Expanding Patchwork Of State "Junk Fees" Laws Presents Compliance Challenges

--Installment 1 of Wiley's State Consumer Protection Series--

State laws regulating disclosures of fees and "total prices" have expanded, and we start our series of state consumer protection alerts with a deeper dive on key compliance obligations for these fee disclosure laws. These laws are often called "junk fees" or "drip pricing" laws, and they typically prohibit companies from advertising a base price without disclosing certain additional fees or charges that might otherwise be disclosed only later in the purchasing process. At a recent conference, state Attorneys General (AGs) identified enforcement of these laws as a priority, and it is an area where federal and state enforcers have collaborated. With greater scrutiny of pricing practices, compliance is not only increasingly important but also increasingly complex, as state laws vary on specific requirements and how they apply across industries like telecommunications, travel booking, hotel and short-term