Despite Rule Delay, FTC Scrutiny Looms for Subscriptions

Consumer protection attorneys Brian Goodrich and Benjamin Genn co-authored a Law360 article analyzing anticipated enforcement of the Federal Trade Commission's (FTC) new click-to-cancel rule, which requires clearer disclosures, simplified cancellations and affirmative consent for auto-renewing subscriptions. Despite delays in the rule's enforcement, recent FTC actions against companies such as Uber and Cleo AI signal heightened scrutiny of subscription practices. The article recommends businesses review and update their policies to ensure compliance with both federal and emerging state auto-renewal regulations to avoid significant penalties and reputational risks.

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