Consumer Finance Monitor Podcast Episode: A Look at the FTC’s Click-to-Cancel Rule, with James Kohm, Associate Director of Enforcement Division of the FTC’s Bureau of Consumer Protection
The FTC Takes Action Against the Amazon Prime Program
AD Nauseam: Negative Options – From Wine, to Cookies, to Gyms – Everything You Need to Know
Podcast - The FTC's Click to Cancel Proposal
Autorenewals - The Crypto Exchange Podcast
The Federal Trade Commission (“FTC”) has recently announced that the FTC’s Click to Cancel Rule (the “Rule”) has been postponed to July 14, 2025. Originally planned to become effective May 14, 2025, the Commission released...more
Companies with B2C or B2B recurring payment programs that include negative option terms should review their disclosure, consent, and cancellation practices to ensure compliance with the rule....more
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
The rule impacts both B2B and B2C subscription autorenewals and other negative option programs; however, significant legal challenges could impact the rule’s implementation....more
The fate of the FTC’s long-awaited final “Click-to-Cancel” rule has become tangled in uncertainty as it faces numerous lawsuits and the new incoming presidential administration. In October, the FTC published its Final Rule...more
In this month's article, we share some of our top "bites" for the prior and current month covered during the November 2024 webinar....more
The Federal Trade Commission's Final Negative Option Rule ("Click to Cancel Rule") contains stringent new requirements for negative option programs, making it even more difficult to run compliant negative option offers....more
The Federal Trade Commission (FTC) published its final “Click-to-Cancel” Rule in the Federal Register on November 15, 2024, meaning that companies should ensure that they comply with the rule’s requirements within the next...more
Today’s ever-shifting business environment means that consumers, businesses, employers, and employees all expect to transact digitally. To remain efficient and competitive, companies must digitally transform their businesses....more
Attention, any companies that sell direct to consumers: the FTC has announced a new final rule requiring businesses to make it easier for consumers to opt-out and cancel subscriptions. Businesses will have 180 days to comply...more
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
Subscription-based services are a lynchpin of the services industry and the current focus of the Federal Trade Commission’s (FTC) new “click to cancel” rule. Responding to customer complaints focusing on the difficulty of...more
On October 16, 2024, the Federal Trade Commission announced the final FTC “Click-to-Cancel” Rule pertaining to recurring subscriptions and memberships. The Federal Trade Commission is not the only regulatory agency that...more
Companies offering automatic renewal or continuous service terms to consumers subject to California law should review their consent, notice, and cancellation practices. On September 24, 2024, California Governor Gavin...more
On September 24, 2024, Governor Gavin Newsom signed into law Assembly Bill No. 2863, which will further amend California’s Automatic Renewal Law (ARL)....more
This week, California amended its automatic renewal and continuous service offer law (ARL). Key provisions include the addition of “free-to-pay conversions,” consent obligations, misrepresentation prohibitions, request for...more
Subscription services, initially marketed as a cheaper, more accessible option, have recently been experiencing a price surge. In 2023, top subscription apps like Apple Music, Amazon Music, YouTubeTV, Netflix, Peacock, HBO...more
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
Retailers and service providers with US business operations should take note: the Federal Trade Commission (FTC) is increasing its scrutiny of negative option marketing activity to combat unfair or deceptive practices related...more
Most consumers have signed up for subscriptions, automatic deliveries, or free trials that convert into a paid subscription. In this episode of The Crypto Exchange, Carlin McCrory welcomes colleagues Mark Furletti and Jill...more
Editor’s Note: On November 16, 2022, HaystackID shared an educational webcast on the proliferation of enterprise messaging content in the COVID-era, a proliferation accelerated by the pre-existing industry trend of legal...more
With several new state laws effective in 2022, it is becoming increasingly difficult for businesses to develop baseline compliance protocols across federal and state automatic renewal laws. Against this backdrop, federal...more
‘Tis the season for retailers to set best practices to avoid class actions, regulatory enforcement actions, and competitor claims. Ring in the new year with these top five U.S. advertising and marketing law takeaways. 1....more
Subscription services face increased scrutiny from regulators, lawmakers and the plaintiffs’ bar. As we highlighted in a recent client alert, the FTC warned companies against using “dark patterns” in connection with paid...more
As part of the new Fair Consumer Contracts Act, Germany will soon require specific cancellation/termination mechanisms for consumer subscriptions. These mechanisms come on top of the updated EU-wide consumer contract rules...more