News & Analysis as of

Federal Trade Commission (FTC) Rulemaking Process State Attorneys General

WilmerHale

Eighth Circuit Vacates the FTC's Click to Cancel Rule, but Federal and State Regulators Likely to Remain Active

WilmerHale on

On July 8, 2025, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) “Click to Cancel” Rule....more

Dickinson Wright

Rule Interrupted: “Click-to-Cancel” is “Click-to-Gone”

Dickinson Wright on

The Federal Trade Commission’s (FTC) negative option rule, better known as the “Click-to-Cancel” rule, which was set to go into effect July 14, 2025, has been vacated in its entirely by the Eighth Circuit in Custom...more

Hudson Cook, LLP

Eighth Circuit Vacates FTC's Negative Option Rule

Hudson Cook, LLP on

On July 8, 2025, the Eighth Circuit issued an opinion that vacated the FTC's Negative Option Rule in its entirety. The FTC's compliance deadline for the Rule, which had been extended once, was set to go into effect on July...more

Mayer Brown

A Post-CARS Rule Brake? Not So Fast. Buckle Up for New Regulatory Activity in the Motor Vehicle Space

Mayer Brown on

The Fifth Circuit vacated the Federal Trade Commission’s (“FTC”) Combating Auto Retail Scams Trade Regulation Rule (“CARS Rule”) on January 27, 2025, determining that the FTC failed to follow its own procedural requirements...more

McGlinchey Stafford

FTC’s CARS Rule Vacated — What Finance Companies Need to Know

McGlinchey Stafford on

In a procedural decision, the U.S. Court of Appeals for the Fifth Circuit vacated the CARS Rule (officially, the Combatting Auto Retail Scams Trade Regulation Rule, sometimes known as the Vehicle Shopping Rule) which was...more

Husch Blackwell LLP

What We're Watching: State Attorneys General Offices in 2025

Husch Blackwell LLP on

As the Oval Office and Congress flip to Republican control, we expect more state AG-led efforts to impact public policy. Shortly after the New Year, we gathered together attorneys from our State Attorneys General team to...more

Holland & Knight LLP

Fifth Circuit Strikes Down FTC's Auto Retail Scam Rule: Key Implications for Dealers

Holland & Knight LLP on

The U.S. Court of Appeals for the Fifth Circuit on Jan. 27, 2025, vacated the Federal Trade Commission's (FTC) Rule on Combating Auto Retail Scams (CARS Rule) before it could take effect, finding that the FTC failed to follow...more

Katten Muchin Rosenman LLP

CFPB Proposes a New Rule Prohibiting Certain Contractual Terms for Consumer Financial Products

On January 13, the Consumer Finance Protection Bureau (CFPB) published a new proposed rule attempting to ban certain contractual provisions in "take it or leave it" consumer contracts that purport to "waive substantive...more

Shipkevich PLLC

[Webinar] Post-Election Analysis and Impact on the Debt Settlement Industry - December 10th, 1:00 pm EST

Shipkevich PLLC on

Felix Shipkevich and Yvonne Bowser-Caballero of Shipkevich PLLC, with special guest Nicholas Kosmas, Chief Legal Officer of ClearOne Advantage LLC, will host a webinar to discuss a post-election overview of the regulatory...more

Seyfarth Shaw LLP

Fifth Circuit Set to Weigh Challenge to FTC’s CARS Rule - Seyfarth's Future of Automotive Series

Seyfarth Shaw LLP on

The administrative challenge brought by the National Automobile Dealers Association (NADA) and another trade association against the Combating Auto Retail Scams (“CARS”) Trade Regulation Rule, issued last year by the Federal...more

Foley & Lardner LLP

Colorado Attorney General Releases Proposed Privacy Rules and Begins Holding Stakeholder Meetings

Foley & Lardner LLP on

On July 7, 2021, Colorado enacted the Colorado Privacy Act (CPA), becoming the third U.S. state to adopt a comprehensive privacy law. As previously described, the CPA doesn’t apply to everyone. Instead, it only applies to...more

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