Payments Pros – The Payments Law Podcast
Jul 8, 2026 · 21 min · 8 segments
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…
Today, I want to talk about a recent FTC enforcement action against an online retailer.
Recent meaning recent as of the time of this recording, which is we are here in June of 2026.
And I want to talk about this because this seems to have been a developing trend over the past year and a half now of the Trump administration.
I want to spend a lot of time talking about ROSCA and negative options, cancellations, and things of that
nature.
And I wanted to talk about that because a lot of attention has been paid to the dismantling of the Consumer Financial Protection Bureau.
In fact, the FTC has provided advanced notice of proposed rulemaking in payments with respect to negative option features.
Another example of advanced rulemaking concerns disclosures about costs when people purchase groceries and cooked food deliveries online.
The point here is that the FTC is not waiting for the new rules to be finalized and adopted.
Last month, in May of 2026, the FTC filed a lawsuit and concurrently settled that lawsuit against a major online retailer.
We have written about these cases before on our blogs, but we are now adding this to the podcast because we believe that we are seeing a trend, as I mentioned earlier.
Although this enforcement action was against a major online retailer, it is worth it for both retailers and processors to take note because, as I mentioned before, the FTC has also brought suit against processors making similar allegations.
In the FTC's proposed order, which actually has been finalized, the retailer will pay $35 million, which will be used to provide full relief to the consumers harmed by the retailer's alleged unlawful billing and cancellation practices.
The order also prohibits the retailer from misrepresenting material terms of its subscription offerings and requires it to disclose material terms of its subscription offerings while obtaining consumers' expressed informed consent to charges and maintain a simple cancellation mechanism for negative option features.
Today, I want to talk about a recent FTC enforcement action against an online retailer.
Recent meaning recent as of the time of this recording, which is we are here in June of 2026.
And I want to talk about this because this seems to have been a developing trend over the past year and a half now of the Trump administration.
I want to spend a lot of time talking about ROSCA and negative options, cancellations, and things of that
nature.
And I wanted to talk about that because a lot of attention has been paid to the dismantling of the Consumer Financial Protection Bureau.
In fact, the FTC has provided advanced notice of proposed rulemaking in payments with respect to negative option features.
Another example of advanced rulemaking concerns disclosures about costs when people purchase groceries and cooked food deliveries online.
The point here is that the FTC is not waiting for the new rules to be finalized and adopted.
Last month, in May of 2026, the FTC filed a lawsuit and concurrently settled that lawsuit against a major online retailer.
We have written about these cases before on our blogs, but we are now adding this to the podcast because we believe that we are seeing a trend, as I mentioned earlier.
Although this enforcement action was against a major online retailer, it is worth it for both retailers and processors to take note because, as I mentioned before, the FTC has also brought suit against processors making similar allegations.
In the FTC's proposed order, which actually has been finalized, the retailer will pay $35 million, which will be used to provide full relief to the consumers harmed by the retailer's alleged unlawful billing and cancellation practices.
The order also prohibits the retailer from misrepresenting material terms of its subscription offerings and requires it to disclose material terms of its subscription offerings while obtaining consumers' expressed informed consent to charges and maintain a simple cancellation mechanism for negative option features.
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