Disclosure Requirements, Appeals, Enforcement

With “Click-to-Cancel” Rule Now Vacated by 8th Circuit, What’s Next for FTC?

Wiley Rein LLP on 7/16/2025

The U.S. Court of Appeals for the Eighth Circuit on July 2 issued a decision vacating the Federal Trade Commission’s (FTC) revised Negative Option Rule, which the previous Administration called the “Click to Cancel” Rule....more

Eighth Circuit Strikes Down FTC’s Click-to-Cancel Rule

Arnall Golden Gregory LLP on 7/14/2025

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

FTC’s “Click-to-Cancel” Rule Struck Down by Eighth Circuit

Ropes & Gray LLP on 7/14/2025

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

What’s Ahead as Corporate Transparency Act Comes to a Crossroads

Farella Braun + Martel LLP on 1/15/2025

The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more

The SEC’s New Corporate Buy-Back Rules Have Been Formally Vacated By the U.S. 5th Circuit Court of Appeals: Issuers May Suspend...

Proskauer - Regulatory & Compliance on 12/20/2023

On December 19, 2023, the Fifth Circuit formally vacated the SEC’s buy-back disclosure rules. While it is unclear what, if any, action the SEC may take in response to this definitive ruling, the realistic options appear to be...more

SEC Sued Over Newly Adopted Share Repurchase Rules

Keating Muething & Klekamp PLL on 5/18/2023

On Friday, May 12, 2023, the U.S. Chamber of Commerce announced that it had filed a lawsuit against the SEC to prevent implementation of the SEC’s new Share Repurchase Disclosure Modernization rules, which KMK has recently...more