2024 Payments Year in Review: CFPB and FTC Regulatory Trends - Part Three — Payments Pros – The Payments Law Podcast
Consumer Finance Monitor Podcast Episode: A Look at the FTC’s Click-to-Cancel Rule, with James Kohm, Associate Director of Enforcement Division of the FTC’s Bureau of Consumer Protection
Effective September 2, 2025, Massachusetts will begin enforcing 940 CMR 38.00, a new regulation aimed at promoting price transparency for consumers. These comprehensive rules apply to the sale or lease of goods and services...more
The U.S. Court of Appeals for the Eighth Circuit on July 2 issued a decision vacating the Federal Trade Commission’s (FTC) revised Negative Option Rule, which the previous Administration called the “Click to Cancel” Rule....more
On July 8, the U.S. Court of Appeals for the Eighth Circuit issued a unanimous opinion in Custom Communications Inc. v. Federal Trade Commission that vacates the Federal Trade Commission’s (FTC) Rule Concerning Recurring...more
Yesterday, the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Negative Option Rule (Click-to-Cancel Rule or Rule) that was set to go into effect on July 14....more
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
What happened and why? On July 8, 2025, a unanimous three-judge panel of the Eighth Circuit Court of Appeals vacated the updated version of the FTC’s Negative Option Rule (also known as the “click to cancel” rule) to have...more
The U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s Rule Concerning Subscriptions and Other Negative Option Plans (often referred to as the “Click-to-Cancel” rule) on July 8, just days...more
Companies selling subscriptions have been busy navigating compliance with the Federal Trade Commission’s Negative Option Rule, which is scheduled to go into effect July 14. But when it rains, it pours....more
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
In October 2024, the Federal Trade Commission (“FTC”) updated its 1973 Negative Option Rule to address unfair and deceptive online subscription practices. See 16 C.F.R. § 425 (2024) (the “Negative Option Rule” or the “Rule”)....more
Last fall, the FTC published the Rule Concerning Recurring Subscriptions and Other Negative Option Programs, or the “Click-to-Cancel Rule.” The Rule targets practices where cancellation is intentionally more difficult than...more
New York AG Letitia James entered into a settlement with Equinox Group, LLC (Equinox Group), which operates fitness services under Equinox, Equinox+, and SoulCycle, resolving allegations that its subscription and cancellation...more
From streaming services and gym memberships to software vendor agreements and e-commerce franchises, automatic contract renewals are common occurrences. Currently, California law protects consumers regarding automatic renewal...more
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
Companies with recurring payment programs with negative option terms now have until July 14, 2025, to bring their disclosure, consent, and cancellation practices into full compliance....more
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
Companies with B2C or B2B recurring payment programs that include negative option terms now have until July 14, 2025, to ensure their disclosure, consent, and cancellation practices are compliant with the Negative Option...more
On Friday, the Federal Trade Commission voted to defer the compliance deadline for the amended Negative Option Rule by 60 days. The Commission issued a statement on the new deadline....more
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
The Federal Trade Commission (FTC) released a statement on May 9 deferring by 60 days its enforcement of certain provisions of the Negative Option Rule (the Rule). The bulk of the Rule’s requirements are now scheduled to go...more
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
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
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
Our Consumer Protection/FTC Group investigates the implications of a Federal Trade Commission complaint against Uber alleging deceptive billing and cancellation practices under the Restore Online Shoppers’ Confidence Act...more
This week, the Federal Trade Commission (FTC) filed a lawsuit in federal court against rideshare and delivery company Uber for allegedly deceptive subscription practices, including making it unreasonably difficult to cancel....more