Federal Trade Commission Adopts New “Click-to-Cancel” Rule

Written by: Ian M. Stanford and Steven T. Lawrence If your business includes any sort of subscription-based or membership model, a new federal regulation may change how your customers cancel their subscription or membership.  On October 16, 2024, the Federal Trade Commission announced its final “Click-to-Cancel” rule.  The new rule applies to “negative option programs,”…

The Corporate Transparency Act: July and September 2024 Update to the Beneficial Ownership Information Frequently Asked Questions

In July and September 2024, FinCEN provided some additional guidance on the Corporate Transparency Act (“CTA”) by updating its Frequently Asked Questions web page related to beneficial ownership information report filing obligations of terminated, administratively dissolved and disregarded entities, and clarifying the contents of such beneficial ownership information report filings.  Below is a brief summary…

The Corporate Transparency Act – A Series of the Latest Updates for Reporting Companies

The effective date of the Corporate Transparency Act and its corresponding rules promulgated by FinCEN was January 1, 2024.  In January 2023, we published an article that discussed the intent and importance of the CTA (available here).  The CTA may be a landmark piece of legislation that reshapes how certain entities report and disclose information…

The Federal Trade Commission Seeks to Ban Non-Compete Clauses

In July 2021, President Biden issued an Executive Order encouraging the Federal Trade Commission (“FTC”) to consider exercising its rulemaking authority to “curtail the unfair use of non-compete clauses and other clauses or agreements that may unfairly limit worker mobility.”[1] On January 5, 2023, the FTC issued a press release stating that non-competes in employment…

Get Prepared – The Corporate Transparency Act: A New Federal Disclosure Requirement for Certain Entities

New federal reporting requirements that implicate many small businesses will soon take effect.  If your business is required to report under the new regulations, certain information about your business, personal information of business owners, and certain key individuals within the business will be required to be reported to the federal government.    On January 1,…