We ended last month’s update noting that the Federal Trade Commission (FTC) had finalized its Combating Auto Retail Scams (CARS) Rule. Shortly following the Final Rule’s publication, the National Automobile Dealers...more
2/7/2024
/ CARS Rule ,
COPPA ,
Federal Breach Notification Standard ,
Federal Trade Commission (FTC) ,
Fees ,
Goods or Services ,
Labeling ,
NPRM ,
Regulatory Agenda ,
Telemarketing Sales Rule ,
Unfair or Deceptive Trade Practices
The Federal Trade Commission (FTC or the Commission) had a busy December. While many of us were winding down for the holidays, the FTC finalized a new rule, requested comments on a new proposed rule and extended the comment...more
1/3/2024
/ Advertising ,
Breach Notification Rule ,
Consumer Financial Products ,
COPPA ,
Corporate Counsel ,
Data Collection ,
Federal Trade Commission (FTC) ,
Fees ,
Green Guides ,
Non-Compete Agreements ,
NPRM ,
Online Safety for Children ,
Regulatory Agenda ,
Regulatory Reform ,
Rulemaking Process ,
Telemarketing ,
Telemarketing Sales Rule ,
Unfair or Deceptive Trade Practices
On November 30, Massachusetts Attorney General Andrea Campbell (the “AGO”) unveiled a new proposed rule regulating “junk fees” and consumer subscriptions (the “Proposed Rule”). The Proposed Rule in large part mimics, and in...more
12/12/2023
/ Advertising ,
Automatic Renewals ,
Consumer Financial Products ,
Federal Trade Commission (FTC) ,
Fees ,
Financial Regulatory Reform ,
Financial Services Industry ,
Financial Transactions ,
Free Trials ,
Goods or Services ,
Proposed Rules ,
Regulatory Agenda ,
State Attorneys General ,
Subscription Services
A number of interesting developments out of the Federal Trade Commission (FTC) this month. First, the FTC’s Notice of Proposed Rulemaking on “Junk Fees” was officially published in the Federal Register, meaning the 60-day...more
11/28/2023
/ Advertising ,
Breach Notification Rule ,
Federal Trade Commission (FTC) ,
Fees ,
Marketing ,
Non-Compete Agreements ,
NPRM ,
Regulatory Requirements ,
Safeguards Rule ,
Telemarketing Sales Rule ,
Unfair or Deceptive Trade Practices
The big regulatory news out of the FTC in October is a Notice of Proposed Rulemaking on Unfair or Deceptive Fees, or as the Commission calls them, “Junk Fees.” As we explain in more detail in our article on the Proposed...more