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
As pharmaceutical manufacturers, digital health companies and telehealth platforms continue to reshape the delivery of medications, DTC pharmacy models have emerged as a critical component of patient engagement and...more
Yes, as of January 1, 2026, distilleries will be permitted to ship spirits direct-to-consumer in California under the state’s groundbreaking new alcohol shipping law, Assembly Bill 1246, signed by Governor Gavin Newsom on...more
The first week of October 2025 marked a significant shift in U.S. drug pricing policy as the Trump administration unveiled a series of sweeping actions to deliver on his promise to lower drug prices. From President Trump’s...more
With the US Food and Drug Administration’s (FDA) September 9, 2025 announcement that it will increase its enforcement of the Federal Food, Drug, and Cosmetics Act (FFDCA), its rules governing direct-to-consumer (DTC)...more
On September 9, 2025, the U.S. Food and Drug Administration (“FDA”) Office of Prescription Drug Promotion (“OPDP”) issued numerous untitled letters as part of the agency’s wider attack on direct to consumer (“DTC”)...more
Earlier this month, the US Department of Health and Human Services (HHS) and US Food and Drug Administration (FDA) announced a nationwide crackdown on direct-to-consumer (DTC) drug advertisements....more
On September 16, 2025, the U.S. Food and Drug Administration (FDA) released more than 60 warning letters sent to specific pharmaceutical manufacturers, alleging misbranding of a particular drug through direct-to-consumer...more
FDA’s two-part strategy for reining in DTC advertisements involves greater enforcement combined with rulemaking to require more risk information in broadcast advertisements....more
Last week, the White House issued a memorandum directing the Secretary of Health and Human Services (HHS), Robert F. Kennedy Jr., to take “appropriate action to ensure transparency and accuracy in direct-to-consumer...more
On July 31, 2025, the White House released a fact sheet discussing additional steps taken by the Trump administration surrounding efforts towards lowering drug prices for Americans. ...more
Channeling Tracy Chapman’s 1988 hit, the Food and Drug Administration and the Department of Health & Human Services (“HHS”) are “talkin’ bout a revolution” in drug promotion. While many have described the latest actions as...more
he Food and Drug Administration (FDA) issued a press release on Sept. 9 announcing a “crackdown” on direct-to-consumer (DTC) pharmaceutical advertising and promising “sweeping reforms" in line with President Trump's same-day...more
FDA’s recent announcement that it is undertaking sweeping reforms and a major enforcement initiative targeting allegedly misleading direct-to-consumer (DTC) prescription drug advertising will have significant implications for...more
On September 9, 2025, the U.S. Food and Drug Administration (FDA) and Department of Health and Human Services (HHS) dropped a regulatory bombshell: the FDA issued approximately 100 cease-and-desist letters and thousands of...more
On September 9, 2025, the U.S. Food and Drug Administration (“FDA”) issued a Press Release announcing a “crackdown on deceptive drug advertising.” Concurrently, the U.S. Department of Health and Human Services (“HHS”)...more
The U.S. Food and Drug Administration (FDA) announced it is changing its approach to direct-to-consumer (DTC) drug advertisements after a directive from a White House Memo instructing FDA and HHS to “to ensure transparency...more
The U.S. Food and Drug Administration (FDA) recently published a warning letter (Warning Letter) targeting a dental laboratory after a lengthy inspection found that the dental laboratory's operations, which offer...more
Food Venture Financing Trends - Saudi Arabia-headquartered food tech startup Calo, specializing in direct-to-consumer meal subscription services, secured $39 million in a Series B extension, which will enable them to...more
On June 12, 2025, Senators Bernie Sanders (I-Vt.) and Angus King (I-Maine) introduced the End Prescription Drug Ads Now Act, with Senators Chris Murphy (D-Conn.), Peter Welch (D-Vt.), Jeff Merkley (D-Ore.), and Dick Durbin...more
President Trump’s highly publicized executive order 14297, titled “Delivering Most-Favored-Nation Prescription Drug Pricing to American Patients,” targets the discrepancy in drug pricing in the United States compared with...more
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
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
Direct-to-consumer (“DTC”) genetic testing companies are faced with more scrutiny than ever over their privacy practices, security practices, and data use policies. In December 2023, 23andMe experienced a data breach...more
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
On August 29, 2024, the U.S. Food and Drug Administration (FDA) Office of Prescription Drug Promotion (OPDP) issued an untitled letter to AbbVie, Inc. (AbbVie) regarding a promotional, direct-to-consumer (DTC) television...more