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Final Rules › Enforcement Actions › Subscription Services

Loeb & Loeb LLP

60 More Days for Click to Cancel

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Take a quick breath—but just a short one—because late Friday, the Federal Trade Commission (FTC) decided (3-0) to push the compliance date of its Negative Option (or "Click to Cancel") Rule, a regulation designed to make...more

Cooley LLP

FTC Delays Enforcement of Amended Negative Option Rule

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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

DLA Piper

FTC Pauses “Click-to-Cancel” Rule Until July 14

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The Federal Trade Commission (FTC) announced on May 9, 2025 that it will delay full implementation of the amended Negative Option Rule and begin enforcing it on July 14, 2025....more

DLA Piper

FTC “Click-to-Cancel” Rule to Take Effect May 14

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In October 2024, the Federal Trade Commission (FTC) finalized significant updates to the Negative Option Rule, which are slated to take effect on May 14, 2025. A negative option is a contract term under which a buyer agrees...more

Latham & Watkins LLP

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

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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

Latham & Watkins LLP

Unpacking the FTC’s New Negative Option Rule, Its Legal Challenges, and Future Uncertainty

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The rule impacts both B2B and B2C subscription autorenewals and other negative option programs; however, significant legal challenges could impact the rule’s implementation....more

Morrison & Foerster LLP

The FTC’s Final “Click-to-Cancel” Rule Faces Legal and Political Hurdles

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The fate of the FTC’s long-awaited final “Click-to-Cancel” rule has become tangled in uncertainty as it faces numerous lawsuits and the new incoming presidential administration. In October, the FTC published its Final Rule...more

Hudson Cook, LLP

CFPB Bites of the Month - November 2024 - CFPB Take Me Home, Country Roads

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In this month's article, we share some of our top "bites" for the prior and current month covered during the November 2024 webinar....more

Benesch

A New Era of Auto-Renewal: A Closer Look at the New FTC and California Requirements

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It’s time to revisit automatic renewal compliance. With California amending its Automatic Renewal Law ("ARL") on September 24, 2024, and the Federal Trade Commission (“FTC”) finalizing its “Click-to-Cancel” Rule (“FTC Final...more

Bass, Berry & Sims PLC

FTC Releases “Click to Cancel” Rule

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On October 16, the Federal Trade Commission (FTC) released the final version of its Rule Concerning Recurring Subscriptions and Other Negative Option Programs (Rule), which requires sellers of products and services to receive...more

Perkins Coie

FTC Finalizes “Click To Cancel” Rule With Substantial Requirements for Recurring Subscription Programs

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The Federal Trade Commission (FTC) announced its final Negative Option Rule (the Rule)—which the FTC often refers to as the “Click to Cancel” rule—for automatically renewing subscriptions, free trials that convert to paid...more

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