What We're Thinkin

CA SB 2863 Signed by CA Gov Newsom

TL;DR:  No news on the FTC Negative Option Rulemaking...nada, nunca. This silence/delay may be due to some recent court decisions adversely impacting the FTC and federal agency rulemakings generally, which may be giving FTC leadership some pause on its aggressive rulemaking efforts.  Or not...who...

TL;DR.  No news on the status of the FTC Negative Option Rulemaking … and even Vegas won't venture to guess an over/under effective date given the utter mishigas this process has become.  But if we were to guess, we think it is likely to be issued by the end of the year, possibly as early as Q3, ...

  Many have been asking about the status of the amended FTC Negative Option Rule and when it is likely to go into effect.      TL;DR.   Still don't know for sure, though not any time soon given a recent decision by the ALJ overseeing the three informal hearings conducted earlier this year on...

Pretty Much Everyone:  Any clue as to when the new FTC Negative Option rule will go into effect?  Did the recent Informal Hearings on the rulemaking process impact such timing, and what the heck were they about and how'd they go? Cobalt's Answer(ish):  Timing unclear, and somewhat of a sh!tsh0w....

Update on Auto Renewal legal developments in the past year.

Spring 2023 Auto Renewal Legislative Update

April 2022 State Auto Renewal Update

California Amends its Auto Renewal Law - October 4, 2021

Visa Withdraws Billing Descriptor Requirement

Summary of FTC v. Moviepass - Important 3 Minute Read

FTC issues Enforcement Policy Statement Regarding Negative Option Marketing

FTC May 2022 Rulemaking on the Telemarketing Sales Rule

          Hello all. Here is our review of and observations on the FTC's recent Negative Option Rule rulemaking.  Our “Full Story” write-up below, as long as it may seem, is a lot shorter than the 83-page proposal, so buckle up and grab some popcorn!  Or, if too much for you right...