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ROSCA Unfair or Deceptive Trade Practices Federal Trade Commission (FTC)

Arnall Golden Gregory LLP

FTC Enforcement Priorities: What the Agency’s Actions Reveal About 2026 Risk

Key Takeaways - FTC enforcement in 2026 is concentrated on subscription practices, telemarketing, earnings claims, and auto-renewal models, with ROSCA, TSR, and the Business Opportunity Rule driving significant civil penalty...more

Benesch

FTC Enforcement Trends In 2026: What Businesses, Advertisers Should Be Watching Now

Benesch on

Regulators continue to signal a return to core consumer‑friendly principles through new rulemaking initiatives, and recent enforcement activity, warning letters, and public commentary offer a practical preview of where...more

Venable LLP

[Webinar] How Subscription Offers Have Become One of the Hottest Areas of Challenge in 2026 - February 26th, 2:00 pm - 3:00 pm ET

Venable LLP on

No company wants a lawsuit or civil investigative demand over their autorenewal practices. And settling a case for millions or billions of dollars is even worse. In 2025, negative options and subscription offers became one of...more

Goodwin

FTC’s “Click-to-Cancel” Rule Gets New Life As FTC’s Enforcement Wave Continues to Target Negative-Option Sellers

Goodwin on

The Federal Trade Commission (FTC) is increasingly directing both its enforcement and rulemaking efforts toward auto-renewal programs, with a particular focus on burdensome or opaque cancellation procedures. ...more

Hinshaw & Culbertson - Consumer Crossroads

Ask and You Shall Receive a Recurring Subscription: FTC Sues a Web Q&A Service for Deceptive Negative Option

Two weeks into the new year, the Federal Trade Commission (“FTC”) sued JustAnswer LLC and its CEO (together, “JustAnswer”), alleging they deceived consumers into enrolling in monthly recurring subscriptions without obtaining...more

Hinch Newman LLP

How Does the FTC Calculate Monetary Civil Penalties for Rule Violations?

Hinch Newman LLP on

The Federal Trade Commission generally seeks monetary civil penalties when it is alleging violations of rules that the agency enforces, such as the Made in USA Labeling Rule, the Restore Online Shoppers’ Confidence Act and...more

Troutman Pepper Locke

FTC Sues JustAnswer Over Allegedly Deceptive Subscription Practices

Troutman Pepper Locke on

The Federal Trade Commission (FTC) has sued JustAnswer LLC and its founder and CEO, Andrew Kurtzig, alleging that the online Q&A platform deceives consumers into costly recurring subscriptions without their informed consent,...more

Venable LLP

FTC Lawsuit Targets JustAnswer for Alleged ROSCA and Subscription Disclosure Violations

Venable LLP on

Last week, the Federal Trade Commission (FTC) filed a lawsuit in federal court against JustAnswer LLC and its CEO, arising from the company’s subscription program. According to the complaint, JustAnswer operates an online...more

BakerHostetler

Wondering if the FTC Is Moving Away from ROSCA Enforcement? We Have Our (Just)Answer.

BakerHostetler on

Although many New Year’s resolutions lose momentum by February (guilty!), the FTC’s commitment to Restore Online Shoppers’ Confidence Act (ROSCA) enforcement shows no signs of slowing....more

Hudson Cook, LLP

CFS Bites of the Month - 2025 Annual Review - Automatic Renewals, Click-to-Cancel, and Subscriptions

Hudson Cook, LLP on

In this article, we share a timeline of monthly "bites" for 2025 applicable to automatic renewal, click to cancel, lease to own, and subscription transactions. The CFPB spent 2025 walking back much of the guidance and actions...more

Wiley Rein LLP

Wiley Consumer Protection Download (January 6, 2026)

Wiley Rein LLP on

Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Federal Trade Commission (FTC), the Consumer Financial Protection Bureau (CFPB), and the state level. Check out our new State...more

Hudson Cook, LLP

State Attorneys General Join FTC Suit Against Major Rideshare Company for "Cancel Anytime" Subscription Practices

Hudson Cook, LLP on

Twenty-one states and the District of Columbia have joined an FTC enforcement lawsuit against a major rideshare and food delivery company over its subscription and cancellation practices. The allegations center on the...more

