ARTICLE · 22 NOVEMBER 2014

FTC Secures $22 Million Settlement For Alleged ROSCA Violations

Klein Moynihan Turco LLP

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Earlier this week, the Federal Trade Commission ("FTC") announced that three companies agreed to pay more than $22 million in consumer refunds for allegedly violating the Restore Online Shoppers’ Confidence Act ("ROSCA").

United StatesLitigation, Mediation & Arbitration

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Earlier this week, the Federal Trade Commission ("FTC") announced that three companies agreed to pay more than $22 million in consumer refunds for allegedly violating the Restore Online Shoppers' Confidence Act ("ROSCA"). The ROSCA settlement is one of the largest in FTC history.

ROSCA Generally

ROSCA was enacted in January 2011 to prohibit online retailers from charging consumers' financial accounts unless they have clearly disclosed all material terms associated with their subject products/services and obtained consumers' express informed consent to bill for those products/services. ROSCA mandates that sellers obtain financial account information directly from consumers and not share that information with other third party sellers (for example, the sharing of consumer financial information between sellers in an online co-registration flow). Third party sellers are required to create a process for the consumer to re-enter personal and financial information

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