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ARTICLE · 15 APRIL 2025

Recent FTC Settlement Underscores Importance Of Compliant Subscription Practices

Frankfurt Kurnit Klein & Selz PC
Frankfurt Kurnit Klein & Selz PC
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Frankfurt Kurnit Klein & Selz PC

Frankfurt Kurnit Klein & Selz PC

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As the new Federal Trade Commission leadership continues to shape its consumer protection agenda, we look to recent enforcement and rulemaking activity for insight into the agency's current priorities—and a recent settlement indicates that enforcement of the Restore Online Shoppers' Confidence Act remains one of them.

United StatesConsumer Protection
Kate Patton
Kate Patton
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As the new Federal Trade Commission leadership continues to shape its consumer protection agenda, we look to recent enforcement and rulemaking activity for insight into the agency's current priorities—and a recent settlement indicates that enforcement of the Restore Online Shoppers' Confidence Act ("ROSCA") remains one of them.

Online cash advance company Cleo AI recently agreed to pay $17 million to settle FTC allegations that it violated Section 5(a) of the FTC Act and ROSCA by deceiving consumers with false promises of instant or same-day access to cash advances and making it difficult for consumers to cancel their subscriptions.

As described in the complaint, Cleo promises consumers access to cash advances of hundreds of dollars "today" or "instantly." When consumers attempt to obtain such advances, they are presented with two subscription options for which Cleo charges monthly fees. Despite its representations, the FTC alleges that, in fact, Cleo limits its

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This post first appeared in Frankfurt Kurnit's Focus on the Data blog (www.focusonthedata.com). It provides general coverage of its subject area. We provide it with the understanding that Frankfurt Kurnit Klein & Selz is not engaged herein in rendering legal advice, and shall not be liable for any damages resulting from any error, inaccuracy, or omission. Our attorneys practice law only in jurisdictions in which they are properly authorized to do so. We do not seek to represent clients in other jurisdictions.

Originally published by the New York Legal Ethics Reporter

www.fkks.com

This alert provides general coverage of its subject area. We provide it with the understanding that Frankfurt Kurnit Klein & Selz is not engaged herein in rendering legal advice, and shall not be liable for any damages resulting from any error, inaccuracy, or omission. Our attorneys practice law only in jurisdictions in which they are properly authorized to do so. We do not seek to represent clients in other jurisdictions.

www.fkks.com

This alert provides general coverage of its subject area. We provide it with the understanding that Frankfurt Kurnit Klein & Selz is not engaged herein in rendering legal advice, and shall not be liable for any damages resulting from any error, inaccuracy, or omission. Our attorneys practice law only in jurisdictions in which they are properly authorized to do so. We do not seek to represent clients in other jurisdictions.

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