Disclosure Requirements, Appeals, Statutory Authority

SEC Climate Rule Saga Continues

Fenwick & West LLP on 7/25/2025

The Securities and Exchange Commission’s (SEC) controversial climate disclosure rules have been essentially dead since last March, when the SEC voted to end its defense of the rules. ...more

SEC Requests Eighth Circuit Decide Climate Rules Litigation

Wilson Sonsini Goodrich & Rosati on 7/25/2025

On July 23, 2025, the U.S. Securities and Exchange Commission submitted a status report to the U.S. Court of Appeals for the Eighth Circuit regarding the final climate-related disclosure rules. According to the status report,...more

Click-to-Cancelled! Eighth Circuit Vacates Federal Trade Commission’s Revised Negative Option Rule

Mayer Brown on 7/21/2025

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

Eighth Circuit Cancels FTC’s “Click-to-Cancel” Rule

Benesch on 7/15/2025

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

Eighth Circuit Slams the Brakes on FTC’s Click-to-Cancel Rule

Miller Canfield on 7/14/2025

In a dramatic turn of events, the United States Court of Appeals for the Eighth Circuit has vacated the Federal Trade Commission’s (FTC) Click-to-Cancel Rule, which was set to take effect on July 14, 2025. ...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