The vacated Click-to-Cancel rule doesn’t signal the end for subscription-related enforcement actions – the FTC has several other tools at its disposal to pursue companies for unfair or deceptive practices.
Paavana Kumar, a partner in the Advertising + Marketing Practice Group at Davis+Gilbert was quoted extensively in Bloomberg Law discussing the FTC’s potential enforcement trends going forward and how businesses can stay compliant in the new subscription landscape.
“Going forward, the FTC is likely to bring enforcement actions that bundle subscription claims with other deceptive practices,” Paavana said. Companies still should be aware of and maintain compliance with general rules against deceptive practices as well as ROSCA. “You want to be clear and transparent with consumers no matter what,” Paavana emphasized. “Between the federal rules that are [still] in effect and state laws, the requirements aren’t that different from what click-to-cancel would have mandated.”
For more insight on the vacated Click-to-Cancel rule and what businesses can expect going forward, read the full article below.