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Regulatory Requirements Cancellation Rights

Womble Bond Dickinson

FTC Defers Some Click-to-Cancel Rule Enforcement to July 14, 2025

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Companies with recurring payment programs with negative option terms now have until July 14, 2025, to bring their disclosure, consent, and cancellation practices into full compliance....more

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

Venable LLP

The FTC Defers Compliance Deadline for Updated Negative Option Rule to July 14 - A Fast VAST Update​​

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On Friday, ​the Federal Trade Commission voted to defer the compliance deadline for the amended Negative Option Rule by 60 days. The Commission issued a statement on the new deadline....more

Alston & Bird

FTC Delays Compliance Deadline for Click-to-Cancel Rule Until July 14, 2025

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Our Consumer Protection/FTC Team notes that the Federal Trade Commission extended the compliance deadline of the Negative Option Rule (better known as the Click-to-Cancel Rule) by 60 days....more

BakerHostetler

FTC Delays Enforcement of Negative Option Rule Until July 14

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The Federal Trade Commission (FTC) released a statement on May 9 deferring by 60 days its enforcement of certain provisions of the Negative Option Rule (the Rule). The bulk of the Rule’s requirements are now scheduled to go...more

Wiley Rein LLP

Is Your Company Prepared for the FTC’s May 14 “Click-to-Cancel” Compliance Deadline?

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A May 14, 2025 deadline is rapidly approaching for companies to comply with several of the most significant changes to the Federal Trade Commission’s (FTC) amended negative option rule, often called the “click-to-cancel”...more

Alston & Bird

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

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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

Subscription Sellers Take Note: New Tariffs Could Hit You Hard and Require You to Notify Customers

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Every company will be impacted by the new import tariffs, as they increase manufacturing costs. However, companies selling on an autorenewal basis could disproportionately feel the impact and should proceed with caution...more

DLA Piper

German Higher Courts Clarify Strict Requirements for Online Contract Cancellations

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In two recent decisions, the German Higher Regional Courts (Oberlandesgerichte – OLG) of Cologne and Munich have clarified the – strict – German requirements for cancellation buttons on websites of tech companies providing...more

Lowenstein Sandler LLP

FTC "Click-To-Cancel" Rule Coming Soon

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The Federal Trade Commission’s final “click-to-cancel” rule, which goes into effect on May 14, 2025, attempts to address the difficulties consumers may face when trying to cancel an automatically renewing subscription. The...more

Clark Hill PLC

FTC Finalizes Click-To-Cancel Rule

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The Federal Trade Commission (FTC) recently finalized and issued a new rule governing negative option features, like subscription or membership agreements with automatic renewal and recurring payment options. The rule,...more

Snell & Wilmer

FTC Click to Cancel Rule

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In 2023, the U.S. Federal Trade Commission (FTC) sought public comments on how to combat perceived unfair and deceptive trade practices, recurring subscription charges, and cancelation of such plans. Born out of these...more

Arnall Golden Gregory LLP

Eighth Circuit Refuses to Stay Click-to-Cancel Rule

On January 17, 2025, the United States Court of Appeals for the Eighth Circuit denied a petition to administratively stay the effective date of the Federal Trade Commission’s controversial “Click-to-Cancel” Rule. A divided...more

Morris, Manning & Martin, LLP

FTC “Click to Cancel” Rule: What to Know Now

On October 16, 2024, the Federal Trade Commission (FTC) announced its final “Click to Cancel” Rule (the Rule) as a part of its ongoing review of its 1973 Negative Option Rule. The FTC revised the Rule to provide additional...more

Sheppard Mullin Richter & Hampton LLP

Click! FTC Updates Its Negative Option Rule

The FTC updated its Negative Option Rule last month and gave it a new name to emphasize the expanded scope of programs to which it applies. It will now be the “Rule Concerning Recurring Subscriptions and Other Negative Option...more

Morrison & Foerster LLP

The FTC Issues Final Rule on “Click-to-Cancel” and Negative Option Programs

After a multi-year process that was initiated in 2019, the U.S. Federal Trade Commission (FTC) has officially brought the 1973 Negative Option Rule into the 21st century, but not without opposition. The FTC has announced a...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

Holland & Knight LLP

The New Cancel Culture: The FTC's "Click to Cancel" Rule

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The Federal Trade Commission (FTC) has made several amendments to the prior Negative Option Rule (Rule) that alter how subscription- and membership-based businesses will need to operate. This Holland & Knight alert summarizes...more

Moritt Hock & Hamroff LLP

FTC’s Final ‘Click to Cancel’ Rule on Negative Option Programs: What You Need to Know

On October 16, 2024, the Federal Trade Commission (FTC) announced its Final Rule revising its Negative Option Rule, now known as the Rule Concerning Recurring Subscriptions and Other Negative Option Programs (the Rule). The...more

Troutman Pepper Locke

Lawsuit Filed Challenging FTC’s Final Negative Option Rule

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Earlier this week, we discussed the Federal Trade Commission’s (FTC) final amendments to the Negative Option Rule, now retitled the Rule Concerning Recurring Subscriptions and Other Negative Option Programs. These amendments,...more

Polsinelli

FTC’s “Click-to-Cancel” Rule on Subscriptions and Renewals

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What’s Happening? On October 16, 2024, the Federal Trade Commission (“FTC”) finalized a rule that, once effective, requires businesses to provide their customers with an easy method of cancelling or terminating “negative...more

Troutman Pepper Locke

FTC Finalizes Amendments to Negative Option Rule

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In March 2023, we discussed the Federal Trade Commission’s (FTC) Notice of Proposed Rulemaking (NPRM) aimed at making it easier for consumers to cancel recurring subscriptions and memberships. The proposed rule was part of...more

Sheppard Mullin Richter & Hampton LLP

CFPB: Negative Option Marketing Practices May Violate CFPA

On January 19, the CFPB issued Circular 2023-01 to affirm that companies offering “negative option” subscription services are required to comply with federal consumer financial protection laws. According to the Circular,...more

Akerman LLP

Amendments to California’s Automatic Renewal Law Take Effect

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Amendments to California’s automatic renewal law (ARL) enacted in October 2021 go into effect today, July 1, 2022. The amendments add enhanced procedural requirements related to the cancellation of subscription-based products...more

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