Compliance Perspectives: Rolling Out New Compliance Initiatives
On July 28, The New York City Department of Consumer and Worker Protection (DCWP) announced that its amended debt-collection rule, scheduled to take effect on October 1, 2025, has been postponed, leaving the industry in limbo...more
On July 28, the New York City Department of Consumer and Worker Protection (NYC DCWP) announced another delay of the effective date of its amended debt collection rules. The rules will not go into effect on October 1, as...more
After several weeks of back and forth on a potential 10-year moratorium on state or local AI legislation and regulation enforcement, the final version of the so-called One Big Beautiful Bill Act, signed into law on July 4,...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
Maryland has enacted a law that establishes a financial-services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....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
Enforcement of the Federal Trade Commission (FTC) Click-to-Cancel Rule (Rule) has now been deferred to July 14, 2025. The FTC noted that enforcement of the Rule did not adequately consider the compliance burdens...more
The Federal Trade Commission (FTC or Commission) on May 9, 2025, voted to defer the compliance deadline for the amended Negative Option Rule (Rule) by 60 days "given the complexities" of conforming to the amended Rule....more
Companies with B2C or B2B recurring payment programs that include negative option terms now have until July 14, 2025, to ensure their disclosure, consent, and cancellation practices are compliant with the Negative Option...more
If you've been following the latest updates on the click-to-cancel rule, you might have heard about the recent extension granted by the Federal Trade Commission....more
On Friday, the Federal Trade Commission voted to defer the compliance deadline for the amended Negative Option Rule by 60 days. The Commission issued a statement on the new deadline....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
The Federal Trade Commission (FTC) released a statement on May 9 deferring by 60 days its enforcement of certain provisions of the Negative Option Rule (the Rule). The bulk of the Rule’s requirements are now scheduled to go...more
Late Friday, the FTC announced that the Commission had voted 3-0 to extend the compliance deadline for the to-be-effective provisions of the Negative Option Rule, formerly known as the “Click to Cancel Rule.” While the...more
2025 has already been a busy year in UK consumer protection law. With the CMA having issued its annual plan for 2025 / 2026 on 27 March 2025 and its new enforcement powers under the Digital Markets, Competition and Consumer...more
On April 10, 2025, the Food and Drug Administration (FDA) released a pre-recorded webinar outlining the updated "healthy" nutrient content claim rule. As we previously discussed, the rule will go into effect on April 28,...more
The CMA' s new enforcement powers granted under the Digital Markets, Competition and Consumers Act 2024 ("DMCCA") come in to force on 6 April 2025, bringing major change to the consumer protection regime. Provisions relating...more
2025 is set to be a busy year in UK consumer protection law. With the CMA issuing its annual plan for 2025 / 2026 on 27 March 2025 and its new powers to enforce consumer protection law under the Digital Markets, Competition...more
On February 25, the Food and Drug Administration (FDA) announced a delay in the effective date for its final rule updating the criteria to use the "healthy" nutrient content claim on food labeling....more
The European Union has significantly overhauled its product liability regime with a new directive concerning liability for defective products (Product Liability Directive). EU member states have until December 9, 2026, to...more
Since the enactment of California’s so-called “Junk Fee Ban,” S.B. 478 (more formally known as the “Honest Pricing Law” or the “Hidden Fees Statute”), Benesch has been fielding a wide range of questions from retailers and...more
Update: OMB approved the FCC's broadband disclosure rules on October 10, 2023, meaning that most of the rules will become applicable to ISPs with more than 100,000 subscriber lines on April 10, 2024, and to all other ISPs on...more