Automatic renewals have become a preferred method of goods and service delivery for many businesses, particularly in the context of e-commerce. The patchwork of state and federal laws and regulations makes absolute compliance a difficult proposition for many companies. In a purported effort to provide clarity to companies regarding their compliance obligations in this space, the FTC recently finalized its Rule Concerning Recurring Subscriptions and Other Negative Option Programs. While the Final Rule has reached the last stage of the FTC’s rulemaking process, questions remain.
By Andrew Lustigman and Morgan Spina
Automatic renewals have become a preferred method of goods and service delivery for many businesses, particularly in the context of e-commerce. The ever-changing landscape of federal and state laws regulating negative options and automatic renewals has been widely documented.
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