification regarding the scope of the proposed rule. Specifically, it is unclear whether the rule is intended to apply solely to transactions for the purchase of consumer goods or services or whether it also extends to business-to-business advertising and marketing involving goods and services that are not purchased primarily for personal, household, or family use.

  As drafted, the proposal broadly refers to the advertising, display, and offering of goods and services, but it does not expressly distinguish between consumer and commercial transactions. This creates uncertainty for businesses that advertise or market products and services exclusively to other businesses.

  If the Department intends the rule to apply only to consumer transactions, I encourage it to expressly state that limitation in the final rule. Conversely, if the Department intends the rule to reach business-to-business transactions, additional guidance regarding the scope and application of the rule to commercial transactions would be helpful.

  Thank you.

  Comment added July 17, 2026 9:36pm

• National Consumer Law Center

  Attached please find the comments of the National Consumer Law Center, which focus on rental housing junk fees.

  Comment attachment
  National-Consumer-Law-Center_-Comments-re-NYCDWP-Proposed-Rule-Prohibiting-Charging-Consumers-Hidden-Junk-Fees.pdf

  Comment added July 28, 2026 9:13am

• Gloria Lisa Baksh

  I support the enactment and enforcement of rules that prohibit charging consumers hidden “junk fees.” The most vulnerable people are elderly and immigrant consumers. They need the support of The Department of Consumer and Worker Protection, and I encourage elected officials to review and ensure the enactment of a strong and effective proposal.

  Comment added July 29, 2026 10:29am

• New York State Office of the Attorney General

  See Attachment.

  Comment attachment
  Comment-Letter-on-DCWP-Proposed-Junk-Fees-Rule.pdf

  Comment added August 3, 2026 12:21pm

• Yosep Blake Bak - NYS PE 107881

  COMMENT ON PROPOSED RULE – RULES REGARDING JUNK FEES

  To: New York City Department of Consumer and Worker Protection
  Rule: Proposed 6 RCNY § 5-16 (General Fee Disclosures) and amendment to 6 RCNY § 6-47
  Reference: 2026 RG 027 / DCWP-75
  Comment deadline: August 7, 2026
  Submitted by: Yosep Blake Bak, P.E. – New York State Professional Engineer, License No. 107881
  Capacity: Individual. No client interest is held in any matter addressed in this comment.

  SUMMARY

  I support the proposed rule. I write to propose four amendments, each directed at a category of mandatory charge that the rule as drafted may not reach:

  1. Format lock-in. A fee charged to obtain, open, export, or transfer a digital deliverable the consumer has already purchased is a mandatory fee that is not reasonably avoidable, and the format of a deliverable should be disclosed before the consumer consents to pay.

  2. The governmental-charge carve-out. A charge represented as a tax or government fee should have to be identified and matched to the amount actually imposed.

  3. Substantiation. Subdivision (f) correctly identifies a substantiable basis as the test of a legitimate fee, but makes it evidentiary only. It should be operative.

  4. Scope. The final Statement of Basis and Purpose should confirm that professional design, inspection, and compliance services advertised to New York City consumers are “services” under subdivision (b).

  Disclaimer. This comment alleges no wrongdoing by any person or firm. Where a question is open, it is identified as open rather than asserted as a finding. Nothing in Part VI is a request that the Department take action outside its jurisdiction; it is offered solely to establish the basis of the commenter’s knowledge.

  I. THE RULE’S CORE STRUCTURE IS SOUND

  The proposed rule correctly locates the harm. A fee is a junk fee when the consumer cannot see it in time to act on it. Subdivisions (c) and (d) address that directly, and the prominence requirement – that the total price be disclosed at least as prominently as any other pricing information – is the operative mechanism that makes disclosure meaningful rather than nominal.

  I note one framing point that motivates the amendments below. Subdivision (f) requires records sufficient to establish the basis of any fee, including its nature, purpose, amount, and refundability. That is the correct engineering test: a charge is legitimate when it corresponds to something the person can document. The Department has identified the right standard. As drafted, however, it operates only after the Department has alleged a material fact in a proceeding. Comment 3 addresses this.

  II. COMMENT 1 – FORMAT LOCK-IN AS A MANDATORY FEE THAT IS NOT REASONABLY AVOIDABLE

  Current proposed language. Section 5-16(a) defines “mandatory fees and charges” to include fees not reasonably avoidable by the consumer, and separate fees for aspects of a good or service a reasonable person would expect to be included.

