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Vacated Rulemaking Process

Katten Muchin Rosenman LLP

A CAT-astrophic Funding Model? Court Sends SEC Back to the Drawing Board

The US Court of Appeals for the Eleventh Circuit (Eleventh Circuit) recently vacated the Securities and Exchange Commission’s (SEC) 2023 funding order for the Consolidated Audit Trail (CAT) (the 2023 Funding Order), stayed...more

WilmerHale

Eighth Circuit Vacates the FTC's Click to Cancel Rule, but Federal and State Regulators Likely to Remain Active

WilmerHale on

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

Arnall Golden Gregory LLP

Eighth Circuit Strikes Down FTC’s Click-to-Cancel Rule

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, resolving the challenges to the rule filed on the heels of its adoption in...more

Troutman Pepper Locke

Eighth Circuit Vacates FTC’s Negative Option Rule for Procedural Violations

Troutman Pepper Locke on

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

Sheppard Mullin Richter & Hampton LLP

Eighth Circuit Vacates FTC’s “Click-to-Cancel” Negative Option Rule

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the FTC’s “click-to-cancel” Negative Option Rule, holding that the FTC violated the FTC Act and the Administrative Procedure Act when it finalized the...more

Dickinson Wright

Rule Interrupted: “Click-to-Cancel” is “Click-to-Gone”

Dickinson Wright on

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

Lerman Senter PLLC

"Click to Cancel" Rule Vacated Ahead of July 14th Deadline

Lerman Senter PLLC on

Just days before the “Click to Cancel” negative option rule was to go into effect, the Eight Circuit Court of Appeals vacated the rule in its entirety. As explained in our previous alert, the rule, which would have gone into...more

Winstead PC

8th Circuit Vacates FTC’s “Click to Cancel Rule”

Winstead PC on

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

Hudson Cook, LLP

Eighth Circuit Vacates FTC's Negative Option Rule

Hudson Cook, LLP on

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

Womble Bond Dickinson

FTC’s Click to Cancel Rule is Vacated, But Remember It Was Not Alone

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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

Venable LLP

Eighth Circuit Cancels FTC Negative Option Rule: What Does It Mean?

Venable LLP on

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

Loeb & Loeb LLP

The FTC's "Click to Cancel" Rule Has Been...Canceled

Loeb & Loeb LLP on

The U.S. Court of Appeals for the Eighth Circuit vacated the FTC's “click to cancel” rule which was set to take effect on July 14. According to the court, the FTC erred in its rulemaking process by failing to produce a...more

Morrison & Foerster LLP

A Hard Reset on 1033?: A Look at What’s Next for Open Banking

The financial services industry generally, and data aggregators specifically, have watched intently as the Trump administration has altered the course of the Consumer Financial Protection Bureau (CFPB or “Bureau”), in an...more

Troutman Pepper Locke

Update on FTC’s CARS Rule

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As of April 27, 2025, the Federal Trade Commission (FTC) had not filed a petition for a writ of certiorari to appeal the Fifth Circuit’s decision vacating the Combating Auto Retail Scams Trade Regulation Rule (CARS Rule). The...more

Nossaman LLP

District Court Vacates Lesser Prairie-Chicken 4(d) Rule

Nossaman LLP on

On March 29, 2025, the U.S. District Court for the Western District of Texas (District Court) vacated the Endangered Species Act (ESA) special 4(d) rule for the northern distinct population segment (DPS) of the lesser...more

Holland & Knight LLP

Fifth Circuit Strikes Down FTC's Auto Retail Scam Rule: Key Implications for Dealers

Holland & Knight LLP on

The U.S. Court of Appeals for the Fifth Circuit on Jan. 27, 2025, vacated the Federal Trade Commission's (FTC) Rule on Combating Auto Retail Scams (CARS Rule) before it could take effect, finding that the FTC failed to follow...more

Moritt Hock & Hamroff LLP

11th Circuit Vacates FCC’s TCPA 1:1 Consent Rule

In an eleventh-hour play, on January 24, 2025, the Eleventh Circuit issued a decision that vacated the Federal Communication Commission’s (FCC) One-to-One Consent Rule, which was all set to go into effect on January 27, 2025....more

Troutman Pepper Locke

Fifth Circuit Vacates FTC’s CARS Rule

Troutman Pepper Locke on

Yesterday, the U.S. Court of Appeals for the Fifth Circuit issued a significant opinion vacating the Federal Trade Commission’s (FTC) Combating Auto Retail Scams Trade Regulation Rule (CARS Rule). The decision came in...more

Vinson & Elkins LLP

Appeals Court Invalidates Key Parts of PHMSA’s 2022 Rulemaking on Natural Gas Safety

Vinson & Elkins LLP on

In a unanimous opinion, a panel of judges from the United States Court of Appeals for the District of Columbia Circuit (the “D.C. Circuit”) vacated four key aspects from a 2022 rulemaking by the Pipeline and Hazardous...more

Snell & Wilmer

D.C. Circuit Curbs Department of Transportation’s Pipeline Rules, Further Signaling an Everchanging Approach to the Administrative...

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Last week, the U.S. Court of Appeals for the District of Columbia Circuit vacated a series of regulations passed by the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA). The...more

Goodwin

Fifth Circuit Vacates the Private Funds Rules And Constrains the SEC’s Rulemaking Authority

Goodwin on

Yesterday, a three-judge panel of the U.S. Court of Appeals for the Fifth Circuit vacated the “Private Funds Rules,” which the Securities and Exchange Commission (the “SEC”) adopted on August 23, 2023. The opinion of the...more

Foley Hoag LLP

Fifth Circuit Vacates New Private Funds Rules

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In a 3-0 decision issued today, June 5, 2024, the Fifth Circuit Court of Appeals (the “Court”) vacated the new private funds rule adopted by the Securities and Exchange Commission (the “SEC”) on August 23, 2023 (the “Rule”)....more

Seward & Kissel LLP

Fifth Circuit Vacates the Private Fund Advisers Rules in their Entirety

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On June 5th, the United States Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) vacated the Securities and Exchange Commission’s (the “SEC”) final rule regarding the regulation of private fund advisers (the “Final...more

ArentFox Schiff

No More Surprise Medical Bills: Texas Court Again Vacates Arbitration Provisions of Surprise Billing Rule

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On February 6, 2023, health care providers scored a second significant victory when a federal court in Texas again vacated portions of the Biden Administration’s rules governing the arbitration procedures to resolve surprise...more

(ACOEL) | American College of Environmental...

How Safe is Your WOTUS Harbor?

In 2005 the Corps of Engineers adopted a Regulatory Guidance Letter (RGL) providing that an “approved jurisdictional determination” (AJD) “will remain valid for a period of five years, unless new information warrants revision...more

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