News & Analysis as of

Disclosure Requirements Negative Option Rule Consent

Orrick, Herrington & Sutcliffe LLP

Navigating Federal and California Negative Option Rules: Key Insights for Businesses

As regulatory scrutiny around automatic renewals intensifies, understanding the Federal Trade Commission’s new “Click-to-Cancel” rule and California’s recently amended Automatic Renewal Law, is essential for companies looking...more

Venable LLP

July 1 and July 14 Autorenewal and Negative Option Compliance Deadlines: A Fast VAST Alert

Venable LLP on

On July 1, California's amended autorenewal law takes effect, and the Federal Trade Commission's (FTC) updated enforcement deadline for the primary requirements of the updated Negative Option Rule (so-called Click to Cancel...more

Miller Canfield

FTC's 'Click-to-Cancel' Rule Battles Through Political Shifts and Legal Challenges

Miller Canfield on

The Federal Trade Commission’s (“FTC”) Negative Option Rule, dubbed the “Click-to-Cancel” Rule (the “Rule”), stands to substantially change the way online businesses must interact with customers. Its fate is now in the hands...more

Paul Hastings LLP

Updated California and FTC Auto-Renewal Regulations Take Effect

Paul Hastings LLP on

In the fall of 2024, California and the Federal Trade Commission (FTC) amended their respective auto-renewal regulations. The amendments detail new and largely parallel disclosure, consent, and cancellation requirements for...more

Holland & Knight LLP

FTC Signals Enforcement on Auto-Renewing Subscriptions and Sales

Holland & Knight LLP on

In January 2025, prior to President Donald Trump's inauguration, the Federal Trade Commission (FTC) finalized its Click to Cancel Rule (Rule). This regulation requires additional disclosures, consents and simple cancellation...more

Dorsey & Whitney LLP

FTC Finalizes Click to Cancel and Negative Option Rule

Dorsey & Whitney LLP on

On October 16, 2024, the Federal Trade Commission (FTC) announced a revision to its negative option rule. The rule, formally entitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs,” is a...more

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