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Comment by collingreen

6 days ago

Gotta pay all those data scientists and lawyers the big bucks in order to figure out how to checks notes stop actively preventing customers from canceling your service when they want to.

I'm happy to consult on this with all those poor businesses for under $100,000,000 in order to help the court vibes feel like the cost isn't over the limit.

I feel confident I can affordably write a few whitepapers and design guidelines to help these poor folks out as they research if there should be a cancel button and if it should work.

4 comments

collingreen

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db48x  6 days ago

With 106,000 companies doing this, that’s less than $1,000 each. Do you think that _your_ company could review all of its marketing materials for compliance with a new FTC rule for less than that? How much would you as a consultant charge one of those companies for your assistance?

But if you don’t like the rule, talk to your local Congresscritter and ask them to propose a bill to amend or remove it. Complaining about it in snarky internet comments isn’t going to get you anywhere.

  • collingreen  5 days ago

    Thanks for the downvote!

    I don't have any problem with the rule, which is why you dont see me arguing against it. I'm also not trying to change the laws by commenting on hn so your advice to not comment and instead call my reps comes off as pretty rude.

    I do have a problem with the bad faith take of it costing a bunch of money to pay lawyers and data scientists in order to figure out how to "make it possible to cancel" including things like the examples of cancel buttons that literally don't work. Bad faith from the courts to undermine consumer friendly rules is worth discussion.

    You may disagree with that and that's fine - happy to see a good faith response from you (but your goalpost moving requirement of updating all marketing doesn't meet the bar for me there) about why that cost might be higher than I expect. That might be an interesting convo.

    • db48x  5 days ago

      > but your goalpost moving requirement of updating all marketing doesn't meet the bar for me there

      I didn’t move the goalposts here. The new rules that are at issue here were about much more than just providing a button that cancels your subscription. See the actual text of the amendment to the rules <https://www.ftc.gov/system/files/ftc_gov/pdf/p064202_negativ...> if you don’t believe me. But I’ll quote the summary here:

          The Federal Trade Commission (“FTC” or “Commission”) issues final amendments to the Commission’s trade regulation “Rule Concerning Use of Prenotification Negative Option Plans,” retitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs” (“Rule,” “final Rule” or “Negative Option Rule”). The final Rule now applies to all negative option programs in any media, and, among other things, (1) prohibits misrepresentations of any material fact made while marketing using negative option features; (2) requires sellers to provide important information prior to obtaining consumers’ billing information and charging consumers; (3) requires sellers to obtain consumers’ unambiguously affirmative consent to the negative option feature prior to charging them; and (4) requires sellers to provide consumers with simple cancellation mechanisms to immediately halt all recurring charges.

  • eviks  5 days ago

    > Complaining about it in snarky internet comments isn’t going to get you anywhere.

    In what fantasy land is the following any different?

    > talk to your local Congresscritter and ask them to propose a bill to amend or remove it