As this year’s Cybersecurity Awareness Month comes to an end, we wanted to highlight a recently enacted piece of legislation that may provide protection for your business in the event of a data breach and remind you to include your cybersecurity policies in your end-of-year policy reviews and updates.

A safe harbor for certain small

  • The FTC’s Click to Cancel Rule has been postponed to July 14, 2025 (60-day extension)
  • Rule applies to all subscription agreements with Negative Option Features in both B2B and B2C contexts.
  • Key requirements: simplified cancellation processes, clear representations, and explicit consent mechanisms
  • Maximum penalty of $51,744 per violation, with potential for multiple violations