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
Amendments to California’s Automatic Renewal Law (ARL) will take effect on July 1, 2025. Enacted in September 2024 through Assembly Bill No. 2863, the amendments expand disclosure, consent, and cancellation obligations for...more
The Federal Trade Commission (“FTC”) has recently announced that the FTC’s Click to Cancel Rule (the “Rule”) has been postponed to July 14, 2025. Originally planned to become effective May 14, 2025, the Commission released...more
Companies with recurring payment programs with negative option terms now have until July 14, 2025, to bring their disclosure, consent, and cancellation practices into full compliance....more
Federal officials just postponed enforcement of the Click-to-Cancel rule, which requires businesses offering subscriptions or memberships to provide a cancellation process as straightforward as the sign-up procedure. The...more
Our Consumer Protection/FTC Team notes that the Federal Trade Commission extended the compliance deadline of the Negative Option Rule (better known as the Click-to-Cancel Rule) by 60 days....more
Are you a contractor who sells services directly to customers at their homes or outside your ordinary place of business? If so, do you know about Ohio’s Home Solicitation Sales Act? Understanding this law is crucial, and if...more
Every company will be impacted by the new import tariffs, as they increase manufacturing costs. However, companies selling on an autorenewal basis could disproportionately feel the impact and should proceed with caution...more
In two recent decisions, the German Higher Regional Courts (Oberlandesgerichte – OLG) of Cologne and Munich have clarified the – strict – German requirements for cancellation buttons on websites of tech companies providing...more
The Federal Trade Commission (FTC) recently finalized and issued a new rule governing negative option features, like subscription or membership agreements with automatic renewal and recurring payment options. The rule,...more
In our last update on the Digital Markets Competition and Consumer Act (DMCC Act), we outlined some of the key consumer protection enhancements set to come into force in the UK. In particular, the DMCC Act sets out new rules...more
This week, California amended its automatic renewal and continuous service offer law (ARL). Key provisions include the addition of “free-to-pay conversions,” consent obligations, misrepresentation prohibitions, request for...more
Now that independent schools are well into the 2024-2025 school year, independent schools are turning their attention toward enrollment and re-enrollment season for the 2025-2026 school year. ...more
Automatic renewals continue to be a big priority for state regulators. When companies work to develop strategies to comply with the growing patchwork of specific state laws in this area, they often start by looking at...more
The Digital Markets, Competition and Consumers Act 2024 (DMCCA) has recently received royal assent, following the announcement of the July General Election. We examine the key developments in our previous article. One very...more
During the last several years, many states have adopted automatic renewal contract, or ARC, laws for the protection of consumers, driven in large part by new subscription-based contracts sold in digital distribution 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
Recently, the State of New York enacted SB 5941-B (the “Act”), which revises the general business law, focusing on the obligation of businesses to inform consumers about an impending automatic renewal or continuous service...more
Earlier this week, we posted that a plaintiff filed a proposed class action against the NFL over its automatic renewal practices. The complaint alleges that the NFL used “dark patterns” to enroll consumers in its NFL+...more
Last week, a plaintiff filed a proposed class action against the NFL over its automatic renewal practices. The plaintiff alleges that the company used deceptive practices to automatically subscribe its Game Pass users to a...more
Amendments to California’s automatic renewal law (ARL) enacted in October 2021 go into effect today, July 1, 2022. The amendments add enhanced procedural requirements related to the cancellation of subscription-based products...more
Subscription service providers should be aware of the various changes coming to California's automatic renewal law. California’s already stringent laws governing recurring subscription programs are about to become even more...more
The first half of 2022 saw significant activity affecting the state automatic renewal laws (ARLs) that regulate continuing or renewing contracts: • Lawsuits were filed against prominent companies such as Amazon and...more
Businesses with automatic renewal contracts—including subscriptions—should take note of Colorado’s new law that went into effect earlier this year on January 1, 2022. While companies subject to other state’s auto-renewal...more
In several recent posts and a webinar, we’ve talked about how the FTC and state AGs are focusing on automatic renewals. A series of new laws and investigations show that this continues to be a hot topic for both lawmakers and...more
Colorado and Delaware have enacted new laws for automatic renewal or negative options offers. The new laws became effective January 1, 2022. Illinois already has a law on the books related to automatic renewals but has...more