National Consumer Law Center joins the Consumer Federation of America and the National Consumers League in strong support of a Federal Trade Commission (“FTC” or “Commission”) rule that comprehensively addresses modern negative option plans, also called “subscription plans” or “subscriptions”. Subscription plans frequently result in consumer overpayment, unintended enrollment, and unreasonable cancellation procedures. An adequate Negative Option Rule should rely on the following principles:
- Prohibition on misrepresentations;
- Disclosure of material terms; 3. Cancellation as easy as initiation;
- Consent separate from other portions of a transaction;
- Prohibition on unreasonable save offers; and
- Notice to consumers prior to each recurring charge.
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