12 Days of Regulatory Insights: Day 10 – State AGs on Pricing and Renewals — Regulatory Oversight Podcast
A January 2026 decision from the U.S. District Court for the Southern District of New York held that an auto-extension clause in a letter of credit did not create an evergreen instrument (resulting in the letter of credit’s...more
Use cases for letters of credit (LOCs) in the re/insurance industry are familiar to many. Even in an era when more than 100 non-US re/insurers hold reciprocal re/insurer status and presumably face fewer calls by US cedents...more
Key Takeaways - The Federal Trade Commission (“FTC”) restarts negative option rulemaking after the court vacated the 2024 rule. The agency’s March 2026 Advance Notice of Proposed Rulemaking (“ANPRM”) has placed a renewed...more
On March 11, the Federal Trade Commission (FTC) issued a new Advance Notice of Proposed Rulemaking (ANPRM) to revisit its Rule Concerning the Use of Prenotification Negative Option Plans. The move follows the Eighth Circuit’s...more
The Federal Trade Commission (FTC) has signaled its interest in making another attempt to update its rule imposing disclosure and other requirements on subscriptions and auto-renewals. ...more
In this episode of our special 12 Days of Regulatory Insights podcast series, RISE attorney Nam Kang welcomes Partners Clay Friedman and Mike Yaghi for a practical look at 2025 regulatory enforcement trends in advertising and...more
The Department of Homeland Security (DHS) announced on Oct. 29, 2025, it is ending the practice of USCIS automatically extending validity of employment authorization documents (EADs) of foreign nationals who have timely filed...more
On September 25, 2025, Amazon agreed to pay $2.5 billion to settle claims brought by the Federal Trade Commission (FTC) alleging that the company misled consumers into signing up for Prime memberships and made it difficult...more
When the FTC’s “Click to Cancel” Rule (otherwise known as the revised Negative Option Rule), was in litigation in July 2025, we predicted the FTC was likely to instead focus on enforcing the Restore Online Shoppers Confidence...more
Massachusetts Attorney General (AG) Andrea Joy Campbell has issued guidelines to help businesses comply with the recently enacted consumer protection regulations, prohibiting “junk fees” and providing consumers with greater...more
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
Recent enforcement actions underscore the growing risks for businesses with automatically renewing subscriptions. In June 2025, New York Attorney General Letitia James announced a $600,000 settlement with fitness company...more
On July 1, California's amended autorenewal law takes effect, and the Federal Trade Commission's (FTC) updated enforcement deadline for the primary requirements of the updated Negative Option Rule (so-called Click to Cancel...more
As July prepares to descend upon us, the swirl regarding the impending legal requirements for properly offering and administering autorenewing subscriptions has become downright maddening – which rules will apply? How can I...more
Take a quick breath—but just a short one—because late Friday, the Federal Trade Commission (FTC) decided (3-0) to push the compliance date of its Negative Option (or "Click to Cancel") Rule, a regulation designed to make...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
Key Takeaways - - Beginning May 14, businesses offering "negative option features" can incur significant financial penalties for each violation of the FTC’s “click-to-cancel” rule. - The rule imposes obligations related to...more
A May 14, 2025 deadline is rapidly approaching for companies to comply with several of the most significant changes to the Federal Trade Commission’s (FTC) amended negative option rule, often called the “click-to-cancel”...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
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
A recent Ninth Circuit decision, Chabolla v. ClassPass, Inc., underscores critical considerations for retailers with online Terms of Service / Use agreements, particularly regarding arbitration provisions and related consumer...more
Massachusetts Attorney General (AG) Andrea Joy Campbell announced Massachusetts’ new consumer protection regulations prohibiting “junk fees” and providing consumers with greater transparency regarding trial and subscription...more
Venable's AdLaw Symposium is back! Please join us in our Washington, DC, headquarters for this highly anticipated event focused on providing you with the information you need to promote your brand with confidence....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