Wiley Rein LLP

Wiley Consumer Protection Download (December 16, 2025)

Wiley Rein LLP on

Bipartisan Group of 42 AGs Send Letter to Technology Companies Regarding AI Chatbot Features. On December 9, the National Association for Attorneys General (NAAG) sent a letter, signed by 42 Attorneys General (AGs), to...more

Troutman Pepper Locke

12 Days of Regulatory Insights: Day 10 – State AGs on Pricing and Renewals — Regulatory Oversight Podcast

Troutman Pepper Locke on

In this episode of our special 12 Days of Regulatory Insights podcast series, RISE attorney Nam Kang welcomes Partners Clay Friedman and Mike Yaghi for a practical look at 2025 regulatory enforcement trends in advertising and...more

Kelley Drye & Warren LLP

FTC Quietly Reopens Click to Cancel Rulemaking in Response to Petition

In July, the Eighth Circuit vacated the FTC’s “Click to Cancel Rule.” Since then, the FTC has continued to challenge cancellation practices under other authority....more

Venable LLP

FTC’s Melissa Holyoak Outlines Consumer Protection Focus at ANA Advertising Law Conference

Venable LLP on

In her remarks at this year’s ANA Masters of Advertising Law Conference, Commissioner Melissa Holyoak of the Federal Trade Commission (FTC) emphasized three areas where the agency is focusing its consumer protection...more

Orrick, Herrington & Sutcliffe LLP

Amazon Ruling Marks New Era of Personal Liability for Execs

A Sept. 17 summary judgment decision in Federal Trade Commission v. Amazon.com Inc. from the U.S. District Court for the Western District of Washington, in finding that two Amazon executives could be personally liable for...more

Hudson Cook, LLP

FTC's Consumer Finance Pivot Brings Industry Pros And Cons

Hudson Cook, LLP on

The first nine months of the new Trump administration have dramatically affected the regulation and oversight of the consumer financial industry. The Consumer Financial Protection Bureau's new leadership moved swiftly to...more

Morrison & Foerster LLP - Social Media

Social Links: Darkness on the Edge of Town

The Federal Trade Commission (FTC) has made clear that youth-focused social apps are a priority. On September 27, the FTC filed a complaint in the Central District of California against Iconic Hearts Holdings, the company...more

Perkins Coie

Lessons From the FTC’s First Privacy Enforcement Actions During Trump 2.0

Perkins Coie on

The Federal Trade Commission (FTC) recently announced its first privacy enforcement actions of the second Trump administration with a flurry of activity in September....more

Alston & Bird

FTC Reaches Record $2.5 Billion Settlement with Amazon over Prime Subscription Practices

Alston & Bird on

The Federal Trade Commission (FTC) reached a $2.5 billion settlement with Amazon over its Prime membership subscription and cancellation practices. Our Consumer Protection/FTC Team highlights what companies should know about...more

Katten Muchin Rosenman LLP

FTC’s Landmark $2.5 Billion Amazon Settlement Highlights Ongoing Focus on “Dark Patterns”

Updated 9/30/2025 - Three days into trial, Amazon agreed to pay $2.5 billion to settle a Federal Trade Commission lawsuit alleging that the company misled millions of consumers into subscribing to Amazon Prime and then...more

Stradling Yocca Carlson & Rauth

The Subscription Cancellation Gap: Clear State Rules, Vague Federal Standards, and Growing Legal Risk

Anyone who’s tried to cancel a gym membership, a digital subscription, or an auto-renewing trial knows the feeling: buried links, print-and-mail forms, long hold times. Some apps simply won’t let go....more

Loeb & Loeb LLP

FTC Scrutiny of Automatic Renewals: What Health & Wellness Companies Should Know

Loeb & Loeb LLP on

Earlier this summer, the Federal Trade Commission’s (FTC’s) “click-to-cancel” rule was overturned by the U.S. Court of Appeals for the Eighth Circuit, just days before the new rule was set to go into effect. According to the...more

Goodwin

FTC Settles with Amazon Over Enrollment and Cancellation Processes for Prime Memberships

Goodwin on

On September 25, 2025, the Federal Trade Commission announced it had reached a settlement with Amazon.com, Inc. and two company executives, resolving allegations that the company’s enrollment and cancellation processes for...more

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