News & Analysis as of

Consumer Contracts Automatic Renewals

Venable LLP

Subscription Sellers Take Note: New Tariffs Could Hit You Hard and Require You to Notify Customers

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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

Vedder Price

An Offer You Can’t Refuse: The FTC’s New “Click-to-Cancel” Rule

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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

Faegre Drinker Biddle & Reath LLP

New Year, New Regulations: 2025 Brings Significant Developments to Federal and State Automatic Renewal Laws

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

Katten Muchin Rosenman LLP

Unsubscribe: What the FTC's "Click-to-Cancel" Rule Means for Retailers and Consumers - The Katten Kattwalk/Kattison Avenue | Issue...

A curated seasonal wardrobe delivered directly to your door, the return to a jam-packed gym, personally proportioned fresh weekly meals, a coffeemaker and a new pair of sneakers shipped within an hour, or a trial run on the...more

Venable LLP

Are Hyperlinked Disclosures "Clear and Conspicuous"? Yes, in some cases, according to the FTC's Final Negative Option Rule - A...

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The Federal Trade Commission's Final Negative Option Rule ("Click to Cancel Rule") contains stringent new requirements for negative option programs, making it even more difficult to run compliant negative option offers....more

Cooley LLP

Government Reveals New Proposals for Incoming Subscription Contracts Regime Under DMCC Act

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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

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: A Look at the FTC’s Click-to-Cancel Rule, with James Kohm, Associate Director of...

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Today’s podcast features James Kohm, the Associate Director for the Enforcement Division of the Federal Trade Commission’s Bureau of Consumer Protection. We discuss the FTC’s “Click-to-Cancel” Rule (consisting of significant...more

Sheppard Mullin Richter & Hampton LLP

Renewal Revolution: Compliance With FTC’s “Click to Cancel” Rule

On October 16, 2024, the Federal Trade Commission (FTC) issued a new rule, referred to as the “Click to Cancel” rule, which is intended to make it easier for consumers to cancel recurring subscriptions and memberships....more

Kelley Drye & Warren LLP

With Uncertainty Surrounding the FTC’s Negative Option Rule, New California Requirements Wait in the Wings

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Last Friday, the FTC’s final Negative Option Rule was published in the Federal Register, starting the clock on the effective dates for the agency’s expansive overhaul of requirements related to goods or services sold through...more

Womble Bond Dickinson

New Click-to-Cancel Requirements… Welcome/Not Welcome?

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The Federal Trade Commission (FTC) announced its long-awaited final Negative Option Rule (the “Rule”) on October 16, 2024. “Negative Options” according to the FTC are arrangements “under which the consumer’s silence or...more

DLA Piper

Preparing for (More) Updates to California’s Automatic Renewal Law

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California has passed additional amendments to its Automatic Renewal Law (ARL), which will further strengthen that law’s already stringent requirements and likely present increased class action risk....more

Lathrop GPM

New Click-To-Cancel FTC Rule Carries New Rules, Hefty Penalties for Violations

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Attention, any companies that sell direct to consumers: the FTC has announced a new final rule requiring businesses to make it easier for consumers to opt-out and cancel subscriptions. Businesses will have 180 days to comply...more

Holland & Knight LLP

The New Cancel Culture: The FTC's "Click to Cancel" Rule

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The Federal Trade Commission (FTC) has made several amendments to the prior Negative Option Rule (Rule) that alter how subscription- and membership-based businesses will need to operate. This Holland & Knight alert summarizes...more

Katten Muchin Rosenman LLP

Cancel Culture - Kattison Avenue | Issue 13

The FTC's new rule makes it easier for consumers to cancel subscriptions and memberships they no longer want. The Federal Trade Commission (FTC) introduced a "click-to-cancel" rule on October 16, amending the 1973...more

Kilpatrick

The FTC takes a new swipe at autorenewal programs

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Use of California’s Auto Renewal Law as a predicate for UCL, FAL or CLRA claims has been a hotbed of consumer class action litigation. Now, the FTC has added a federal arrow to the consumer protection quiver by expanding its...more

BCLP

California, FTC Lead Push To Add Autorenewal Requirements

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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

Brownstein Hyatt Farber Schreck

FTC Finalizes “Click-to-Cancel” Rule Making It Easier for Consumers to Cancel Subscriptions

On Oct. 16, the Federal Trade Commission (FTC) voted 3-2 to finalize its “click-to-cancel” rule that will introduce new requirements to simplify the cancellation process for consumers wishing to terminate their subscriptions...more

Troutman Pepper Locke

FTC Adopts “Click-to-Cancel” Amendments to Its Negative Option Rule

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On October 16, the Federal Trade Commission announced final “click-to-cancel” amendments to its Negative Option Rule. Under the FTC’s amended Negative Option Rule...more

Morgan Lewis

FTC ‘Click-to-Cancel’ Rule Requires Canceling Recurring Charges to Be as Easy as Signing Up

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The Federal Trade Commission (FTC) recently issued its Final Rule requiring businesses subject to its authority to establish equivalency between the ease of signing up and canceling subscriptions, memberships, and other...more

Klein Moynihan Turco LLP

FTC Finalizes Subscription Renewal Rulemaking

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On October 16, 2024, the Federal Trade Commission (“FTC”) announced its final rules applicable to recurring subscription plans. According to the FTC, these rules were implemented to make it easier for consumers to stop paying...more

Kilpatrick

The FTC Expands its Negative Option Rule to Reach Autorenewal and Other Programs

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For companies who offer recurring subscriptions, it is important for them to understand the Federal Trade Commission’s recently finalized rule applicable to negative option marketing that requires such companies to make the...more

Orrick, Herrington & Sutcliffe LLP

FTC finalizes “Click-to-Cancel” Rule

On October 16, the FTC announced a final Negative Option Rule, also known as the “click-to-cancel” rule, requiring sellers to make it as easy for consumers to cancel their enrollment as it was to sign up for the goods or...more

Wiley Rein LLP

FTC Adopts Final “Click-to-Cancel” Rule with Requirements for Recurring Subscriptions

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On October 16, 2024, the Federal Trade Commission (FTC or Commission) announced its adoption of a final “click-to-cancel” Rule that regulates both sign-up and cancellation processes for subscriptions or other recurring...more

Hinch Newman LLP

FTC Announces Final “Click-to-Cancel” Recurring Subscriptions and Memberships Rule

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On October 16, 2024, the Federal Trade Commission announced a final “click-to-cancel” rule that will require sellers to make it as easy for consumers to cancel their enrollment as it was to sign-up. Most of the final rule’s...more

BakerHostetler

What the FTC’s New ‘Click-to-Cancel Rule’ Means for Your Business

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The Federal Trade Commission (FTC) finally released its long-awaited Negative Option Rule (the Final Rule), aka the “Click-to-Cancel Rule,” on October 16. The Final Rule was approved by a partisan vote of 3-2, with the two...more

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