What the FTC Rule Reversal Means for Click-to-Cancel and Auto-Renewal Compliance
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Negative Option (Subscription Billing) – Recent Federal and State Developments
This is a FREE product for HFA Members
On July 8, 2025, the 8th Circuit vacated the newly promulgated FTC Negative Option Rule, following Gibson Dunn’s challenge to the Rule. Although companies will not be subject to the Rule’s more onerous consent and cancellation requirements as the law currently stands, states continue to pass more cumbersome negative option and subscription laws, and the FTC continues to prioritize enforcement of existing subscription laws like ROSCA in various industries, including the health and fitness industry. This session, led by Gibson Dunn consumer protection experts, will discuss these federal and state developments and what it means for compliance going forward.
Presented by:
Mike Goscinski, HFA VP of Government Affairs
Svetlana Gans, Partner and former Chief of Staff, FTC
Caelin Moriarity Mitko, Associate, Litigation & Regulatory Affairs