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Payments Compliance and the FTC’s Focus on Subscription Practices

By Keith J. Barnett on July 8, 2026
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In this episode of Payments Pros, host Keith Barnett examines a recent FTC enforcement action involving alleged violations of the FTC Act and ROSCA. Keith discusses the FTC’s continued focus on negative option features, automatic renewals, subscription disclosures, free trial conversions, and cancellation practices, and explains why these issues remain important for companies operating in the payments ecosystem. He walks through the FTC’s allegations regarding insufficient disclosure of key subscription terms, including automatic renewal provisions and early cancellation fees, as well as concerns about burdensome cancellation processes for consumers. Keith also highlights how the action reflects a broader enforcement trend, with the FTC remaining active in the payments space despite increased attention on changes at the CFPB. The episode closes with practical takeaways for businesses, including the importance of clear disclosures, simple cancellation mechanisms, and careful internal communications regarding subscription and billing practices.

Transcript: Payments Compliance and the FTC’s Focus on Subscription Practices (PDF)

  • Posted in:
    Civil Litigation, Corporate Compliance
  • Blog:
    Regulatory Oversight
  • Organization:
    Troutman Pepper Locke
  • Article: View Original Source

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