With regulators, lawmakers, and consumers increasingly focused on pricing transparency, understanding the legal treatment of surcharges, "junk fees," and disclosure practices is more important than ever. Recent federal and...more
7/25/2025
/ Advertising ,
California ,
Continuing Legal Education ,
Disclosure Requirements ,
E-Commerce ,
Fees ,
New York ,
Point of Sale Terminals ,
Price Transparency ,
Pricing ,
Surcharges ,
UDAP ,
Unfair or Deceptive Trade Practices ,
Webinars
On July 1, California's amended autorenewal law takes effect, and the Federal Trade Commission's (FTC) updated enforcement deadline for the primary requirements of the updated Negative Option Rule (so-called Click to Cancel...more
Ending speculation and uncertainty about whether new leadership at the Federal Trade Commission (FTC) would repeal or continue to defend the agency’s Negative Option Rule, which regulates offerings such as autorenewal of...more
3/21/2025
/ Auto-Renewal ,
Consumer Protection Laws ,
Disclosure Requirements ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
FTC Act ,
Negative Option Rule ,
Regulatory Requirements ,
Rulemaking Process ,
Subscription Services ,
Unfair or Deceptive Trade Practices
As political tides shift, so too does the regulatory outlook for consumer financial services. Among the key documents that could shape the direction of U.S. financial regulation is a January 2021 report by the CFPB Taskforce...more
This week, the Federal Trade Commission (FTC) issued its long-awaited Final Rule on Unfair or Deceptive Fees. When the FTC released the proposed rule over a year ago, the rule covered any business that offered goods or...more
On September 18, the CFPB issued a set of Frequently Asked Questions (FAQs) related to Buy Now, Pay Later (BNPL) products. These FAQs follow the CFPB's release of the 2024 BNPL Interpretive Rule (Interpretive Rule), which...more
This week, the Federal Trade Commission (FTC) released a Proposed Rule, “Rule on Unfair or Deceptive Fees.” The Proposed Rule comes after the FTC solicited comments through its Advance Notice of Proposed Rulemaking in...more
10/12/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Brick-and-Mortar Stores ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
E-Commerce ,
Fees ,
Goods or Services ,
Governor Newsom ,
New Legislation ,
Proposed Rules ,
Public Comment
The law surrounding negative option and continuity programs continues to evolve rapidly. Feeling a bit overwhelmed with the latest developments? Below is what you need to know in light of new laws, new enforcement actions,...more
1/19/2023
/ Automatic Renewals ,
Consent ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Enforcement Actions ,
Enforcement Guidance ,
Federal Trade Commission (FTC) ,
Fees ,
GrubHub ,
New Legislation ,
ROSCA ,
Settlement ,
State Attorneys General ,
Subscription Services ,
Terms of Service ,
Website Design
The California Office of Administrative Law (OAL) has approved the California Department of Financial Protection and Innovation's (DFPI) final regulations, which require providers of commercial financing, including nonbank...more
On July 1, new requirements under California's automatic renewal will take effect. As we previously blogged, the amendments will require businesses to make it even easier for consumers to cancel and impose new requirements on...more