In this episode of The Consumer Finance Podcast, Chris Willis sits down with Jason Cover and Colin Wilson to discuss the evolving world of auto-renewal and subscription compliance, including the FTC’s click-to-cancel rule, its Eighth Circuit setback, and the states racing to fill the gap. They also spotlight a first-of-its-kind municipal rule proposed by New York City and explain why, even in a deregulatory environment, UDAP authority and ROSCA mean the compliance pressure hasn’t gone anywhere. If your business involves subscriptions, recurring billing, or point-of-sale financing, this is a conversation you can’t afford to miss.

Transcript: Point-of-Sale Finance Series: Regulation of Subscription and Auto-Renewal Plans (PDF)

Photo of Chris Willis Chris Willis

Chris is the co-leader of the Consumer Financial Services Regulatory practice at the firm. He advises financial services institutions facing state and federal government investigations and examinations, counseling them on compliance issues including UDAP/UDAAP, credit reporting, debt collection, and fair lending, and defending…

Chris is the co-leader of the Consumer Financial Services Regulatory practice at the firm. He advises financial services institutions facing state and federal government investigations and examinations, counseling them on compliance issues including UDAP/UDAAP, credit reporting, debt collection, and fair lending, and defending them in individual and class action lawsuits brought by consumers and enforcement actions brought by government agencies.

Photo of Jason Cover Jason Cover

Jason’s in-depth experience advising on consumer lending matters both as in-house counsel and outside advisor provides extensive industry knowledge for his financial services clients.

Photo of Colin Wilson Colin Wilson

Colin advises clients in the consumer finance sector on all aspects of compliance, applying insights from his role as an attorney-advisor at the Consumer Financial Protection Bureau. In addition to serving in the Bureau’s Legal Division, he worked in the Office of the

Colin advises clients in the consumer finance sector on all aspects of compliance, applying insights from his role as an attorney-advisor at the Consumer Financial Protection Bureau. In addition to serving in the Bureau’s Legal Division, he worked in the Office of the Director collaborating with senior advisors on a variety of regulatory and policy initiatives.