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
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
Here are curated AG and federal regulatory news stories highlighting key areas in which state and federal regulators’ decisions are having an impact across the US: • FTC Sues LA Fitness to Cancel Unfair Membership...more
The FTC has sued Fitness International, LLC and Fitness & Sports Clubs, LLC—the operators of “LA Fitness”—alleging that the gyms have made it extremely difficult for consumers to cancel memberships and recurring charges in...more
On August 20, 2025, the FTC filed a complaint in the U.S. District Court for the Central District of California, alleging that the Gym violated the FTC Act and the Restore Online Shoppers' Confidence Act (ROSCA). The FTC's...more
On August 12, 2025, the Federal Trade Commission announced that a large online dating company (the "Company") agreed to stop alleged unlawful practices related to advertising, cancellation, and billing. ...more
On July 29, the attorney general from Massachusetts released an updated guidance and a webinar to help businesses in Massachusetts comply with the Bay State’s consumer protection regulations prohibiting so-called “junk fees”...more
On July 8, 2025, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) “Click to Cancel” Rule....more
INTRODUCTION - On July 8, 2025, the Eighth Circuit issued its decision in Custom Communications, Inc. v. Federal Trade Commission, vacating on procedural grounds the FTC’s planned “Click-to-Cancel” rule (the “Rule”), which...more
A unanimous three-judge panel of the Eighth Circuit has vacated the Federal Trade Commission’s (FTC) final rule of amendments to the Negative Option Rule days before the rule’s scheduled July 14, 2025 effective date. The...more
A recent update to EU consumer law will require many businesses selling online to offer a simpler, more accessible way for customers to cancel contracts within the standard 14-day cooling-off period....more
On July 8, the Eighth U.S. Circuit Court of Appeals vacated the Federal Trade Commission’s (FTC) "click-to-cancel" rule (FTC Rule), which would have required companies to provide customers with an easy, one-click method to...more
I had a thought-provoking conversation this week with an in-house counsel about the now-vacated FTC “Click to Cancel” rule—a regulation that was set to take effect July 14 and could have reshaped how companies manage...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
On July 8, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s Negative Option Rule, also referred to as the “Click-to-Cancel” rule (the “Rule”), determining that the FTC...more
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
On July 8, 2025, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Click-to-Cancel Rule, resolving the challenges to the rule filed on the heels of its adoption in...more
On Tuesday July 8, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) “Negative Option” Rule, also called the “Click-to-Cancel” Rule, which expanded regulations on...more
Due to go into effect on July 14, the Negative Option Rule has been struck down by the Eighth Circuit. Our Consumer Protection/FTC Group examines the Federal Trade Commission’s options going forward....more
As has been widely reported, the Eighth Circuit issued a decision this week vacating the Federal Trade Commission’s Click-to-Cancel Rule, which had been scheduled to spring into effect on July 14. In the grand scheme of...more
On Tuesday, July 8, the Eighth Circuit struck down the Federal Trade Commission’s new “click-to-cancel” rule just days before the FTC planned to begin enforcement on July 14, 2025. ...more
On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Click to Cancel Rule (the “Rule”), which was previously scheduled to take effect on May 14, 2025, and later...more
Yesterday, the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Negative Option Rule (Click-to-Cancel Rule or Rule) that was set to go into effect on July 14....more
What happened and why? On July 8, 2025, a unanimous three-judge panel of the Eighth Circuit Court of Appeals vacated the updated version of the FTC’s Negative Option Rule (also known as the “click to cancel” rule) to have...more
On the metaphorical eve of the July 14 effective date for the FTC’s Negative Option Rule, the Eighth Circuit released an opinion Tuesday vacating the Rule in its entirety. The economy-wide notice, consent, cancellation, and...more
In October 2024, the Federal Trade Commission (“FTC”) updated its 1973 Negative Option Rule to address unfair and deceptive online subscription practices. See 16 C.F.R. § 425 (2024) (the “Negative Option Rule” or the “Rule”)....more