We look at the legal considerations that should be addressed when developing subscriptions for consumer financial products and services. After reviewing the practices addressed by federal and state automatic renewal/subscription laws and the types of products and services covered by such laws, we discuss legal requirements for subscriptions and renewals such as up-front disclosures, notification obligations, and cancellation options, federal and state enforcement actions, and private litigation.… Continue Reading
On October 4, California Governor Gavin Newsom signed into law amendments to California’s existing law on automatic subscription renewals. The law applies to all businesses that make automatic renewal or continuous services offers to California consumers. The amendments are effective July 1, 2022.
The amendments include new notice requirements that apply:
- when a consumer accepts a free gift or trial lasting more than 31 days that was included in an automatic renewal or continuous service offer or accepted an automatic renewal or continuous service offer at a promotional or discounted price that applies for more than 31 days.