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
The FTC Takes Action Against the Amazon Prime Program
AD Nauseam: Negative Options – From Wine, to Cookies, to Gyms – Everything You Need to Know
Podcast - The FTC's Click to Cancel Proposal
Autorenewals - The Crypto Exchange Podcast
A federal appeals court just vacated the FTC’s controversial Click-to-Cancel rule on procedural grounds – but businesses shouldn’t drop their guard just yet. Many states already have their own automatic renewal laws on the...more
Amendments to California’s Automatic Renewal Law (ARL) will take effect on July 1, 2025. Enacted in September 2024 through Assembly Bill No. 2863, the amendments expand disclosure, consent, and cancellation obligations for...more
Federal officials just postponed enforcement of the Click-to-Cancel rule, which requires businesses offering subscriptions or memberships to provide a cancellation process as straightforward as the sign-up procedure. The...more
In January 2025, prior to President Donald Trump's inauguration, the Federal Trade Commission (FTC) finalized its Click to Cancel Rule (Rule). This regulation requires additional disclosures, consents and simple cancellation...more
The Federal Trade Commission’s final “click-to-cancel” rule, which goes into effect on May 14, 2025, attempts to address the difficulties consumers may face when trying to cancel an automatically renewing subscription. The...more
It’s time to revisit automatic renewal compliance. With California amending its Automatic Renewal Law ("ARL") on September 24, 2024, and the Federal Trade Commission (“FTC”) finalizing its “Click-to-Cancel” Rule (“FTC Final...more
The Federal Trade Commission (FTC) published its final “Click-to-Cancel” Rule in the Federal Register on November 15, 2024, meaning that companies should ensure that they comply with the rule’s requirements within the next...more
California has passed additional amendments to its Automatic Renewal Law (ARL), which will further strengthen that law’s already stringent requirements and likely present increased class action risk....more
On October 16, the Federal Trade Commission (FTC) released the final version of its Rule Concerning Recurring Subscriptions and Other Negative Option Programs (Rule), which requires sellers of products and services to receive...more
The Federal Trade Commission (FTC) announced its final Negative Option Rule (the Rule)—which the FTC often refers to as the “Click to Cancel” rule—for automatically renewing subscriptions, free trials that convert to paid...more
The Federal Trade Commission (FTC) has made several amendments to the prior Negative Option Rule (Rule) that alter how subscription- and membership-based businesses will need to operate. This Holland & Knight alert summarizes...more
The FTC's new rule makes it easier for consumers to cancel subscriptions and memberships they no longer want. The Federal Trade Commission (FTC) introduced a "click-to-cancel" rule on October 16, amending the 1973...more
On Oct. 16, the Federal Trade Commission (FTC) voted 3-2 to finalize its “click-to-cancel” rule that will introduce new requirements to simplify the cancellation process for consumers wishing to terminate their subscriptions...more
On October 16, the Federal Trade Commission announced final “click-to-cancel” amendments to its Negative Option Rule. Under the FTC’s amended Negative Option Rule...more
The Federal Trade Commission (FTC) recently issued its Final Rule requiring businesses subject to its authority to establish equivalency between the ease of signing up and canceling subscriptions, memberships, and other...more
On October 16, 2024, the Federal Trade Commission (FTC or Commission) announced its adoption of a final “click-to-cancel” Rule that regulates both sign-up and cancellation processes for subscriptions or other recurring...more
Gone are the days when subscriptions were limited to Netflix or Amazon. Today, you can find subscription services for nearly anything—from meal kits to beauty products and beyond. For companies, these subscriptions offer a...more
On October 16, 2024, the Federal Trade Commission announced a final “click-to-cancel” rule that will require sellers to make it as easy for consumers to cancel their enrollment as it was to sign-up. Most of the final rule’s...more
The Federal Trade Commission (FTC) finally released its long-awaited Negative Option Rule (the Final Rule), aka the “Click-to-Cancel Rule,” on October 16. The Final Rule was approved by a partisan vote of 3-2, with the two...more
Companies that automatically renew customers’ subscriptions or memberships, take note. On October 16, 2024, the Federal Trade Commission (FTC) announced sweeping amendments to the Negative Option Rule, which would apply to a...more
The Federal Trade Commission (FTC) has made clear its focus on automatic renewal programs with high-profile lawsuits in recent weeks, alleging violations of the Restore Online Shoppers' Confidence Act (ROSCA). Below are some...more
The California legislature recently renewed its efforts to regulate automatic renewal programs with proposed amendments to its Automatic Renewal Law (ARL). This development does not follow any lack of attention to this area...more
Last week, California's legislature proposed amendments to its Automatic Renewal Law (ARL) to tighten the already-strict requirements for autorenewal, negative option, and continuous service offers. The law would impose new...more
The Federal Trade Commission (FTC), state attorneys general, and class action plaintiffs continue to scrutinize negative option and continuity offers. Negative option marketing can include pre-notification negative option...more
Subscription services, initially marketed as a cheaper, more accessible option, have recently been experiencing a price surge. In 2023, top subscription apps like Apple Music, Amazon Music, YouTubeTV, Netflix, Peacock, HBO...more