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
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....more
A federal appeals court has nullified the Federal Trade Commission’s amendments to its Negative Option Rule intended to make it easier for people to cancel subscriptions....more
On July 8, the U.S. Court of Appeals for the Eighth Circuit blocked the “click-to-cancel” rule, which would have required companies to make it as easy to cancel subscriptions as it was to sign up, including obtaining consent...more
A unanimous three-judge panel of the Eighth Circuit has vacated the Federal Trade Commission’s (FTC) final rule of amendments to the Negative Option Rule days before the rule’s scheduled July 14, 2025 effective date. The...more
Just days before it was set to take effect, the U.S. Court of Appeals for the Eighth Circuit struck down the Federal Trade Commission’s (FTC) much anticipated “Click-to-Cancel Rule” (the “Rule”), delivering regulatory...more
On July 8, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s Negative Option Rule, also referred to as the “Click-to-Cancel” rule (the “Rule”), determining that the FTC...more
Just days before it was scheduled to take effect, the Federal Trade Commission’s (FTC) amended Negative Option Rule, commonly known as the “Click-to-Cancel” Rule (Rule), was vacated by the US Court of Appeals for the Eighth...more
On July 8, a panel for the U.S. Court of Appeals for the Eighth Circuit issued a significant decision in the case of Custom Communications, Inc. v. Federal Trade Commission (FTC). The panel vacated the FTC’s amended Negative...more
On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Click to Cancel Rule (the “Rule”), which was previously scheduled to take effect on May 14, 2025, and later...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
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
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
Last week, a security services company and several trade groups filed their merits brief in the U.S. Court of Appeals for the Eighth Circuit challenging the Federal Trade Commission’s (FTC) newly adopted Negative Option Rule,...more
The fate of the FTC’s long-awaited final “Click-to-Cancel” rule has become tangled in uncertainty as it faces numerous lawsuits and the new incoming presidential administration. In October, the FTC published its Final Rule...more
Businesses now have the chance to influence the new UK rules governing subscriptions contracts by responding the Government’s consultation on the new legislation (and the secondary rules which are required to implement it)....more
On October 16, the FTC announced that it has finalized its “click to cancel” rule, that will require sellers to make it much easier for consumers to cancel subscriptions. The final rule is part of the FTC’s ongoing review of...more
The Federal Trade Commission (FTC) has finalized amendments to the Negative Option Rule, now retitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs“ (“Rule”), which represents a significant...more
The Biden Administration wants to crack down on corporate practices that it believes waste consumers’ time and money through excessive paperwork, long wait times, and other aggravations – and you’ll want to take note so you...more
These days, it seems like there are three guarantees in life—death, taxes, and monumental Supreme Court administrative law opinions in the summer. As you’ve probably heard by now, the trend continues this year, including...more
We love two-parters. Who shot J.R.? Who shot Montgomery Burns? Well, perhaps this one won’t be quite as much fun – but checking in on FTC rulemakings also warrants the two-parter treatment. ...more
Key Takeaways - In its current form, the Negative Option Rule covers only a narrow category of negative option marketing – prenotification negative option plans. The FTC’s proposed Rule seeks to synthesize all of the...more
OnlyFans Users Sue Over Iffy Auto-Renewal Subscriptions - OnlyFans is a subscription-based site that touts itself as being the place for content creators to monetize their content and connect creators with fans. But all...more
In April 2023, the Federal Trade Commission announced a number of consumer protection actions and inquiries involving an important U.S. Supreme Court Ruling regarding the ability of defendants in FTC and SEC actions to raise...more