The FTC’s much-anticipated “Click to Cancel” Rule was nixed, but the FTC is not backing down. The FTC continues to use Section 5 of the FTC Act and various other regulations to bring enforcement actions against companies that fail to provide clear and conspicuous disclosures about recurring charges and easy-to-cancel options for consumers. Thus, though the Rule did not survive, its intent is alive and well. Direct Sellers should audit their recurring charge disclosures and ensure that canceling is just as easy as signing up. 

Overdraft fees have been a persistent concern for lawmakers and regulators since the rise of electronic banking in the late 20th century.