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Proposed Rules Marketing

Vedder Price

SEC Provides Helpful Marketing Rule FAQ Guidance

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On March 19, 2025, the Securities and Exchange Commission (“SEC”) updated its frequently asked questions (FAQs) relating to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Marketing Rule”). The new FAQs permit...more

Davis Wright Tremaine LLP

Stay ADvised: 2025, Issue 3

FTC's Final Junk Fees Rule Narrowed in Scope - On December 17, 2024, the Federal Trade Commission (FTC) released its final Rule on Unfair or Deceptive Fees, commonly known as the "Junk Fees Rule." This final rule has a...more

Klein Moynihan Turco LLP

FTC Takes Aim at Deceptive Earnings Claims

This week, the Federal Trade Commission (“FTC”) proposed changes to the Business Opportunity Rule, together with the possible enactment of a new Earnings Claim Rule. Due to the increasing number of individuals seeking...more

Kelley Drye & Warren LLP

FTC Puts Pedal to the Metal to Release Proposed Rule on MLM Earnings Claims, Changes to Business Opportunity Rule—but Republican...

The FTC released two Notices of Proposed Rulemaking (NPR) and an Advance Notice of Proposed Rulemaking (ANPR) that would establish a new Earnings Claims Rule and expand the existing Business Opportunity Rule – changes that...more

Bass, Berry & Sims PLC

CMS CY 2026 Parts C and D Proposals Focus on Informed Choice

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On December 10, the Centers for Medicare & Medicaid Services (CMS) published a proposed rule, which, if finalized as proposed, has potentially significant implications for Medicare Advantage (MA) plans and Medicare...more

Ropes & Gray LLP

CMS Proposes Beneficiary Protection and Marketing Updates for Medicare Advantage and Part D Plans in 2026

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On November 26, 2024, Centers for Medicare & Medicaid Services (“CMS”) released a proposed rule revising the Medicare Advantage (“MA”) Program (Part C), Medicare Prescription Drug Benefit Program (Part D), Medicare Cost Plan...more

Ballard Spahr LLP

FTC Issues Final Rule to Fight Fake Product Reviews

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The Federal Trade Commission on August 14 announced a final trade regulation rule intended to fight fake reviews and testimonials by prohibiting their purchase or sale and by allowing the agency to seek civil penalties...more

Troutman Pepper Locke

2024 Mid-Year Review: State AGs Shaping Regulatory Landscapes

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In 2024, the landscape of state attorneys general (AGs) is poised for significant change, with numerous elections and regulatory actions reshaping priorities and enforcement strategies. This dynamic environment reflects the...more

Holland & Knight LLP

Fake It Until You Make It: FTC Targets Fake Reviews and Testimonials

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Consumers often research a product or service before they make a purchase. Now more than ever, consumers rely on the reviews and testimonials they see online. This creates a breeding ground for deception. Enter the Federal...more

Troutman Pepper Locke

FTC to Hold Hearing on Proposed Rule to Ban Fake Reviews

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Most products with an online marketing presence generally have “customer reviews.” However, today’s consumers cannot always trust that those reviews are from real purchasers or provide honest feedback about the quality of a...more

BakerHostetler

AD-ttorneys@law - December 2023 #2

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Back in June, we mentioned how politicians were hopping on the Joe Biden bandwagon when it came to a pre-2016 political throwback issue: junk fees. Biden highlighted it in his State of The Union address in February, and...more

Benesch

FCC Set to Upend Lead Generation Industry

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On November 22, 2023, the Federal Communications Commission (FCC) issued a proposed rule that will completely upend the landscape of lead generation and digital marketing for consumer retailers and sellers. The proposed rule...more

Lerman Senter PLLC

FTC Proposes Rule to Eliminate Fake Reviews

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The Federal Trade Commission has proposed a new rule that would make it illegal to post fake reviews and testimonials, suppress negative reviews, or pay for positive reviews....more

Ervin Cohen & Jessup LLP

FTC Proposes Ban on Fake Reviews and Testimonials

On June 30, 2023, the Federal Trade Commission (“FTC”) announced that it would be publishing a notice of proposed rulemaking on the use of consumer reviews and testimonials. The proposed rule follows FTC’s November 2022...more

BCLP

The Best Legal Review of the FTC’s Regulatory Review of Consumer Reviews

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As we drifted into the July 4 weekend, the FTC set off some fireworks with the publication of its long-awaited updates to the Endorsement Guides and its corresponding FAQs, and it followed up on last year’s advance notice of...more

Davis Wright Tremaine LLP

In a One, Two, Three Punch, the FTC Issues Updated Endorsement Guides

The lead-up to the July Fourth holiday was a busy time for endorsement and testimonial watchers—the FTC issued (i) its final, updated Guides to the Use of Endorsements and Testimonials in Advertising, (ii) an updated version...more

Venable LLP

FTC Finalizes Updated Endorsement and Testimonial Guides

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Thirteen months after proposing sweeping changes to its Endorsements and Testimonial Guides (Guides), the Federal Trade Commission (FTC) has finalized its revised guidelines and released an updated set of FAQs to help guide...more

BakerHostetler

FTC Revises Endorsement and Testimonial Guides

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As we have written several times, the FTC has a lot on its plate with respect to rulemaking and proposed revisions to existing Guides. But that load just got a tad bit lighter, as the FTC released its revisions to the...more

Troutman Pepper Locke

Bipartisan State AGs Support FTC’s Amendments to Negative Option Rule

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The New York and Pennsylvania state attorneys general recently led a bipartisan coalition of 26 state AGs in a letter, supporting the Federal Trade Commission (FTC)’s proposed rule amending the Negative Option Rule....more

Ballard Spahr LLP

FTC action against Amazon targets alleged use of digital dark patterns as unfair to consumers

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Last week, the FTC filed a civil case against Amazon alleging that the company used “dark patterns” to enroll people in its Prime program. The case continues a pattern initiated by FTC Chair Lina Khan of challenging...more

Venable LLP

The FTC's Proposed "Rule Concerning Recurring Subscriptions and Negative Options": Improving Regulations or Interfering with...

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Payment service providers should take note of an expansive new rule proposed by the Federal Trade Commission (FTC) intended to protect consumer shoppers of goods and services sold on a subscription basis. For merchants...more

Venable LLP

Click to Cancel: FTC Proposes New Rule Regulating Subscription Services and Negative Option Programs with Broad Implications

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Last week, the Federal Trade Commission announced that its proposed rule replacing its Prenotification Negative Option Rule would result in new, expansive requirements for all forms of negative option offers, including...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

Kelley Drye & Warren LLP

FTC Proposes Massive Expansion of Negative Option Rule; Would Provide Redress and Civil Penalty Authority for Deceptive Practices...

If you’re offering any products or services involving a negative option or automatic renewal plan, pay close attention to the FTC’s announcement today of a proposed rule that would drastically alter requirements for negative...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2023

Federal Reserve Policy Aims to Level the Playing Field for Insured and Uninsured Banks: The Federal Reserve has issued a policy statement clarifying that uninsured state member banks will be subject to the same limitations...more

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