  Objective issue. A common and growing pattern is not clearly captured. A consumer purchases a good or service whose deliverable is digital. The deliverable is released only inside a proprietary container – a vendor portal, a viewer application, a subscription, or an encumbered file format. A further payment is then required to obtain the file in a form the consumer can open, keep, or give to someone else.

  The consumer has paid for the work. The second charge buys access to what they already own. It is not reasonably avoidable, because refusing it means forfeiting the deliverable, and it is for an aspect of the good a reasonable person would expect to be included – nobody buying a document expects to buy the ability to read it separately.

  The pattern is industry-neutral, which fits the Department’s stated approach. Examples include: photography and videography where original files carry a separate charge; home, roof, and structural inspection reports delivered through a vendor portal; dental and medical imaging; personal fitness, sleep, and health data; tax preparation where the prior-year return is gated; residential design and renovation deliverables provided to homeowners; three-dimensional scans of a property; and stored security-camera footage.

  The reason this is a disclosure problem rather than a technical one is that open, published, royalty-free alternatives are already established in every one of these domains. The consumer is not being asked to pay for a capability that does not otherwise exist. Established open standards include, without limitation:

  – Building and product geometry: ISO 16739-1 (IFC), IFCx, BCF, IDS
  – Three-dimensional scan and point cloud data: ASTM E2807 (E57); ASPRS LAS/LAZ
  – Building energy models: gbXML; EnergyPlus IDF; OpenStudio OSM
  – Simulation validation and equipment performance: ANSI/ASHRAE Standard 140; ASHRAE Standard 205
  – Thermal analysis: ISO 6946; ISO 10211; ISO 14683
  – Medical imaging: DICOM (ISO 12052)
  – Archival documents: PDF/A (ISO 19005), including PDF/A-3, which permits the native source file to be embedded inside the delivered PDF
  – Tabular and structured data: CSV; JSON; XML

  Proposed text amendment. Amend the definition of “Mandatory fees and charges” in § 5-16(a) by adding at the end:

  “Mandatory fees and charges further include any fee charged for the delivery, access, retrieval, export, or continued availability of a record, file, image set, model, or data set that the consumer has already purchased, where payment of that fee is a condition of obtaining the item in a format the consumer can open, retain, or transfer without purchasing a separate license, subscription, or application sold or controlled by the person or an affiliate of the person.”

  Proposed text amendment. Add a new paragraph (3) to § 5-16(d):

  “(3) Where a good or service is delivered in whole or in part as a digital file, record, image set, model, or data set, the person must disclose: (i) each file format in which the deliverable will be provided; (ii) whether opening, retaining, or transferring the deliverable requires a license, subscription, or application sold or controlled by the person or an affiliate of the person; and (iii) the price of any such license or subscription.”

  Technical rationale. Disclosing a delivery format costs nothing. It is a single line in an offer. The consumer needs it before consenting to pay, because after payment the leverage has moved: the work is done, the file exists, and the only remaining question is what it costs to hold it.

  Producing an open-format deliverable also costs nothing in the ordinary case. A flattened PDF and a PDF/A-3 containing the same content with the native source file embedded are produced by the same export operation, at the same price, in the same amount of time. Where a person nonetheless charges for the open-format version, subdivision (f) requires them to be able to say what that charge is for. That is the correct outcome. The amendment does not prohibit proprietary formats, mandate any particular standard, or require any person to change what they sell. It requires only that the consumer be told the format before paying, and that a charge to escape that format be counted in the total price.

  I would note that the City has already adopted this principle for its own data. The Open Data Law requires City data sets to be published in machine-readable, non-proprietary formats. The proposed amendment extends to consumers a norm the City applies to itself.

  III. COMMENT 2 – CHARGES REPRESENTED AS TAXES OR GOVERNMENTAL FEES

  Current proposed language. Section 5-16(a) defines “total price” to exclude taxes and fees imposed by a government.

  Objective issue. The exclusion is appropriate, but nothing in the rule requires a person invoking it to show that the excluded charge is in fact governmental, or that it matches the amount a government actually imposed. As drafted, a person may exclude from the total price a charge labeled “permit fee,” “filing fee,” “regulatory recovery fee,” or “compliance fee” without identifying the government imposing it or the amount imposed. A markup embedded in such a line item is invisible to the consumer and is excluded from the very figure the rule is designed to make visible.

