News & Analysis as of

Disclosure Requirements Automatic Renewals Negative Option Rule

Paul Hastings LLP

Updated California and FTC Auto-Renewal Regulations Take Effect

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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

Cooley LLP

FTC Delays Enforcement of Amended Negative Option Rule

Cooley LLP on

On May 9, the Federal Trade Commission (FTC) voted unanimously to delay enforcement of most portions of its amended Negative Option Rule (rule) by 60 days, shifting the compliance deadline for these portions from May 14 to...more

Kelley Drye & Warren LLP

FTC Extends Compliance Deadline for Negative Option or ​“Click to Cancel” Rule, but Indicates Intent to Enforce as Written in July

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

Latham & Watkins LLP

FTC’s Click-to-Cancel Rule to Take Effect on May 14, 2025, Despite Litigation

Latham & Watkins LLP on

Companies with B2C or B2B recurring payment programs that include negative option terms should review their disclosure, consent, and cancellation practices to ensure compliance with the rule....more

Alston & Bird

Cancellation Practices Back in the Spotlight as Click-to-Cancel Rule Looms

Alston & Bird on

Our Consumer Protection/FTC Group investigates the implications of a Federal Trade Commission complaint against Uber alleging deceptive billing and cancellation practices under the Restore Online Shoppers’ Confidence Act...more

Venable LLP

FTC Makes Clear It Will Continue Regulating Subscription Services and Signals Enforcement Priority for Negative Option Rule in...

Venable LLP on

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

Venable LLP

Negative Option and Continuity Marketing

Venable LLP on

The Federal Trade Commission, state attorneys general, and class action plaintiffs continue to scrutinize negative option and continuity offers, including automatic renewals, free-to-pay conversions, and continuity programs....more

Vedder Price

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

Vedder Price on

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

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