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
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
In our last update on the Digital Markets Competition and Consumer Act (DMCC Act), we outlined some of the key consumer protection enhancements set to come into force in the UK. In particular, the DMCC Act sets out new rules...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
California Continues to Tighten and Expand Automatic Renewal Law with New Restrictions Taking Effect July 1, 2025 On September 24, 2024, Governor Gavin Newsom signed into law Assembly Bill No. 2863, which amends California’s...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
Automatic renewals continue to be a big priority for state regulators. When companies work to develop strategies to comply with the growing patchwork of specific state laws in this area, they often start by looking at...more
The Digital Markets, Competition and Consumers Act 2024 (DMCCA) has recently received royal assent, following the announcement of the July General Election. We examine the key developments in our previous article. One very...more
During the last several years, many states have adopted automatic renewal contract, or ARC, laws for the protection of consumers, driven in large part by new subscription-based contracts sold in digital distribution and...more
It’s that time of year again. Regardless of what you call them—subscriptions, negative option programs, automatic renewals, or continuous service offers—states are continuing to enact and enforce new laws with increasingly...more
Recently, the State of New York enacted SB 5941-B (the “Act”), which revises the general business law, focusing on the obligation of businesses to inform consumers about an impending automatic renewal or continuous service...more
On June 28, the Connecticut governor signed HB 5314 (the “Act”), enacting measures relating to automatic renewal offers and consumer agreements. The Act, among other things, includes newly defined terms such as “automatic...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
Earlier this week, we posted that a plaintiff filed a proposed class action against the NFL over its automatic renewal practices. The complaint alleges that the NFL used “dark patterns” to enroll consumers in its NFL+...more
Last week, a plaintiff filed a proposed class action against the NFL over its automatic renewal practices. The plaintiff alleges that the company used deceptive practices to automatically subscribe its Game Pass users to a...more
Amendments to California’s automatic renewal law (ARL) enacted in October 2021 go into effect today, July 1, 2022. The amendments add enhanced procedural requirements related to the cancellation of subscription-based products...more
Subscription service providers should be aware of the various changes coming to California's automatic renewal law. California’s already stringent laws governing recurring subscription programs are about to become even more...more
The first half of 2022 saw significant activity affecting the state automatic renewal laws (ARLs) that regulate continuing or renewing contracts: • Lawsuits were filed against prominent companies such as Amazon and...more
Businesses with automatic renewal contracts—including subscriptions—should take note of Colorado’s new law that went into effect earlier this year on January 1, 2022. While companies subject to other state’s auto-renewal...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
In a case of first impression, the California Court of Appeal, Fourth District (San Diego), considered "under what circumstances a 'sign-in wrap' agreement … is valid and enforceable" between consumers and online companies...more
Colorado and Delaware have enacted new laws for automatic renewal or negative options offers. The new laws became effective January 1, 2022. Illinois already has a law on the books related to automatic renewals but has...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
In 2017, California updated its automatic renewal law to create some of the strictest requirements in the country. Now, just four years later, the Governor Newsom signed a new law that will impose even stricter requirements....more
Automatically renewing contracts — which have become increasingly popular for the convenient, uninterrupted delivery of goods and services they provide — continue to be targeted by state legislatures concerned about...more
Automatically renewing contracts have become increasingly popular with both businesses and consumers due to their convenient, consistent delivery of a wide range of goods and services. But concerns about allegedly unexpected...more