  This matters in the trades and professional services a New York City homeowner, cooperative, or condominium board retains. Governmental filing fees, professional service, and administrative markup are routinely presented as a single line item. The consumer cannot tell which portion the City receives and which the vendor retains.

  Proposed text amendment. Add a new paragraph to § 5-16(d):

  “Where any charge or fee excluded from the total price is represented, expressly or by implication, as a tax or as a fee imposed by a government, the person must disclose the governmental authority imposing the charge, the statute, rule, or published fee schedule under which it is imposed, and the exact amount so imposed. Any portion of such a charge that exceeds the amount actually imposed by a government, or that is not imposed by a government, is a mandatory fee and must be included in the total price.”

  Technical rationale. Every governmental fee has a published schedule and a citation. A person charging it can identify it. A person who cannot identify it is not passing through a governmental charge. The amendment closes the exclusion to exactly the amount the government receives and no more, which is the exclusion’s purpose.

  IV. COMMENT 3 – SUBSTANTIATION SHOULD BE OPERATIVE, NOT ONLY EVIDENTIARY

  Current proposed language. Section 5-16(f)(1) requires records sufficient to establish the basis of a fee. Section 5-16(f)(2) provides that failure to maintain, retain, or produce such a record, where relevant to a material fact alleged by the Department, creates a presumption that the fact is true.

  Objective issue. The presumption is a sound enforcement tool, but it operates only once the Department has already commenced a proceeding and alleged a material fact. A person may therefore impose a fee they cannot substantiate, and be in compliance with the rule, until the Department opens a case. The recordkeeping duty in (f)(1) has no independent consequence.

  Proposed text amendment. Add to § 5-16(e):

  “It is a deceptive and unconscionable trade practice for any person to impose a fee or charge described by a name, purpose, or basis that the person cannot substantiate from the records required to be maintained under subdivision (f) of this section.”

  Technical rationale. The Department’s own reasoning supports this. The proposed rule explains that recordkeeping will prevent a “service fee” that does not support service workers, or a “processing fee” unrelated to processing costs. That harm occurs when the fee is charged, not when the Department later alleges it. Making substantiation operative aligns the duty with the injury, and it costs a person nothing who is already complying with (f)(1).

  V. COMMENT 4 – CONFIRMATION OF SCOPE AS TO PROFESSIONAL SERVICES

  Requested action. I ask that the final Statement of Basis and Purpose confirm expressly that professional design, inspection, and regulatory-compliance services offered or advertised in New York City, or to a New York City consumer, are “services” within § 5-16(b).

  Technical rationale. Cooperative and condominium boards, small building owners, and homeowners retain registered design professionals, inspectors, and filing representatives directly. These engagements exhibit the fee patterns the rule targets: pass-through line items of uncertain origin, digital deliverables released only through a vendor platform, and charges for a further copy of a report the consumer has already paid for. An express confirmation would remove any argument that professional services fall outside a consumer protection rule, and would give the Department’s enforcement staff a clear answer to a question that will otherwise be raised.

  VI. BASIS OF THE COMMENTER’S KNOWLEDGE

  I am a New York State licensed professional engineer. I prepare and seal design and compliance documentation filed under the New York City Construction Codes and the New York City Energy Conservation Code, and I have submitted technical comments in two open Department of Buildings rulemakings during 2026.

  I offer two observations from that practice, solely to establish that the patterns described above are not hypothetical. I am not asking this Department to act on either. Neither falls within its jurisdiction, and both are being pursued in their proper venues.

  Single-implementation dependence. A rule now open for comment would establish a compliance pathway requiring the use of a specific category of jurisdiction-specific simulation software approved by a building official. That metric exists today in one implementation. There is no competitive market of engines for it. When a regulation or a contract requires a deliverable that only one product can produce, the price of that product is not disciplined by anything, and every party downstream – including the ultimate consumer paying for the filing – absorbs it. Whether that dependence is justified is a question that can only be answered if the acceptance criteria are published. That is the same disclosure logic this proposed rule applies to fees.

  Absence of a published cost basis. A separate proposed fee, on which I have submitted a cost analysis, would charge licensed professionals an annual amount for a credential whose infrastructure cost, on any generous estimate, rounds to zero, and whose renewal check is a query against a State database that already exists at no cost. No itemized cost basis has been published. I raise it here only because it is the clearest illustration I have of the principle in subdivision (f): a charge is defensible when its basis is documented and available, and indefensible when it is not, and that proposition does not depend on who is charging.

