News & Analysis as of

Notice of Proposed Rulemaking (NOPR) Proposed Rules Subscription Services

Perkins Coie

FTC Proposes Rulemaking for Recurring Subscription Programs

Perkins Coie on

The Federal Trade Commission (FTC) recently announced a notice of proposed rulemaking to expand its “Negative Option Rule” to apply to all recurring subscription programs (Proposed Amendment). The Proposed Amendment would...more

Hinch Newman LLP

FTC Compliance Attorney Discusses Agency’s Dramatic Proposed Updates to Recurring Subscriptions and Memberships

Hinch Newman LLP on

The Federal Trade Commission recently announced a proposed a “click to cancel” provision requiring sellers to make it as simple for consumers to cancel their enrollment as it was to enroll. According to the FTC, if...more

Morgan Lewis

FTC Makes It Easier to Say No with Proposed Rule to Limit Negative Option Marketing

Morgan Lewis on

The US Federal Trade Commission (FTC or Commission) proposes expanding the Negative Option Rule to all subscription agreements. The FTC, in a 3-1 vote with Commissioner Christine S. Wilson (R) dissenting, published a notice...more

Sheppard Mullin Richter & Hampton LLP

FTC Increases Scrutiny of Negative Option Marketing

Retailers and service providers should take note: the Federal Trade Commission (FTC) is increasing its scrutiny of negative option marketing activity to combat unfair or deceptive practices related to subscriptions,...more

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