Just days before it was scheduled to take effect, the Federal Trade Commission’s (FTC) amended Negative Option Rule, commonly known as the “Click-to-Cancel” Rule (Rule), was vacated by the US Court of Appeals for the Eighth...more
7/15/2025
/ Administrative Procedure Act ,
Appeals ,
Cancellation Rights ,
Consumer Protection Laws ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Loper Bright Enterprises v Raimondo ,
Rulemaking Process ,
Statutory Interpretation ,
Subscription Services ,
Unfair or Deceptive Trade Practices
Consistent with President Trump’s de-regulatory agenda, the Consumer Financial Protection Bureau (CFPB or Bureau) is withdrawing over five dozen of its guidance documents, including interpretive rules, advisory opinions, and...more
On October 16, 2024, and by a 3-2 vote of its commissioners, the Federal Trade Commission (FTC) issued a broad-reaching final “click to cancel” rule (Rule), updating its Negative Option Rule, that could subject companies to...more