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Federal Trade Commission (FTC) Disclosure Requirements Consent

Fisher Phillips

Court Strikes Down FTC’s Click-to-Cancel Rule – But Businesses Still Face Major Risk from State Auto-Renewal Laws

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A federal appeals court just vacated the FTC’s controversial Click-to-Cancel rule on procedural grounds – but businesses shouldn’t drop their guard just yet. Many states already have their own automatic renewal laws on the...more

Miller Canfield

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

Miller Canfield on

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

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

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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

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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

Arnall Golden Gregory LLP

State Wave of Click-to-Cancel Rules

The end of President Biden’s administration saw the Federal Trade Commission (“FTC”) adopt the sweeping “Click-to-Cancel” rule, which stands to impose a spate of requirements for disclosure, consent, and cancellation on any...more

Paul Hastings LLP

Updated California and FTC Auto-Renewal Regulations Take Effect

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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

Benesch

FTC Ride-Hail Lawsuit Shows Renewed Interest in Subscriptions

Benesch on

Notwithstanding significant changes at the Federal Trade Commission (FTC) – including the removal of two of the five Commissioners, and the new appointment of Commissioner Mark Meador – the Commission has sent a clear message...more

BakerHostetler

COPPA Is Back in the Saddle: FTC Publishes Final Rule for Children’s Privacy

BakerHostetler on

Just as we’re getting ready to pick out our cowboy boots and bolo ties for Beyoncé’s Cowboy Carter Tour, the Federal Trade Commission (FTC or Commission) published its long-awaited finalized amendments (Final Rule) to the...more

Holland & Knight LLP

FTC Signals Enforcement on Auto-Renewing Subscriptions and Sales

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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

Lowenstein Sandler LLP

FTC "Click-To-Cancel" Rule Coming Soon

Lowenstein Sandler LLP on

The Federal Trade Commission’s final “click-to-cancel” rule, which goes into effect on May 14, 2025, attempts to address the difficulties consumers may face when trying to cancel an automatically renewing subscription. The...more

Skadden, Arps, Slate, Meagher & Flom LLP

FTC Finalizes Long-Awaited Child Online Privacy Rule Amendments

On January 16, 2025, the Federal Trade Commission (FTC) finalized amendments to the Children’s Online Privacy Protection Act (COPPA) Rule (Final Rule) relating to the collection, use and disclosure of personal information...more

Snell & Wilmer

FTC Click to Cancel Rule

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In 2023, the U.S. Federal Trade Commission (FTC) sought public comments on how to combat perceived unfair and deceptive trade practices, recurring subscription charges, and cancelation of such plans. Born out of these...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

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

Morgan Lewis

FTC ‘Click-to-Cancel’ Rule Requires Canceling Recurring Charges to Be as Easy as Signing Up

Morgan Lewis on

The Federal Trade Commission (FTC) recently issued its Final Rule requiring businesses subject to its authority to establish equivalency between the ease of signing up and canceling subscriptions, memberships, and other...more

Hinch Newman LLP

FTC Announces Final “Click-to-Cancel” Recurring Subscriptions and Memberships Rule

Hinch Newman LLP on

On October 16, 2024, the Federal Trade Commission announced a final “click-to-cancel” rule that will require sellers to make it as easy for consumers to cancel their enrollment as it was to sign-up. Most of the final rule’s...more

Foley & Lardner LLP

FTC Finalizes “Click-to-Cancel” Rule 18 October 2024

Foley & Lardner LLP on

The Federal Trade Commission (FTC) has finalized amendments to the Negative Option Rule, now retitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs“ (“Rule”), which represents a significant...more

Akin Gump Strauss Hauer & Feld LLP

Senate Advances Landmark Tech Policy Priorities

Key Points - The Senate has passed landmark children’s online privacy and safety legislation via a near-unanimous vote shortly before departing for the August recess. The bill is comprised of revised versions of the Kids...more

Venable LLP

Fast VAST Update: California Proposes Sweeping Changes to Autorenewal Law

Venable LLP on

Last week, California's legislature proposed amendments to its Automatic Renewal Law (ARL) to tighten the already-strict requirements for autorenewal, negative option, and continuous service offers. The law would impose new...more

McDermott Will & Schulte

Tips for Alcohol Suppliers Utilizing Social Media

In light of the Federal Trade Commission’s (FTC) 2023 revisions to its Endorsement Guides, it is essential to ensure that your business is compliant. While the alcohol industry is known for product innovation, the industry is...more

Hinch Newman LLP

FTC Advertising Law Alert: Proposed Revisions to the COPPA Rule

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The Children’s Online Privacy Protection Rule requires operators of websites and online services that are directed to children under 13 years of age, or that have “actual knowledge” they are collecting personal information...more

Verrill

Glory, Glory, Hallelujah!

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Remember that old parody of the Battle Hymn of the Republic we used to sing before there was an Internet? There are apparently many versions, but they all generally involve children inflicting various types of mayhem on their...more

Venable LLP

Ninth Circuit Upholds Dismissal of Autorenewal Lawsuit, Finds Disclosure, Consent, and Acknowledgment Sufficient

Venable LLP on

In January, the Ninth Circuit agreed with a California district court's finding that a software company's autorenewal practices did not violate California's autorenewal law. The decision reflects a win for companies offering...more

Venable LLP

Is Your New Year’s Resolution to Comply with Automatic Renewal Laws? If So, Look No Further

Venable LLP on

The law surrounding negative option and continuity programs continues to evolve rapidly. Feeling a bit overwhelmed with the latest developments? Below is what you need to know in light of new laws, new enforcement actions,...more

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