News & Analysis as of

Final Rules Federal Trade Commission (FTC) Disclosure Requirements

Arnall Golden Gregory LLP

Eighth Circuit Strikes Down FTC’s Click-to-Cancel Rule

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, resolving the challenges to the rule filed on the heels of its adoption in...more

Miller Canfield

FTC's 'Click-to-Cancel' Rule Battles Through Political Shifts and Legal Challenges

Miller Canfield on

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

Perkins Coie

The FTC “Junk Fee” Rule Is Here… Along With a Wave of State Laws

Perkins Coie on

Key Takeaways - - The Federal Trade Commission’s Rule on Unfair or Deceptive Fees is now in effect. - The rule applies to businesses that offer or advertise live-event tickets or short-term lodging. - If including the...more

BakerHostetler

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

BakerHostetler on

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

ArentFox Schiff on

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

Perkins Coie

The FTC “Junk Fee” Rule Is Here…Along with a Wave of State Laws

Perkins Coie on

Also referred to as the “junk fee” rule against “bait-and-switch” or “drip” pricing, the rule was adopted with bipartisan support in the waning days of the Biden presidency. Further, the Republican-led FTC under the Trump...more

IR Global

FTC Implements Rule to Eliminate Hidden Fees in Pricing

IR Global on

On May 12, 2025, the Federal Trade Commission (FTC) enacted the Rule on Unfair or Deceptive Fees (the “Rule”), mandating that businesses disclose all mandatory fees upfront in advertised prices. This initiative aims to...more

Holland & Knight LLP

Podcast - New Guidance on Complying with FTC Rule on Deceptive and Unfair Fees

Holland & Knight LLP on

In this episode of "Clearly Conspicuous," consumer protection attorney Anthony DiResta breaks down the Federal Trade Commission's (FTC) Rule on Unfair or Deceptive Fees, focusing on recent FAQs that clarify its application...more

Winstead PC

The Federal Trade Commission (FTC) Click-to-Cancel

Winstead PC on

The Federal Trade Commission (“FTC”) has recently announced that the FTC’s Click to Cancel Rule (the “Rule”) has been postponed to July 14, 2025. Originally planned to become effective May 14, 2025, the Commission released...more

Snell & Wilmer

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

Snell & Wilmer on

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

Holland & Knight LLP

FTC Defers Negative Option Rule Compliance Deadline by 60 Days

Holland & Knight LLP on

The Federal Trade Commission (FTC or Commission) on May 9, 2025, voted to defer the compliance deadline for the amended Negative Option Rule (Rule) by 60 days "given the complexities" of conforming to the amended Rule....more

Loeb & Loeb LLP

60 More Days for Click to Cancel

Loeb & Loeb LLP on

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

Cooley LLP on

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

Arnall Golden Gregory LLP

Unhidden Fees: FTC Mandates Upfront Disclosure of All Mandatory Fees in Live-Event Ticketing

The live entertainment industry should take note that the Federal Trade Commission (“FTC”) has finalized its Rule on Unfair or Deceptive Fees aimed at eliminating deceptive pricing practices in the live-event ticketing...more

Alston & Bird

FTC Delays Compliance Deadline for Click-to-Cancel Rule Until July 14, 2025

Alston & Bird on

Our Consumer Protection/FTC Team notes that the Federal Trade Commission extended the compliance deadline of the Negative Option Rule (better known as the Click-to-Cancel Rule) by 60 days....more

Venable LLP

FTC Staff Issues Guidance Ahead of New Rule Targeting Deceptive Fees

Venable LLP on

Last week, the Federal Trade Commission (FTC) published a set of Frequently Asked Questions (FAQ) aimed at helping businesses and consumers understand the agency’s Rule on Unfair or Deceptive Fees, which takes effect on May...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

Fox Rothschild LLP

FTC’s Unfair/Deceptive Fees Rule Takes Effect

Fox Rothschild LLP on

The Federal Trade Commission’s (FTC) Rule on Unfair or Deceptive Fees, 16 C.F.R. Part 464, is effective as of May 12, 2025. According to the FTC’s recent press release, the Rule “prohibits bait-and-switch pricing and other...more

Fenwick & West LLP

The FTC Rule on Unfair or Deceptive Fees: FAQs and Guidance

Fenwick & West LLP on

On May 12, 2025, the Federal Trade Commission’s Rule on Unfair or Deceptive Fees will take effect. Under the rule, certain businesses must disclose all mandatory fees and the total price up front to limit bait-and-switch...more

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

Perkins Coie

FTC “Click-To-Cancel” Rule Goes Into Effect May 14

Perkins Coie on

Key Takeaways - - Beginning May 14, businesses offering "negative option features" can incur significant financial penalties for each violation of the FTC’s “click-to-cancel” rule. - The rule imposes obligations related to...more

Kelley Drye & Warren LLP

FTC Issues FAQs on Fees Rule, Affirms Rule to Become Effective Next Week

The FTC issued FAQs to answer common questions about its Rule on Unfair or Deceptive Fees and to provide a small entity compliance guide in connection with the Rule. The issuance of the FAQs affirms that the current FTC, led...more

Foley & Lardner LLP

Is Your Company Prepared for the FTC’s Junk Fees Rule, Effective May 12?

Foley & Lardner LLP on

On May 5, 2025, the Federal Trade Commission (FTC or “the Commission”) published FAQs aimed at providing consumers and businesses with information regarding the agency’s Rule on Unfair or Deceptive Fees (the “Junk Fees Rule”...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

Bricker Graydon LLP

COPPA 2.0: The Remake

Bricker Graydon LLP on

After the Children’s Online Privacy Protection Rule (COPPA) updates, proposed by the FTC’s Final Rule, were paused due to an Executive Order in January this year, many wondered whether that would be the end of the long...more

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