News & Analysis as of

ROSCA Enforcement Actions

Wilson Sonsini Goodrich & Rosati

FTC Files Consumer Protection Complaint Against Uber for Deceptive Billing and Cancellation Practices

On April 21, 2025, the Federal Trade Commission (FTC) announced that it had filed a complaint against Uber Technologies, Inc. and Uber USA LLC (collectively, Uber), a rideshare and delivery company. Among other things, the...more

Orrick, Herrington & Sutcliffe LLP

FTC acts against finance app for alleged deceptive cash advance practices

On March 27, the FTC announced an enforcement action resulting in a stipulated order from the U.S. SDNY regarding a cash advance company’s alleged violations of Section 5(a) of the FTC Act and the Restore Online Shoppers’...more

Venable LLP

Cleo AI Settles with FTC for $17 Million for Alleged Misleading Practices and Autorenewal Violations

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In one of the first settlements since the new administration took office, the Federal Trade Commission (FTC) announced a $17 million monetary judgment with Cleo AI to resolve allegations that Cleo violated Section 5 of the...more

Sheppard Mullin Richter & Hampton LLP

FTC Orders Fintech Company to Pay $17 Million for Allegedly Deceptive Subscription Practices

On March 27, the FTC announced that a fintech company offering cash advances through a mobile app has agreed to pay $17 million to resolve allegations that it violated the FTC Act and the Restore Online Shoppers’ Confidence...more

Hudson Cook, LLP

CFPB Bites of the Month - 2024 Annual Review - Fintech

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In this article, we share a timeline of our monthly "bites" for 2024 applicable to companies in FinTech. The Consumer Financial Protection Bureau was on a tear in the months leading up to the election and the inauguration of...more

Hudson Cook, LLP

CFPB Bites of the Month - November 2024 - CFPB Take Me Home, Country Roads

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In this month's article, we share some of our top "bites" for the prior and current month covered during the November 2024 webinar....more

Goodwin

FTC Files Suit Against Online Cash Advance Provider for Allegedly Deceptive and Misleading Conduct

Goodwin on

On November 5, 2024, the FTC announced​ that it had filed suit against a California-based online cash advance provider for allegedly deceptive and misleading advertisements and representations, in violation of the FTC Act, 15...more

Sheppard Mullin Richter & Hampton LLP

FTC Takes Aim at Mobile Banking App for Deceptive Advertising Practices

On November 5, the Federal Trade Commission (“FTC”) filed a complaint against a company in connection with its mobile banking app, alleging violations of Section 5(a) of the FTC Act and Section 4 of the Restore Online...more

Orrick, Herrington & Sutcliffe LLP

FTC orders billing companies to shut down and issues $40M payout for fraud

On September 17, the FTC announced that the U.S. District Court for the Middle District of Florida approved the Commission’s order, effectively shutting down several companies named in the FTC’s June complaint and required...more

Venable LLP

Handle Autorenewal Programs with Care: Federal Trade Commission Targets Care.com for Alleged Dark Patterns and Earnings Claims

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Companies that care about avoiding Federal Trade Commission (FTC) action should take heed. Last month, the FTC announced an $8.5 million settlement with Care.com, resolving claims challenging its advertising claims and...more

Clark Hill PLC

Children’s Data Update: From FTC and State Agency Enforcement to KOSA Advancing the Senate

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On July 7, the FTC and the Los Angeles District Attorney’s Office filed a complaint in the United States District Court for the Central District of California against the developer of an anonymous messaging app (NGL Labs,...more

Cooley LLP

FTC Continues Aggressive ROSCA Enforcement Agenda Against Negative Option Sellers

Cooley LLP on

In June 2024, the US Federal Trade Commission (FTC) and the Department of Justice jointly filed a complaint under the Restore Online Shoppers’ Confidence Act (ROSCA) in the US District Court for the Northern District of...more

BakerHostetler

FTC Concerns over Marketing to Kids - It’s Not Just About COPPA Anymore

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The Federal Trade Commission (FTC or Commission) has signaled for some time that while the Children’s Online Privacy Protection Act (COPPA) is limited to children under the age of 13, it also has concerns about the...more

Orrick, Herrington & Sutcliffe LLP

FTC refers ROSCA case against software company and executives to DOJ

On June 17, the FTC announced an enforcement action against a software company and two of its executives for its practices related to its subscription model. According to the redacted complaint filed by the DOJ (upon referral...more

Sheppard Mullin Richter & Hampton LLP

FTC Settles with Cash-Advance Fintech for Alleged Deceptive and Discriminatory Practices

On January 23, the FTC entered into a settlement agreement with a cash-advance fintech app for $3 million over violations of the FTC Act, the Restore Online Shoppers’ Confidence Act (ROSCA), and ECOA....more

Sheppard Mullin Richter & Hampton LLP

FTC Settles with Fintech for $18M over Deceptive Cash Transfers and Difficult-to-Cancel Memberships

On November 2, the FTC entered into a settlement agreement with a Manhattan-based fintech company for $18 million over alleged deceptively marketed cash advances to consumers and impeding customers’ ability to cancel...more

Orrick, Herrington & Sutcliffe LLP

FTC takes action against investment advisor, cites violations of Notice of Penalty Offenses

On January 13, the FTC announced an action against an investment advisor and its owners concerning allegations that the defendants made deceptive claims when selling their services to consumers. ...more

Venable LLP

Is Your New Year’s Resolution to Comply with Automatic Renewal Laws? If So, Look No Further

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The law surrounding negative option and continuity programs continues to evolve rapidly. Feeling a bit overwhelmed with the latest developments? Below is what you need to know in light of new laws, new enforcement actions,...more

Wiley Rein LLP

Wiley Consumer Protection Download (November 14, 2022)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Venable LLP

Vonage, Autorenewals, and the FTC’s Ever-Expanding Interpretation of ROSCA

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Last week, the Federal Trade Commission (FTC) issued a press release, announcing a $100 million settlement with Vonage, an internet-based telephone service company, for alleged violations of the Restore Online Shoppers’...more

Troutman Pepper Locke

FTC Report Highlights Evolving Dark Patterns and Signals Increased Enforcement

Troutman Pepper Locke on

The Federal Trade Commission (FTC) recently released a Bringing Dark Patterns to Light report, detailing the rise in sophisticated “dark patterns” that the FTC asserts are designed to trick and trap consumers. As the FTC’s...more

BakerHostetler

Not Every Payment Processing Case Is the Same - the Latest FTC Case Provides Some Helpful Reminders

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Most of the Federal Trade Commission’s (FTC) law enforcement actions involving payment processors have exclusively focused on allegations that processors did not do sufficient due diligence before onboarding questionable...more

Venable LLP

[Webinar] New Laws and Requirements for Automatic Renewal Programs: What Businesses Need to Know in 2022 - February 23rd, 2:00 pm...

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The laws and rules governing automatic renewal programs continue to change on a regular basis. Over the past year, the Federal Trade Commission has announced a number of settlements and lawsuits enforcing the federal Restore...more

Ballard Spahr LLP

A Closer Look at Automatic Renewal Laws

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Over the past several years, state legislatures have become more aggressive in passing laws to protect consumers’ digital rights. The promulgation of state data security and privacy laws, such as the California Consumer...more

Orrick, Herrington & Sutcliffe LLP

Putting Individuals In The (Urth)Box: FTC Goes After Individual Executives For Unfair And Deceptive Practices

In an increasing trend, the Federal Trade Commission (FTC) joined other federal regulators seeking to hold individuals – not just companies – liable in enforcement proceedings. The most recent target was San Francisco-based...more

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