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Federal Trade Commission (FTC) › Consumer Contracts › Compliance

Mintz

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

Mintz on

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

Latham & Watkins LLP

Unpacking the FTC’s New Negative Option Rule, Its Legal Challenges, and Future Uncertainty

Latham & Watkins LLP on

The rule impacts both B2B and B2C subscription autorenewals and other negative option programs; however, significant legal challenges could impact the rule’s implementation....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

BCLP

Are You Preparing to Comply with the FTC “Click-to-Cancel” Rule?

BCLP on

The Federal Trade Commission (FTC) published its final “Click-to-Cancel” Rule in the Federal Register on November 15, 2024, meaning that companies should ensure that they comply with the rule’s requirements within the next...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

Holland & Knight LLP on

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

Venable LLP

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

Venable LLP on

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

Venable LLP

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

Venable LLP on

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

Fenwick & West LLP

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

Fenwick & West LLP on

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

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