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Final Rules Enforcement Actions Federal Trade Commission (FTC)

DLA Piper

FTC’s “Click-to-Cancel” Rule Voided

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A unanimous three-judge panel of the Eighth Circuit has vacated the Federal Trade Commission’s (FTC) final rule of amendments to the Negative Option Rule days before the rule’s scheduled July 14, 2025 effective date. The...more

BakerHostetler

FTC’s Junk Fee Rule FAQs Give Road Map for Displaying Price

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In May the FTC’s Rule on Deceptive or Unfair Fees (the Rule) went into effect, and the FTC staff published accompanying FAQs for business. We have blogged a lot about the proposed Rule, enforcement in this space and its windy...more

ArentFox Schiff

Beware of Hidden Fees: The FTC Already Enforcing New ‘Junk Fees’ Rule

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On May 12, the Federal Trade Commission’s (FTC) Rule on Unfair or Deceptive Fees took effect. Often referred to as the “Junk Fees Rule,” the Rule targets hidden, misleading, and deceptive charges and fees imposed by...more

Snell & Wilmer

FTC Click-to-Cancel Rule Enforcement Delayed 60 Days to Enable Business Compliance

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Enforcement of the Federal Trade Commission (FTC) Click-to-Cancel Rule (Rule) has now been deferred to July 14, 2025. The FTC noted that enforcement of the Rule did not adequately consider the compliance burdens...more

Loeb & Loeb LLP

60 More Days for Click to Cancel

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Take a quick breath—but just a short one—because late Friday, the Federal Trade Commission (FTC) decided (3-0) to push the compliance date of its Negative Option (or "Click to Cancel") Rule, a regulation designed to make...more

Cooley LLP

FTC Delays Enforcement of Amended Negative Option Rule

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On May 9, the Federal Trade Commission (FTC) voted unanimously to delay enforcement of most portions of its amended Negative Option Rule (rule) by 60 days, shifting the compliance deadline for these portions from May 14 to...more

DLA Piper

FTC Pauses “Click-to-Cancel” Rule Until July 14

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The Federal Trade Commission (FTC) announced on May 9, 2025 that it will delay full implementation of the amended Negative Option Rule and begin enforcing it on July 14, 2025....more

Kelley Drye & Warren LLP

FTC Extends Compliance Deadline for Negative Option or ​“Click to Cancel” Rule, but Indicates Intent to Enforce as Written in July

Late Friday, the FTC announced that the Commission had voted 3-0 to extend the compliance deadline for the to-be-effective provisions of the Negative Option Rule, formerly known as the ​“Click to Cancel Rule.” While the...more

DLA Piper

FTC “Click-to-Cancel” Rule to Take Effect May 14

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In October 2024, the Federal Trade Commission (FTC) finalized significant updates to the Negative Option Rule, which are slated to take effect on May 14, 2025. A negative option is a contract term under which a buyer agrees...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

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: The Impact of the Election on the FTC

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Today’s podcast features Stephen Calkins, a law professor at Wayne State University in Detroit and former General Counsel of the Federal Trade Commission (the “FTC”). President Trump recently fired, without good cause, the...more

Perkins Coie

FTC (Finally) Publishes Amended COPPA Rule: Compliance Deadlines Set

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On April 22, 2025, the Federal Trade Commission published in the Federal Register the amendments to the Children’s Online Privacy Protection Act (COPPA) rule it announced on January 16, 2025. ...more

Goodwin

2024 Year in Review: Cards, Payments, and Consumer Banking

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We expect continued scrutiny by regulators on fees, including enforcement actions and rulemakings, with the caveat that the new administration could shift federal priorities away from this fee crackdown....more

Seyfarth Shaw LLP

FTC Requests Stay of Appeals to Challenges to FTC Non-Compete Rule Citing New Administration

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On March 7, 2025, lawyers for the Federal Trade Commission (FTC) filed motions requesting a 120-day stay of the agency’s appeal of district court decisions in the Fifth Circuit and Eleventh Circuit, which had blocked the...more

Cozen O'Connor

States and Feds Continue Crackdown on Hidden Fees

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Massachusetts Attorney General Andrea Campbell has announced new consumer protection regulations targeting so-called “junk fees.” Effective September 2, 2025, the regulations require businesses to clearly and prominently...more

Bradley Arant Boult Cummings LLP

New Chairman of the FTC: Can You Compete?

The Federal Trade Commission has a new chairman — Andrew Ferguson. Prior to becoming chairman, Ferguson was sworn in as an FTC commissioner in April 2024 under then-President Joe Biden. Ferguson’s designation as chairman may...more

Davis Wright Tremaine LLP

New Administration Outlook: A Return to Regulatory Humility? What Advertisers Can Expect From the FTC

It would be an understatement to say that the first weeks of the second Trump Administration have been intense. Dizzying? Possibly. Whiplashing? On some fronts, yes. Between rolling back DEI and levying, pulling back, and...more

Alston & Bird

Flurry of FTC Action in the Final Days of the Khan FTC Precedes Transition to the Ferguson FTC

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Our Consumer Protection/FTC and Antitrust Teams highlight a spate of activity by the Federal Trade Commission (FTC) in its final days under the leadership of Lina Khan and offers a preview of what’s to come with Andrew...more

Venable LLP

The Fifth Circuit Slams the Brakes and Vacates FTC CARS Rule

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This week, the U.S. Court of Appeals for the Fifth Circuit vacated the Federal Trade Commission’s (FTC) Combatting Auto Retail Scams (CARS) rule....more

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Strikes Down FTC’s ‘Junk Fee’ Rule for Auto Dealers

On January 24, 2025, the Fifth Circuit Court of Appeals struck down an FTC rule aimed at curbing deceptive advertising and sales practices in the auto industry. The rule, which sought to prohibit certain “junk fees” and...more

Wiley Rein LLP

What Just Happened at the FTC and CFPB: Wiley Consumer Protection Download (January 24, 2025)

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In the two weeks before Inauguration, both the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC) released a flurry of rulemaking developments, policy announcements, and enforcement filings and...more

BakerHostetler

The Federal Trade Commission - The Week That Was

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Check your spam filters, as it is quite possible that they may have filtered out some Federal Trade Commission (FTC or the Commission) emails last week because of the literal deluge of emails spewing forth from the agency....more

Davis Wright Tremaine LLP

Stay ADvised: 2025, Issue 3

FTC's Final Junk Fees Rule Narrowed in Scope - On December 17, 2024, the Federal Trade Commission (FTC) released its final Rule on Unfair or Deceptive Fees, commonly known as the "Junk Fees Rule." This final rule has a...more

Arnall Golden Gregory LLP

Eighth Circuit Refuses to Stay Click-to-Cancel Rule

On January 17, 2025, the United States Court of Appeals for the Eighth Circuit denied a petition to administratively stay the effective date of the Federal Trade Commission’s controversial “Click-to-Cancel” Rule. A divided...more

BakerHostetler

[Podcast] AD Nauseam: Junk Fees Rule Crosses the Finish Line

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On today’s episode of AD Nauseam, Amy and Daniel are back with special guest, Randy Shaheen, a fellow partner at BakerHostetler, to discuss the passing of the FTC’s new Junk Fees Rule....more

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