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NYC Delays Enforcement of Automated Employment Decision Tools Law

Client Alert | 1 min read | 12.13.22

New York City has just announced that it will delay enforcement of Local Law 144, which will require employers and employment agencies using automated employment decision tools to ensure that a bias audit is conducted prior to the use of such tools, and will require notice of the use of such tools to covered candidates or employees.  The NYC Department of Consumer and Worker Protection is planning a second public hearing on the law, due to the high volume of public comments received in response to its proposed rules.  The agency is currently planning to delay enforcement of the rule until April 15, 2023.  We will continue to monitor for updates.

Insights

Client Alert | 3 min read | 02.11.26

Clicking All the Right Boxes: FTC Moves to Revive “Click-to-Cancel” Rule Following Eighth Circuit Vacatur

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates....