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
Podcast - The FTC's Click to Cancel Proposal
Autorenewals Crossover Episode with The Crypto Exchange - The Consumer Finance Podcast
In the fall of 2024, California and the Federal Trade Commission (FTC) amended their respective auto-renewal regulations. The amendments detail new and largely parallel disclosure, consent, and cancellation requirements for...more
Late Friday, the FTC announced that the Commission had voted 3-0 to extend the compliance deadline for the to-be-effective provisions of the Negative Option Rule, formerly known as the “Click to Cancel Rule.” While the...more
Every company will be impacted by the new import tariffs, as they increase manufacturing costs. However, companies selling on an autorenewal basis could disproportionately feel the impact and should proceed with caution...more
On January 14, 2025, the first part of the Federal Trade Commission’s (“FTC”) update to the Negative Option Rule went into effect. Negative options are contract terms that allow a seller to interpret a customer’s silence or...more
The Greek philosopher Heraclitus is credited with the maxim, “The only constant in life is change.” Suffice it to say: automatic renewal laws (ARLs) are no exception. As subscriptions and memberships for goods and...more
If it’s been a while since you’ve looked at the state and federal laws governing autorenewals, subscriptions, and continuous service offers, your business is likely in need of an update. Multiple jurisdictions, on both state...more
This week, California amended its automatic renewal and continuous service offer law (ARL). Key provisions include the addition of “free-to-pay conversions,” consent obligations, misrepresentation prohibitions, request for...more
On Friday, the FTC announced what would ordinarily be an unremarkable enforcement action against a company for unsubstantiated earnings claims. The FTC alleges that WealthPress, an investment advice company purporting to...more
With several new state laws effective in 2022, it is becoming increasingly difficult for businesses to develop baseline compliance protocols across federal and state automatic renewal laws. Against this backdrop, federal...more
Subscription services face increased scrutiny from regulators, lawmakers and the plaintiffs’ bar. As we highlighted in a recent client alert, the FTC warned companies against using “dark patterns” in connection with paid...more
Automatic renewal clauses, or “evergreen clauses,” are a frequent occurrence in contracts of all kinds and are becoming increasingly prevalent as businesses transition from traditional methods of selling products and services...more