News & Analysis as of

Federal Trade Commission (FTC) Automatic Renewals Compliance

Lowenstein Sandler LLP

FTC Click-to-Cancel Rule on Hold, but California’s Automatic Renewal Law Remains Intact: What Companies Need To Know

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On July 8, the Eighth U.S. Circuit Court of Appeals vacated the Federal Trade Commission’s (FTC) "click-to-cancel" rule (FTC Rule), which would have required companies to provide customers with an easy, one-click method to...more

Mintz

Click to Cancel: What the FTC’s Setback Means for Subscription-Based Businesses

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I had a thought-provoking conversation this week with an in-house counsel about the now-vacated FTC “Click to Cancel” rule—a regulation that was set to take effect July 14 and could have reshaped how companies manage...more

Nelson Mullins Riley & Scarborough LLP

Do NOT Cancel Your Click-to-Cancel Compliance Efforts!

As has been widely reported, the Eighth Circuit issued a decision this week vacating the Federal Trade Commission’s Click-to-Cancel Rule, which had been scheduled to spring into effect on July 14. In the grand scheme of...more

Lerman Senter PLLC

"Click to Cancel" Rule Vacated Ahead of July 14th Deadline

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Just days before the “Click to Cancel” negative option rule was to go into effect, the Eight Circuit Court of Appeals vacated the rule in its entirety. As explained in our previous alert, the rule, which would have gone into...more

Latham & Watkins LLP

FTC’s Click-to-Cancel Rule to Take Effect on May 14, 2025, Despite Litigation

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Companies with B2C or B2B recurring payment programs that include negative option terms should review their disclosure, consent, and cancellation practices to ensure compliance with the rule....more

Morrison & Foerster LLP

The FTC’s Final “Click-to-Cancel” Rule Faces Legal and Political Hurdles

The fate of the FTC’s long-awaited final “Click-to-Cancel” rule has become tangled in uncertainty as it faces numerous lawsuits and the new incoming presidential administration. In October, the FTC published its Final Rule...more

Venable LLP

Are Hyperlinked Disclosures "Clear and Conspicuous"? Yes, in some cases, according to the FTC's Final Negative Option Rule - A...

Venable LLP on

The Federal Trade Commission's Final Negative Option Rule ("Click to Cancel Rule") contains stringent new requirements for negative option programs, making it even more difficult to run compliant negative option offers....more

Lathrop GPM

New Click-To-Cancel FTC Rule Carries New Rules, Hefty Penalties for Violations

Lathrop GPM on

Attention, any companies that sell direct to consumers: the FTC has announced a new final rule requiring businesses to make it easier for consumers to opt-out and cancel subscriptions. Businesses will have 180 days to comply...more

Holland & Knight LLP

The New Cancel Culture: The FTC's "Click to Cancel" Rule

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The Federal Trade Commission (FTC) has made several amendments to the prior Negative Option Rule (Rule) that alter how subscription- and membership-based businesses will need to operate. This Holland & Knight alert summarizes...more

Lerman Senter PLLC

What the FTC's Click to Cancel Rule Means for Subscription Services

Lerman Senter PLLC on

Subscription-based services are a lynchpin of the services industry and the current focus of the Federal Trade Commission’s (FTC) new “click to cancel” rule. Responding to customer complaints focusing on the difficulty of...more

Hinch Newman LLP

California Expands “Dark Pattern” Automatic Renewal Legislation

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On October 16, 2024, the Federal Trade Commission announced the final FTC “Click-to-Cancel” Rule pertaining to recurring subscriptions and memberships. The Federal Trade Commission is not the only regulatory agency that...more

Venable LLP

California Amends Autorenewal Law, with Stricter Consent Requirements and a “One Save” Rule: Fast VAST Update

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This week, California amended its automatic renewal and continuous service offer law (ARL). Key provisions include the addition of “free-to-pay conversions,” consent obligations, misrepresentation prohibitions, request for...more

Hinch Newman LLP

FTC Compliance Attorney Discusses Agency’s Dramatic Proposed Updates to Recurring Subscriptions and Memberships

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The Federal Trade Commission recently announced a proposed a “click to cancel” provision requiring sellers to make it as simple for consumers to cancel their enrollment as it was to enroll. According to the FTC, if...more

Sheppard Mullin Richter & Hampton LLP

Negative Option Practices Under Increased Scrutiny in the US

Retailers and service providers with US business operations should take note: the Federal Trade Commission (FTC) is increasing its scrutiny of negative option marketing activity to combat unfair or deceptive practices related...more

Foley & Lardner LLP

What You Need to Know About Automatic Renewals

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We live in the age of “Have it fast! Have it now! Have it without hassle!” At the same time customers are demanding ease in online transactions, businesses are naturally seeking to meet consumer demand while reducing...more

Venable LLP

State Automatic Renewal Laws Are Starting to Look Like a Patchwork Quilt as the FTC Expands Enforcement of ROSCA

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With several new state laws effective in 2022, it is becoming increasingly difficult for businesses to develop baseline compliance protocols across federal and state automatic renewal laws. Against this backdrop, federal...more

Perkins Coie

Ad Law Resolutions for 2022

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‘Tis the season for retailers to set best practices to avoid class actions, regulatory enforcement actions, and competitor claims. Ring in the new year with these top five U.S. advertising and marketing law takeaways. 1....more

Fenwick & West LLP

Changes to California’s Automatic Renewal Law May Require Updates for Subscription Service Providers

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Subscription services face increased scrutiny from regulators, lawmakers and the plaintiffs’ bar. As we highlighted in a recent client alert, the FTC warned companies against using “dark patterns” in connection with paid...more

Ballard Spahr LLP

A Closer Look at Automatic Renewal Laws

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Over the past several years, state legislatures have become more aggressive in passing laws to protect consumers’ digital rights. The promulgation of state data security and privacy laws, such as the California Consumer...more

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