News & Analysis as of

Subscription Services Final Rules Enforcement Actions

DLA Piper

FTC “Click-to-Cancel” Rule to Take Effect May 14

DLA Piper on

In October 2024, the Federal Trade Commission (FTC) finalized significant updates to the Negative Option Rule, which are slated to take effect on May 14, 2025. A negative option is a contract term under which a buyer agrees...more

Latham & Watkins LLP

FTC’s Click-to-Cancel Rule to Take Effect on May 14, 2025, Despite Litigation

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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

Latham & Watkins LLP

Unpacking the FTC’s New Negative Option Rule, Its Legal Challenges, and Future Uncertainty

Latham & Watkins LLP on

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

Morrison & Foerster LLP

The FTC’s Final “Click-to-Cancel” Rule Faces Legal and Political Hurdles

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

Hudson Cook, LLP

CFPB Bites of the Month - November 2024 - CFPB Take Me Home, Country Roads

Hudson Cook, LLP on

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

Benesch

A New Era of Auto-Renewal: A Closer Look at the New FTC and California Requirements

Benesch on

It’s time to revisit automatic renewal compliance. With California amending its Automatic Renewal Law ("ARL") on September 24, 2024, and the Federal Trade Commission (“FTC”) finalizing its “Click-to-Cancel” Rule (“FTC Final...more

Bass, Berry & Sims PLC

FTC Releases “Click to Cancel” Rule

Bass, Berry & Sims PLC on

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

Perkins Coie on

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

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