Just days before the “Click to Cancel” negative option rule was to go into effect, the Eight Circuit Court of Appeals vacated the rule in its entirety. As explained in our previous alert, the rule, which would have gone into...more
7/11/2025
/ Appeals ,
Automatic Renewals ,
Compliance ,
Consumer Protection Act ,
Consumer Protection Laws ,
Disclosure Requirements ,
Federal Trade Commission (FTC) ,
FTC Act ,
Rulemaking Process ,
Unfair or Deceptive Trade Practices ,
Vacated
The Federal Communications Commission is enhancing its Robocall Mitigation Database (RMD) compliance obligations and increasing base forfeiture amounts for RMD violations. The FCC’s new rules follow a recent Enforcement...more
1/17/2025
/ Compliance ,
Data Collection ,
Data Privacy ,
Enforcement Actions ,
FCC ,
Fees ,
Filing Deadlines ,
Fines ,
New Rules ,
OMB ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Mitigation ,
Robocalling ,
Telecommunications
On December 26, 2024, the Fifth Circuit reinstated a stay of the Corporate Transparency Act’s requirement that businesses must file Beneficial Ownership Information reports. Accordingly, there is at present no obligation to...more
1/3/2025
/ Appeals ,
Beneficial Owner ,
Compliance ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Filing Deadlines ,
FinCEN ,
Preliminary Injunctions ,
Reporting Requirements ,
SCOTUS ,
Stays
Subscription-based services are a lynchpin of the services industry and the current focus of the Federal Trade Commission’s (FTC) new “click to cancel” rule. Responding to customer complaints focusing on the difficulty of...more
The FCC has released new rules that expand caller ID authentication requirements, impose enhanced robocall mitigation obligations, create new mechanisms to hold providers accountable for non-compliance, and set forth the...more
4/19/2023
/ Authentication ,
Compliance ,
Enforcement ,
FCC ,
Filing Deadlines ,
Infrastructure ,
Mitigation ,
New Rules ,
Noncompliance ,
Notice of Proposed Rulemaking (NOPR) ,
Penalties ,
Robocalling
The recently-signed Oklahoma Telephone Solicitation Act of 2022 (OTSA) will become effective November 1, 2022. The OTSA, like the federal Telephone Consumer Protection Act (TCPA), and the Florida Telephone Solicitation Act...more