  The Department has, in this rule, articulated that principle better than any City instrument I have read. My comments above are directed at making it operate as far as the Department’s authority reaches.

  VII. REQUESTS

  1. Adopt the four amendments proposed in Parts II through V, or state in the final Statement of Basis and Purpose why each category of charge is already reached by the rule as drafted.

  2. If the Department concludes that format lock-in is already captured by the existing definition of mandatory fees, state that expressly, so the conclusion is available to consumers, businesses, and enforcement staff.

  3. Confirm where the public record of written comments required by Charter § 1043(e) for this rulemaking is maintained, and how a member of the public may inspect it.

  I appreciate the Department’s work on this rule and would be glad to provide further technical detail on any of the standards referenced in Part II.

  Respectfully submitted,

  Yosep Blake Bak, P.E.
  New York State Professional Engineer, License No. 107881

  Comment added August 3, 2026 4:42pm

• Anonymous

  This is absurd. The text of the bill does ABSOLUTELY NOTHING to prohibit or even limit junk fees.

  It only requires the ‘total price’ upfront, instead of at purchase. As if knowing the fees exist upfront instead of seeing them at checkout makes any difference. The junk fees still exist.

  It’s deceptive how this rule is being advertised.

  “The proposed rule addresses junk fees by making it a deceptive trade practice to offer, display or advertise the price of a good or service without clearly and conspicuously posting the total price, meaning the price
  including all mandatory charges and fees.”

  “This “all in” pricing requirement applies to any price for a good or service that is offered, advertised, or
  displayed, whether it is a fixed price for an item or service, or tied to a variable like an hourly rate or service based on a unit of measurement. Anywhere a person, meaning an individual or business, chooses to advertise, offer, or display a specific price, that advertisement, offer, or display must include a disclosure
  of the total price”

  Comment added August 3, 2026 7:20pm

• Eric Fruits & Brian Albrecht

  We submit these comments to the Department of Consumer and Worker Protection’s proposed rule relating to “junk fees.” The attached letter explains four reasons why the Proposed Rule, as drafted, will impose costs on New York City businesses and consumers that far outweigh any transparency it provides.

  Comment attachment
  ICLE-Comments-to-NYC-DCWP-re-Junk-Fees-2026.pdf

  Comment added August 4, 2026 3:33pm

• Laura Chadwick

  August 7, 2026

  Submitted via email to [email protected] and via http://rules.cityofnewyork.us

  New York City Department of Consumer and Worker Protection
  42 Broadway New York, NY 10004

  Re: Comments on Proposed Rule, “Rules Regarding Junk Fees,” 6 RCNY § 5-16 (Reference Nos. 2026 RG 027 / DCWP-75)

  Dear Commissioner:

  Travel Tech Association (Travel Tech) submits these comments on the Department’s proposed rule adding Section 5-16 to Title 6 of the Rules of the City of New York.

  Travel Tech Association is a nonprofit membership organization and the unified voice for the travel technology ecosystem. Travel Tech represents the leading innovators in travel technology, including online travel agencies (OTAs), metasearch engines, short-term rental platforms, Global Distribution Systems, Travel Management Companies, and early-stage travel tech startups. Our members connect millions of consumers to travel options around the world and play a critical role in fostering competition, transparency, and consumer choice in the travel marketplace.

  Travel Tech shares the Department’s goal of protecting consumers from hidden fees, and our members support clear, all-in pricing. Companies already display total prices in compliance with the Federal Trade Commission’s Rule on Unfair or Deceptive Fees (16 C.F.R. Part 464), which took effect on May 12, 2025, and covers short-term lodging and live-event tickets. Adopted in a bipartisan vote, that rule defines the “total price” a business must disclose as “the maximum total of all fees or charges a consumer must pay for any good[s] or service[s] and any mandatory ancillary good or service, except that government charges, shipping charges, and fees or charges for any optional ancillary good or service may be excluded.” The Department’s proposed Section 5-16 defines “total price” in nearly identical terms.

  Because the proposed rule so closely tracks the federal standard our members already meet, we first recommend a straightforward way to align the two and avoid a conflicting local requirement, as set out in Section I below. We do not write to defend hidden fees. We write in support of consistency and to highlight two provisions of the proposed rule that, as drafted, would reach far beyond New York City, shift the burden of proof onto businesses in a manner that raises serious fairness concerns, and fall especially hard on the intermediary platforms that display prices set by third parties. We respectfully urge the Department to revise the rule as described below.

