Consumer Financial Protection Bureau Alert - March 2015

New York City has enacted the nation's first municipal click-to-cancel rule, requiring businesses to provide clear disclosures, simple cancellation processes, and advance renewal notices for subscription services. With approximately 30 states already implementing similar regulations and the federal landscape in flux following the FTC's vacated rule, companies now face an increasingly complex patchwork of compliance obligations. The rule takes effect October 1, 2026, and imposes penalties ranging from $525 t

The Federal Communications Commission has fundamentally altered how businesses must handle consumer opt-out requests under the Telephone Consumer Protection Act, replacing the broad "revoke all" mandate with a more nuanced, category-specific approach for informational messages. This regulatory shift allows companies to maintain separate consent tracks for different types of non-marketing communications while preserving stricter opt-out requirements for telemarketing messages. The Updated Order introduces ne

The FTC and Washington state secured a record $225 million settlement from Amway and affiliated groups over allegations they misled recruits about earnings potential while pressuring them to buy products with little retail opportunity. The complaint reveals that over three-quarters of U.S. product volume was sold to IBOs themselves rather than retail customers, with fabricated sales reporting masking the recruitment-driven model. The settlement's injunctive provisions establish new standards for earnings cl

On October 16, the FTC announced that it has finalized its "click to cancel" rule, that will require sellers to make it much easier for consumers to cancel subscriptions.

The Federal Trade Commission is exploring whether digital platforms should bear greater responsibility for preventing impersonation ads that falsely pose as legitimate businesses or government agencies. Through an Advance Notice of Proposed Rulemaking, the agency seeks public input on potential amendments to its existing Impersonation Rule, examining how ad-optimization tools and platform practices...

Congress has introduced the Stop Spam Calls Act, directing the FCC to revise the definition of prior express written consent under the TCPA to require one-to-one seller consent and logical relevance between sellers and website content. This legislative move comes as the Fifth Circuit questions whether written consent is even required under the TCPA, creating a fascinating tension between congressional intent and judicial interpretation that could reshape telemarketing compliance.

On July 10, 2026, the New York City Department of Consumer and Worker Protection announced the adoption of its “Click-to-Cancel” rule requiring businesses to provide consumers...

State-law class actions targeting automatic renewal and subscription practices are accelerating, creating significant litigation risk for companies that rely on recurring revenue models. Recent settlements demonstrate that even technical compliance failures can lead to seven-figure exposure, with California, Illinois, and Virginia statutes driving the most aggressive litigation.

The Federal Trade Commission has reached a settlement with a payment processor and four affiliated entities over allegations that they knowingly facilitated deceptive merchants, including foreign tech-support operations, in accessing the U.S. card-payment system. The case resulted in a $4.85 million monetary judgment and features a significant Joint Statement from FTC leadership establishing a knowledge standard for unfair payment-processing claims under Section 5.

This week's product recalls span a wide range of consumer goods, from eye care products and baby bath seats to electric vehicles and over-the-counter medications. Each recall addresses specific safety hazards including sterility concerns, drowning risks, fire hazards, and undeclared substances that could pose serious health risks to consumers.