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Final Rules Unfair or Deceptive Trade Practices

Winstead PC

The Federal Trade Commission (FTC) Click-to-Cancel

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The Federal Trade Commission (“FTC”) has recently announced that the FTC’s Click to Cancel Rule (the “Rule”) has been postponed to July 14, 2025. Originally planned to become effective May 14, 2025, the Commission released...more

Snell & Wilmer

FTC Click-to-Cancel Rule Enforcement Delayed 60 Days to Enable Business Compliance

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Enforcement of the Federal Trade Commission (FTC) Click-to-Cancel Rule (Rule) has now been deferred to July 14, 2025. The FTC noted that enforcement of the Rule did not adequately consider the compliance burdens...more

Arnall Golden Gregory LLP

Unhidden Fees: FTC Mandates Upfront Disclosure of All Mandatory Fees in Live-Event Ticketing

The live entertainment industry should take note that the Federal Trade Commission (“FTC”) has finalized its Rule on Unfair or Deceptive Fees aimed at eliminating deceptive pricing practices in the live-event ticketing...more

Venable LLP

FTC Staff Issues Guidance Ahead of New Rule Targeting Deceptive Fees

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Last week, the Federal Trade Commission (FTC) published a set of Frequently Asked Questions (FAQ) aimed at helping businesses and consumers understand the agency’s Rule on Unfair or Deceptive Fees, which takes effect on May...more

Fox Rothschild LLP

FTC’s Unfair/Deceptive Fees Rule Takes Effect

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The Federal Trade Commission’s (FTC) Rule on Unfair or Deceptive Fees, 16 C.F.R. Part 464, is effective as of May 12, 2025. According to the FTC’s recent press release, the Rule “prohibits bait-and-switch pricing and other...more

Fenwick & West LLP

The FTC Rule on Unfair or Deceptive Fees: FAQs and Guidance

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On May 12, 2025, the Federal Trade Commission’s Rule on Unfair or Deceptive Fees will take effect. Under the rule, certain businesses must disclose all mandatory fees and the total price up front to limit bait-and-switch...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

Perkins Coie

FTC “Click-To-Cancel” Rule Goes Into Effect May 14

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Key Takeaways - - Beginning May 14, businesses offering "negative option features" can incur significant financial penalties for each violation of the FTC’s “click-to-cancel” rule. - The rule imposes obligations related to...more

Kelley Drye & Warren LLP

FTC Issues FAQs on Fees Rule, Affirms Rule to Become Effective Next Week

The FTC issued FAQs to answer common questions about its Rule on Unfair or Deceptive Fees and to provide a small entity compliance guide in connection with the Rule. The issuance of the FAQs affirms that the current FTC, led...more

Hudson Cook, LLP

Massachusetts Junk Fee Regulation Presents Challenges to Advertising of Bank Deposit Products

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In early March, nearly a year and a half after it was initially proposed, the Massachusetts Attorney General's Office finalized the Commonwealth's "junk fee" regulation (the "Final Rule") while simultaneously issuing a...more

BakerHostetler

FTC Files Brief Fully Supporting Its Click-to-Cancel Rule

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Just prior to the Federal Trade Commission’s (FTC or Commission) publication of its Click-to-Cancel Rule (the Rule) – which we wrote about in depth here – in the Federal Register, several trade associations filed petitions...more

Kelley Drye & Warren LLP

“Junk Fee” Legislative Roundup – 2025 Edition

2024 was an action-packed year for followers of federal and state laws and regulations governing the disclosure of fees, or so-called ​“junk fee” laws....more

Morgan Lewis

Massachusetts Attorney General Issues Expansive ‘Junk Fees Rule’

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The Attorney General of Massachusetts recently promulgated rules expanding the scope of its enforcement against alleged “junk fees,” including business practices for consumer subscriptions, renewals, and recurring charge...more

Foley Hoag LLP - State AG Insights

Massachusetts AG Issues Broad "Junk Fee" Regulations

On Monday, March 3, 2025, Massachusetts Attorney General Andrea Campbell finalized new regulations under the Massachusetts Consumer Protection Act, Chapter 93A, restricting the use of hidden or surprise fees at the end of a...more

Hudson Cook, LLP

New Massachusetts Business Rule Continues Recent Regulation of Rental Price Disclosures

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A rule governing Unfair and Deceptive Fees (940 CMR 38.00) published March 3 by the Massachusetts Attorney General sets new Total Price disclosure obligations in marketing and sales for a wide set of covered businesses,...more

Cozen O'Connor

States and Feds Continue Crackdown on Hidden Fees

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Massachusetts Attorney General Andrea Campbell has announced new consumer protection regulations targeting so-called “junk fees.” Effective September 2, 2025, the regulations require businesses to clearly and prominently...more

Venable LLP

FTC's "Click-to-Cancel" Rule Challenged by Industry in the Eighth Circuit

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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

BakerHostetler

5th Circuit Slams the Brakes on FTC’s CARS Rule

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There are generally two paths that the Federal Trade Commission (FTC) takes for rulemaking. First, there may be a specific statute that gives the FTC specific rulemaking authority, such as the Children’s Online Privacy...more

Hudson Cook, LLP

CFPB Bites of the Month - 2024 Annual Review - Debt Collection

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In this article, we share a timeline of our monthly "bites" for 2024 applicable to debt collection practices. Like 2023, the theme of 2024 was medical debt collection....more

Holland & Knight LLP

Fifth Circuit Strikes Down FTC's Auto Retail Scam Rule: Key Implications for Dealers

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The U.S. Court of Appeals for the Fifth Circuit on Jan. 27, 2025, vacated the Federal Trade Commission's (FTC) Rule on Combating Auto Retail Scams (CARS Rule) before it could take effect, finding that the FTC failed to follow...more

Ballard Spahr LLP

Fifth Circuit Court of Appeals strikes down FTC CARS Rule

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The Fifth Circuit Court of Appeals has struck down the FTC’s controversial CARS Rule, saying that the commission violated its own procedural rules by failing to issue an Advance Notice of Proposed Rulemaking (“ANPRM”) before...more

Alston & Bird

Flurry of FTC Action in the Final Days of the Khan FTC Precedes Transition to the Ferguson FTC

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Our Consumer Protection/FTC and Antitrust Teams highlight a spate of activity by the Federal Trade Commission (FTC) in its final days under the leadership of Lina Khan and offers a preview of what’s to come with Andrew...more

Venable LLP

The Fifth Circuit Slams the Brakes and Vacates FTC CARS Rule

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This week, the U.S. Court of Appeals for the Fifth Circuit vacated the Federal Trade Commission’s (FTC) Combatting Auto Retail Scams (CARS) rule....more

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Strikes Down FTC’s ‘Junk Fee’ Rule for Auto Dealers

On January 24, 2025, the Fifth Circuit Court of Appeals struck down an FTC rule aimed at curbing deceptive advertising and sales practices in the auto industry. The rule, which sought to prohibit certain “junk fees” and...more

Fenwick & West LLP

CLE Takeaways: The Risks and Rewards of Recurring Subscriptions

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For companies offering subscription-based services, the regulatory landscape is becoming increasingly complex, with recent updates to federal and state laws creating new compliance requirements that demand careful attention...more

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