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
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 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
The Federal Trade Commission, state attorneys general, and class action plaintiffs continue to scrutinize negative option and continuity offers, including automatic renewals, free-to-pay conversions, and continuity programs....more
This week, the Federal Trade Commission (FTC) and the Illinois attorney general announced a settlement with Grubhub Inc. to resolve allegations that the company engaged in an array of unfair and deceptive practices that...more
Many alerts and articles discussing the Federal Trade Commission's (FTC) updated Negative Option Rule and the Amendments to California's Automatic Renewal law have focused on the stricter consent and cancellation...more
On October 16, 2024, the Federal Trade Commission (FTC) finalized significant updates to the Negative Option Rule. The amendments to the rule, now titled the “Rule Concerning Recurring Subscriptions and Other Negative Option...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
Blurred Lines: NAD Says Supplement Company Must Add Conspicuous Disclosures When Editorial Content Is Advertising - Once again, the National Advertising Division has examined the increasingly blurry line between...more
The Federal Trade Commission (FTC) recently announced a notice of proposed rulemaking to expand its “Negative Option Rule” to apply to all recurring subscription programs (Proposed Amendment). The Proposed Amendment would...more
Mornings for advertising lawyers usually start slow – coffee in one hand and phone in the other while we glance at emails. Imagine our surprise the other morning when we saw that the Federal Trade Commission (FTC) had issued...more
In a recent report entitled Bringing Dark Patterns to Light, the FTC detailed how companies increasingly have used sophisticated design techniques to allegedly trick or manipulate online consumers into purchasing products or...more
"Now or never." "Don't delay." "No-fee sign-up." "No registration required." "Free 30-day trial." Such advertising messages can be deceptive when they—as it seems they all too often do—send consumers down a rabbit hole where...more
Businesses that allow customers to sign up for automatically renewing subscriptions must comply with a patchwork of state and federal regulations. The Federal Trade Commission (FTC) recently issued an Enforcement Policy...more
Earlier this year, we blogged about the Supreme Court’s decision in AMG v. FTC, which significantly curtailed the FTC’s ability to seek monetary restitution under Section 13(b) of the FTC Act. One quick update there: The...more
We used to think of subscriptions as mostly for newspapers and magazines, but today you can subscribe to get cosmetics, cars, clothes, mental health counseling – even a curated selection of cat toys and treats that will show...more