Consumer Finance Monitor Podcast Episode: A Look at the FTC’s Click-to-Cancel Rule, with James Kohm, Associate Director of Enforcement Division of the FTC’s Bureau of Consumer Protection
Podcast - The FTC's Click to Cancel Proposal
Autorenewals Crossover Episode with The Crypto Exchange - The Consumer Finance Podcast
Last month, HelloFresh agreed to settle an investigation by the California Automatic Renewal Task Force (“CART”) made up of several California counties and cities. CART’s lawsuit, filed contemporaneously with its agreed...more
As promised in last week’s blog that covered the Eighth Circuit’s decision to vacate the Federal Trade Commission’s (FTC) Negative Option Rule (Click-to-Cancel Rule or Rule), we are back with some practical insights on and...more
The federal government just fundamentally changed how businesses need to handle recurring subscriptions by unveiling its new “Click-to-Cancel” rule and making it mandatory to simplify cancellation processes. Designed to...more
Companies that care about avoiding Federal Trade Commission (FTC) action should take heed. Last month, the FTC announced an $8.5 million settlement with Care.com, resolving claims challenging its advertising claims and...more
It’s that time of year again. Regardless of what you call them—subscriptions, negative option programs, automatic renewals, or continuous service offers—states are continuing to enact and enforce new laws with increasingly...more
Last week, the Federal Trade Commission announced that its proposed rule replacing its Prenotification Negative Option Rule would result in new, expansive requirements for all forms of negative option offers, including...more
Retailers and service providers with US business operations should take note: the Federal Trade Commission (FTC) is increasing its scrutiny of negative option marketing activity to combat unfair or deceptive practices related...more
For years, the Federal Trade Commission has aggressively enforced the Restore Online Shoppers’ Confidence Act against digital marketers that offer Internet-based automatic renewals and subscriptions. In short, ROSCA requires...more
Subscription services face increased scrutiny from regulators, lawmakers and the plaintiffs’ bar. As we highlighted in a recent client alert, the FTC warned companies against using “dark patterns” in connection with paid...more
We’ve written about automatic renewals before, but the $10 million price tag in the FTC’s settlement with the operators of ABCmouse should grab your attention. The FTC alleged that over a three-year period, the company...more
Companies responding to the pandemic are faced with the challenges of not only complying with federal, state, and local emergency orders and guidelines for each location in which they operate, but also ensuring that any...more