US Court nullifies FTC requirement for click-to-cancel

The FTC was warned at the time that they were flouting required procedures and that their rule would therefore not survive legal scrutiny. Lo and behold it did not.

Please point to an example of these warnings.

> The FTC is required to conduct a preliminary regulatory analysis when a rule has an estimated annual economic effect of $100 million or more. The FTC estimated in a Notice of Proposed Rulemaking (NPRM) that the rule would not have a $100 million effect.

> But an administrative law judge later found that the rule's impact surpassed the threshold, observing that compliance costs would exceed $100 million "unless each business used fewer than twenty-three hours of professional services at the lowest end of the spectrum of estimated hourly rates," the 8th Circuit ruling said. Despite the administrative law judge's finding, the FTC did not conduct a preliminary regulatory analysis and instead "proceeded to issue only the final regulatory analysis alongside the final Rule," the judges' panel said.

It says it in the article

The fact that it takes more than 24 hours to put a 1 click cancel button is alien to me.

You must not work on these sorts of systems. It can easily take more than 24 hours. In case you’re genuinely interested in learning more, here’s how it works.

There are good reasons for it working this way, BTW. The needs of a company with hundreds or thousands of people are different than the needs of hobbyists and early-stage startups.

1. A user experience designer analyzes the user flow and decides where to put the cancellation button. They make decision about style, layout, and wording. This isn’t a ton of work, but something so critical to the company’s business and retention numbers will probably involve a lot of review, discussion, and bike shedding. This could easily take 24 people-hours of work on its own.

2. Somebody programs the front-end change. They probably have to put it behind a feature flag so it’s not visible until the back end is ready.

3. Somebody programs the back-end. They think about security, authentication, authorization, CSRF. That’s probably handled, but again, this is a critical feature and deserves extra care.

4. Somebody programs the interface to the company’s internal systems. They’re usually kind of a pain to work with. Billing, marketing, support, customer success. Something probably sends an email to the user. Maybe there’s a follow up flow to try to get them back with a special offer a month later. Etc.

5. The change is tested. Preferably with automated tests, but a feature like this has tendrils into systems throughout the company, and a lot of moving parts, so manual testing is also important. If it goes wrong, it’s a big deal, involving the potential for chargebacks and lawsuits, both of which are expensive at scale.

Throughout all this, you’re dealing with legacy code, because billing is one of the oldest systems the company has, and the one with the most risk of change, so the code is nasty and doesn’t follow current conventions. Every change is painful and tedious.

It’s alien to you that this could take more than 24 hours? At any company of size, I have trouble imagining it taking less.

How many companies of "size" you know of? Because that process looks HORRIBLY inefficient and only primed to extract as much money of the consumer. You just need to put it in the account screen. A big red button. Your _workflow_ is there to make excuses. If the move was the other way, you would gladly pay the cost, but because it actually hurts your "business model" then it is suddenly a problem. No buddy, I call BS on all that, and call BS on the law itself.