FTC to Increase Enforcement of Deceptive Tactics to Trick Consumers into Unwanted Subscription Renewals

Cozen O'Connor
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Cozen O'Connor

  • In response to rising complaints of financial harms, The Federal Trade Commission (“FTC”) issued a new enforcement policy (“Policy”) statement to help combat negative option marketing where consumers are deceptively signed up for products and services resulting in unauthorized charges and ongoing billing that is difficult to cancel.
  • The Policy outlines three key requirements companies must adhere to or face potential law enforcement action: disclosing terms of the product or service clearly and conspicuously; obtaining the consumer’s express informed consent before charging; and providing easy and simple cancellations.

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