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Mark Meador Confirmed as Newest Republican FTC Commissioner

...the Senate confirmed Mark Meador as the newest Republican commissioner of the Federal Trade Commission with a 50-46 vote along party lines. Meador’s confirmation solidifies a Republican majority on the Commission,...more

Fraud Prevention, Worker Protection, and Fighting Alleged Big Tech Censorship: A Roundup of the New FTC’s Agenda after the First...

Wednesday, we covered President Trump’s firing of Democratic FTC Commissioners Alvaro Bedoya and Rebecca Slaughter and explored whether a two-member Commission constitutes a quorum for the agency to take formal action....more

Firings of Democratic Commissioners Leave FTC In Flux and Tee Up Revisiting of Humphrey’s Executor

As news hit last night that President Trump fired the two remaining Democratic FTC Commissioners Alvaro Bedoya and Rebecca Slaughter, many questions abound. Would Commissioners Bedoya and Slaughter contest the dismissals?...more

“Junk Fee” Legislative Roundup – 2025 Edition

2024 was an action-packed year for followers of federal and state laws and regulations governing the disclosure of fees, or so-called ​“junk fee” laws....more

FTC Puts Pedal to the Metal to Release Proposed Rule on MLM Earnings Claims, Changes to Business Opportunity Rule—but Republican...

The FTC released two Notices of Proposed Rulemaking (NPR) and an Advance Notice of Proposed Rulemaking (ANPR) that would establish a new Earnings Claims Rule and expand the existing Business Opportunity Rule – changes that...more

FDA Updates ​“Healthy” Nutrient Content Claim for Food

FDA issued a final rule today updating the requirements food must meet to be marketed as ​“healthy.” FDA says that a ​“healthy” claim ​“implies that the nutrient content of the food may help consumers maintain healthy dietary...more

FTC Releases Narrowed Junk Fees Rule for Ticketing and Lodging

Fourteen months after proposing a far-reaching rule that would have overhauled the way fees are disclosed across sectors, the FTC today announced a significantly curtailed final rule limited to the sale of live-event tickets...more

Trump Announces Ferguson to Serve as FTC Chair, Nominates Meador for Open Commissioner Spot

President-elect Trump announced his picks to round out the Federal Trade Commission for his second administration. Trump tapped current Republican Commissioner Andrew Ferguson to be elevated to chair the agency, and nominated...more

What You Need to Know About Extended Producer Responsibility (EPR) Programs

If you manufacture or sell packaging or products that are sold in packaging, you should be mindful of a movement to impose liability for packaging waste through Extended Producer Responsibility, or ​“EPR.” EPR is a policy...more

With Uncertainty Surrounding the FTC’s Negative Option Rule, New California Requirements Wait in the Wings

Last Friday, the FTC’s final Negative Option Rule was published in the Federal Register, starting the clock on the effective dates for the agency’s expansive overhaul of requirements related to goods or services sold through...more

What to Expect at the FTC Pre and Post-Inauguration

With the election decided, the speculation has begun. In our area of the law, that means a number of things, including what will happen at the FTC – with the current Commission and Chair Khan, with recently announced rules...more

CFPB Pushes Move to an Open Banking System with the Personal Financial Data Rights Rule and Sparks Immediate Court Challenges from...

On Tuesday, the Consumer Financial Protection Bureau (CFPB) released the final version of the Personal Financial Data Rights Rule that requires many financial institutions, credit card issuers, and other financial service...more

Amidst AI Crackdown Hype, FTC Stakes Out Aggressive New Position on Unfairness and Means and Instrumentalities Liability

Much has already been said and written about the FTC’s recent enforcement initiative, dubbed ​“Operation AI Comply.” The coordinated sweep announced last month involved five separate FTC enforcement actions against companies...more

FTC Finalizes ​“Click to Cancel” Rule; Brings Vast Changes and New Risks to Subscription Plans, Repeat Delivery Offers

Last year, we wrote about the FTC’s proposal to massively expand the Negative Option Rule to cover any goods or services involving a negative option or automatic renewal plan, including free trials, subscriptions, and repeat...more

Highlights from the 2024 National Advertising Division Conference

Last week, advertising and legal professionals, experts, regulators, and business representatives convened in New York for the annual National Advertising Division (NAD) Conference to consider hot topics, share perspectives...more

FTC Staff Report on MLM Income Disclosures: Many Observations Lead to Many Questions

Yesterday, the Federal Trade Commission issued a staff report documenting its review of 70 publicly available income disclosure statements from a wide range of multi-level marketing (MLM) and direct selling companies...more

FTC Finalizes Rule on “Fake Reviews”

Yesterday, the Federal Trade Commission announced its final rule addressing consumer reviews and testimonials. With this rule, the Commission takes aim at ​“fake” reviews and testimonials by prohibiting their sale or purchase...more

CFPB Issues Interpretive Rule for Paycheck Advance or ​“Earned Wage Access” Products

Late last week, the Consumer Financial Protection Bureau (CFPB) released a proposed interpretive rule asserting that paycheck advance or earned wage access (EWA) products are considered consumer loans and therefore subject to...more

California ​“Junk Fee” Statute Now Fully In Play with New Twist from Last Minute Legislation

As we previously reported, the California AG’s office recently provided clarification through FAQs on the California ​“hidden fee” law that amended the Consumer Legal Remedies Act, SB 478. Those FAQs articulated the position...more

Supreme Court Upholds CFPB Funding Mechanism as Constitutional, Quelling Uncertainty and Reinvigorating the CFPB’s Docket

In a long-awaited decision with profound implications for the future of the agency, the Supreme Court held 7-2 today that the Consumer Financial Protection Bureau (CFPB) is constitutionally funded. CFPB officials can breathe...more

CFPB Report and Hearing with DOT Highlight Risks with Rewards Programs

On May 9, 2024, the CFPB released a report on rewards programs that traces the rise of such programs and warns that it views certain practices as unfair, deceptive, or abusive acts and practices ripe for investigation and...more

California Issues FAQs on Hidden Fee Law

This week, the California AG’s office released a set of FAQs on California’s law addressing hidden fees. As a reminder, the law states that the following practices will be unlawful under the Consumer Legal Remedies Act...more

FTC Staff’s Revised MLM Guidance—More Content, Less Clarity

Yesterday FTC Staff released updated Business Guidance Concerning Multi-Level Marketing that provides a detailed account of their current perspective on applicable standards governing the direct selling and multi-level...more

FTC Staff Doubles Down on Rejected Koscot Standard for Pyramiding Claims, Challenges DSSRC IDS Guidance

Over the past two years, we have seen FTC staff express its opinions on the state of the law in multiple ways. In December 2022, for example, staff issued its Health Products Compliance Guidance, intended to supersede the...more

Senate Confirms New FTC Commissioners Holyoak and Ferguson; Reconfirms Slaughter

After nearly a year without a Republican Commissioner after Christine Wilson’s resignation, the FTC will again have a full slate of five Commissioners – with two new Republican Commissioners in Melissa Holyoak and Andrew...more

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