  I. The Department Should Provide a Safe Harbor for Pricing That Complies with the Federal Standard

  Because the Federal Trade Commission’s rule already governs all-in price display for short-term lodging and live-event tickets, and our members already comply with it, the most direct way for the Department to achieve consistent, transparent pricing without creating a conflicting local standard is to deem federally compliant pricing compliant with Section 5-16. A safe harbor of this kind would give New York City consumers the same protection they already receive under the federal rule, while sparing businesses the burden and confusion of maintaining a separate, City-specific display standard for the same transactions. We respectfully recommend that the Department add the following provision to Section 5-16:

  “An offer, display, or advertisement for short-term lodging, including temporary sleeping accommodations at a hotel, motel, inn, short-term rental, or vacation rental, or for live-event tickets, that complies with Part 464 of Chapter I of Title 16 of the Code of Federal Regulations shall be deemed in compliance with this section.”

  II. The Geographic Scope in Section 5-16(b) Reaches Far Beyond New York City and Should Be Narrowed to Transactions with a Genuine City Nexus

  Section 5-16(b) applies the rule to “any person who offers, displays or advertises goods or services in New York City, or to a New York City consumer.” The phrase “or to a New York City consumer” extends the rule to any business, anywhere in the country or the world, that advertises to a resident of New York City, regardless of whether that business has any physical presence, transactional nexus, or other connection to the City.

  For the travel industry, this scope is unworkable. Travel is inherently interstate and international. A national or global travel platform serves users everywhere, and a resident of New York City may search for a hotel in Miami, a rental car in Denver, or a flight to London. Under the proposed language, every one of those advertisements would be subject to a New York City rule, even though the transaction, the supplier, and the good or service have no connection to the City. Businesses cannot reliably identify which of their users are “New York City consumers” when a price is displayed, and they cannot practically maintain a separate New York City price-display standard for those users alone. The realistic effect is that a single City agency’s rule would govern pricing displays worldwide. This is precisely with we advocated for a federal rule on this matter.

  This scope is broader than the very laws the Department cites as models. California’s SB 478, the Massachusetts junk-fee regulations, and Minnesota’s price-transparency law apply to businesses doing business within those states. The Department’s own longstanding practice, and the statutes it cites as authority, likewise govern sales and advertising within the City. Extending this rule to any advertisement seen by a City resident anywhere is a departure from that practice that also raises constitutional concerns under the dormant Commerce Clause regarding a municipality’s regulation of wholly out-of-jurisdiction commerce.

  Recommendation: The Department should strike “or to a New York City consumer” or revise Section 5-16(b) to apply only to offers, displays, and advertisements with a genuine New York City nexus, such as transactions for goods or services to be provided or delivered in the City, or advertisements directed at consumers physically located in the City. This would achieve the Department’s consumer protection purpose within the City while remaining consistent with the state models the rule cites and with the Department’s existing authority.
   

  III. The Recordkeeping Requirement and Adverse Presumption in Section 5-16(f) Shift the Burden of Proof and Fall Unfairly on Platforms Displaying Third-Party Prices

  Section 5-16(f)(1) requires any covered person to maintain records “sufficient to establish the basis, including the nature, purpose, amount or refundability” of any fee or charge in a covered advertisement or fee breakdown. Section 5-16(f)(2) then provides that a failure to maintain, retain, or produce such a record relevant to a material fact alleged by the Department “creates a presumption that such fact is true.”

  This burden-shifting presumption raises two serious concerns:

  First, it reverses the ordinary burden of proof. Under Section 5-16(f)(2), the Department may allege a violation, and if a business cannot produce records the Department deems sufficient, the Department’s allegation is presumed true. Combined with the absence of any cure period, which the accompanying certification expressly declines to provide, and escalating per-violation penalties, this structure exposes businesses to liability based not on a demonstrated deceptive practice but on a documentation gap. This raises due process concerns. A business acting in good faith should not be presumed to have violated the law because it did not retain a particular record in the form the Department later requests. The recordkeeping obligation itself is also open-ended: “records sufficient to establish the basis” of every fee gives businesses no clear standard for what must be kept or for how long. There is also no provision for a situation where records are destroyed through no fault of the business, such as by a cyberattack.

