How Big Business killed the 'click-to-cancel' FTC rule, which would have saved

The FTC failed to comply with 15 U.S.C. § 57b-3(b)(1), which states that the agency “shall issue a preliminary regulatory analysis” whenever it proposes a rule expected to have a significant economic impact.

After its own ALJ found the rule’s effect would exceed $100 million annually, the FTC was obligated to publish an analysis of the “projected benefits and any adverse economic effects and any other effects” and the effectiveness of alternatives, as required by § 57b-3(b)(1)(C).