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Innovation in Compliance: Allison Lagosh on Proactive Compliance Planning for Regulatory Changes
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When DEI Meets the FCA: What Employers Need to Know About the DOJ’s Civil Rights Fraud Initiative
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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
The Eighth Circuit Court of Appeals has issued a per curiam opinion vacating the FTC’s Click-to-Cancel Rule based on the Federal Trade Commission (FTC)’s failure to comply with a procedural requirement in the FTC Act. This...more
Although the entire Rule has been vacated, businesses offering negative option programs should remain aware of general unfair and deceptive advertising principles and applicable state law requirements. KEY POINTS: On July...more
On July 8, 2025, a three-judge panel of the US Court of Appeals for the Eighth Circuit issued a per curiam opinion vacating the US Federal Trade Commission’s (FTC’s) Negative Option Rule (Click-to-Cancel) on Administrative...more
Due to go into effect on July 14, the Negative Option Rule has been struck down by the Eighth Circuit. Our Consumer Protection/FTC Group examines the Federal Trade Commission’s options going forward....more
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
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
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
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
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
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
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
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
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
Ending speculation and uncertainty about whether new leadership at the Federal Trade Commission (FTC) would repeal or continue to defend the agency’s Negative Option Rule, which regulates offerings such as autorenewal of...more