  Second, and of particular concern for our members, the provision falls hardest on intermediary platforms that display prices and fees set by third-party suppliers. When an online travel platform displays a hotel’s rate, including a mandatory fee the hotel has set, the platform is passing through pricing established by the supplier. The platform does not set that fee and often has no visibility into its “nature, purpose, amount or refundability,” which is information within the hotel’s control, not the platform’s. Under Section 5-16(f), if the Department alleges that a supplier-set fee was improperly excluded or characterized, and the platform cannot produce records establishing the basis of a fee it did not create, the Department’s allegation would be presumed true against the platform. That holds intermediaries responsible for information they cannot access and for pricing decisions they did not make.

  Recommendation: The Department should remove the adverse presumption in Section 5-16(f)(2). If the Department retains a recordkeeping requirement, it should (1) define with specificity what records are required and for how long, (2) provide a reasonable cure period before penalties attach, and (3) expressly account for intermediaries by limiting a platform’s recordkeeping obligation to the pricing information the platform itself sets or controls, rather than fees established by third-party suppliers.

  IV. Conclusion

  Travel Tech supports transparent, all-in pricing, and our members already provide it under the federal lodging rule. We urge the Department to narrow the geographic scope of Section 5-16(b) to transactions with a genuine New York City connection, to remove the adverse presumption in Section 5-16(f)(2) and clarify the associated recordkeeping obligation, and to provide a safe harbor deeming federally compliant pricing compliant with the rule. These changes would allow the Department to achieve its consumer-protection goals without imposing an unworkable global standard or an unfair burden of proof on businesses acting in good faith.

  We appreciate the opportunity to comment and welcome the chance to serve as a resource to the Department as it finalizes this rule.

  Thank you for your consideration.

  Sincerely,

  Laura Chadwick
  President & CEO
  Travel Tech Association
  http://www.traveltech.org

  Comment attachment
  8.7.26-NYC-Rules-Regarding-Junk-Fees-Travel-Tech-Comments.pdf

  Comment added August 6, 2026 2:50pm

• Leo Mann

  I spent thirty years writing the fine print this rule is trying to fix. Terms of service, fee schedules, the “and other charges as applicable” that turns a $29 advertised price into a $47 surprise. I know exactly where the bodies are buried, because I helped bury a few.

  So take this as a friendly note from a reformed insider: I’m for this rule. Strongly. But disclosure alone won’t do it. The industry’s answer to every disclosure mandate is the same — bury the number in a hyperlink, in eight-point type, three screens down, and call it “disclosed.” Technically compliant, completely useless.

  My attached comment lays out three fixes that close the loopholes I’d have used myself: stop companies from quietly amending fee schedules after you’re locked in, capture the fees hiding in documents “incorporated by reference,” and require one all-in number shown as loudly as the advertised price — at the moment of decision, not the moment of checkout.

  One last thing, free of charge: a right nobody understands protects nobody. This rule is enforced by complaint, which means it only works for New Yorkers who know what to look for. Teaching them that part is the work I do now, and I’d do it for the City for nothing like I do for several other major US cities. Email me.

  Respectfully,
  Leo Mann — #1 best-selling author of Don’t Sign That, Founder of The Contract Literacy Movement (www.contractliteracy.com)

  Comment attachment
  Junk-Fees-Public-Comment-Leo-Mann.pdf

  Comment added August 6, 2026 3:19pm

• Zillow Group

  Attached please find the written comments of Zillow Group on the DCWP’s proposed “junk fee” rules. Thank you.

  Comment attachment
  DCWP-Junk-Fee-Rulemaking-Comment-August-2026.pdf

  Comment added August 6, 2026 4:20pm

• Laura C. Dismore

  The attached comment letter is submitted on behalf of Protect Borrowers, a non-profit organization comprising experts, lawyers, and advocates fighting to build an economy where debt doesn’t limit opportunity.

  Comment attachment
  26.8.9-DCWP-Junk-Fees-Comment-Letter-Protect-Borrowers.pdf

  Comment added August 7, 2026 8:48am

• Anonymous

  On behalf of the Chamber of Progress, please find our comments on DCWP’s proposed junk fee rules.

  Comment attachment
  NYC_-DCWP-Proposed-Junk-Fee-Rules-Comments.pdf

  Comment added August 7, 2026 9:13am

• Ian P. Moloney

  Please find comments below

  Comment attachment
  American-Fintech-Council-Response-to-NYC-DCWP-Junk-Fees.pdf

  Comment added August 7, 2026 5:47pm

• Health and Fitness Association

  See attached.

  Comment attachment
  08.07.26-HFA-Comments-Proposed-Rules-Regarding-Junk-Fees.pdf

  Comment added August 7, 2026 6:46pm