Podcast - The Digital Marketplace: The FTC's Focus on Fair Online Transactions
Driving New Standards With California's CARS Rule — Moving the Metal: The Auto Finance Podcast
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
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
Eight months after the Eighth Circuit vacated the FTC’s 2024 “Click to Cancel” Rule, the Commission is starting over by issuing a new Advance Notice of Proposed Rulemaking (“ANPRM”) this week that seeks public comment on...more
Twenty-one states and the District of Columbia have joined an FTC enforcement lawsuit against a major rideshare and food delivery company over its subscription and cancellation practices. The allegations center on the...more
While much focus has recently been paid to the Massachusetts Attorney General's "junk fee" regulation, which includes newly effective negative option requirements, focus on automatic renewal cancellation policies remains a...more
On September 25, 2025, the Federal Trade Commission announced it had reached a settlement with Amazon.com, Inc. and two company executives, resolving allegations that the company’s enrollment and cancellation processes for...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
Despite the demise of the Federal Trade Commission's (FTC) "Click to Cancel" Rule in July 2025, the FTC continues to actively define new standards for lawful subscription practices. The FTC's recent lawsuits and settlements...more
On September 15, the FTC announced it had filed a complaint in the U.S. District Court for the Northern District of California along with a proposed order for permanent injunction and monetary judgment against an educational...more
The Federal Trade Commission (“FTC”) has increased its campaign against businesses that impose unreasonable barriers to consumer cancellation of memberships and subscriptions. Recent actions demonstrate the agency’s intent to...more
The Federal Trade Commission (FTC) has filed a complaint in the Central District of California against Fitness International, LLC and Fitness & Sports Clubs, LLC (together, LA Fitness), alleging unfair and deceptive practices...more
The FTC has sued Fitness International, LLC and Fitness & Sports Clubs, LLC—the operators of “LA Fitness”—alleging that the gyms have made it extremely difficult for consumers to cancel memberships and recurring charges in...more
On August 12, the Federal Trade Commission (FTC) ordered Match Group, owners and operators of online dating platforms such as Match.com, OkCupid, PlentyOfFish, The League, and others, to pay $14 million. This settlement...more
On August 20, 2025, the FTC filed a complaint in the U.S. District Court for the Central District of California, alleging that the Gym violated the FTC Act and the Restore Online Shoppers' Confidence Act (ROSCA). The FTC's...more
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
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
On the metaphorical eve of the July 14 effective date for the FTC’s Negative Option Rule, the Eighth Circuit released an opinion Tuesday vacating the Rule in its entirety. The economy-wide notice, consent, cancellation, and...more
Federal officials just postponed enforcement of the Click-to-Cancel rule, which requires businesses offering subscriptions or memberships to provide a cancellation process as straightforward as the sign-up procedure. The...more
On April 21, 2025, the Federal Trade Commission (FTC) announced that it had filed a complaint against Uber Technologies, Inc. and Uber USA LLC (collectively, Uber), a rideshare and delivery company. Among other things, the...more
This week, the Federal Trade Commission (FTC) filed a lawsuit in federal court against rideshare and delivery company Uber for allegedly deceptive subscription practices, including making it unreasonably difficult to cancel....more
Last week, a security services company and several trade groups filed their merits brief in the U.S. Court of Appeals for the Eighth Circuit challenging the Federal Trade Commission’s (FTC) newly adopted Negative Option Rule,...more
Last Friday in a 2-1 order, the Eighth Circuit Court of Appeals rejected an initial challenge to the Federal Trade Commission’s (FTC) Negative Option Rule. The challengers had asked the court to stay the Rule from taking...more
This week, the Federal Trade Commission (FTC) and the Illinois attorney general announced a settlement with Grubhub Inc. to resolve allegations that the company engaged in an array of unfair and deceptive practices that...more
Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more
Last week, the FTC, by a 3-2 vote along party lines, adopted its click-to-cancel rule, which purports to make it easier to cancel gym memberships, streaming services, and the like. [We wrote about it here.] The final rule...more
On October 16, 2024, the Federal Trade Commission (FTC) finalized significant updates to the Negative Option Rule. The amendments to the rule, now titled the “Rule Concerning Recurring Subscriptions and Other Negative Option...more