News & Analysis as of August 10, 2025

Disclosure Requirements

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

Kelley Drye & Warren LLP on 5/12/2025

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

To Be or Not To Be: Challenge to the FTC's CARS Rule Is Ripe for the Fifth Circuit to Decide

Hudson Cook, LLP on 12/4/2024

On October 9, 2024, the U.S. Court of Appeals for the Fifth Circuit heard oral arguments on the challenge by the National Automobile Dealers Association and the Texas Automobile Dealers Association ("Petitioners") to the...more

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Pending Litigation › Federal Trade Commission (FTC) › Disclosure Requirements

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

To Be or Not To Be: Challenge to the FTC's CARS Rule Is Ripe for the Fifth Circuit to Decide

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