News & Analysis as of

Rulemaking Process Cancellation Rights

Venable LLP

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

Venable LLP on

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

Snell & Wilmer

FTC Click to Cancel Rule

Snell & Wilmer on

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

Dorsey & Whitney LLP

FTC Finalizes Click to Cancel and Negative Option Rule

Dorsey & Whitney LLP on

On October 16, 2024, the Federal Trade Commission (FTC) announced a revision to its negative option rule. The rule, formally entitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs,” is a...more

Brownstein Hyatt Farber Schreck

FTC to Shift Rulemaking Priorities in the Trump Administration

The Federal Trade Commission (FTC) is one of the independent agencies expected to undergo considerable changes in rulemaking priorities once President-elect Trump enters office. Chairwoman Lina Khan is expected to step down...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

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