Published in Law360 on July 10, 2026. © Copyright 2026, Portfolio Media, Inc., publisher of Law360. Reprinted here with permission.

For the recipient of a subpoena from a state attorney general or other state regulator, the prospect of successfully blocking the subpoena through litigation can seem dim.

On July 7, the U.S. Securities and Exchange Commission (SEC) announced the creation of a new Retail Fraud Working Group within its Division of Enforcement. The initiative represents a structural expansion of the SEC’s enforcement capabilities and has direct implications for broker-dealers, investment advisers, and other regulated entities that serve retail clients. This is consistent with prior statements made by SEC Chairman Paul S. Atkins about focusing the SEC’s Division of Enforcement on protecting retail investors.

In this episode of Payments Pros, host Keith Barnett examines a recent FTC enforcement action involving alleged violations of the FTC Act and ROSCA. Keith discusses the FTC’s continued focus on negative option features, automatic renewals, subscription disclosures, free trial conversions, and cancellation practices, and explains why these issues remain important for companies operating in the payments ecosystem. He walks through the FTC’s allegations regarding insufficient disclosure of key subscription terms, including automatic renewal provisions and early cancellation fees, as well as concerns about burdensome cancellation processes for consumers. Keith also highlights how the action reflects a broader enforcement trend, with the FTC remaining active in the payments space despite increased attention on changes at the CFPB. The episode closes with practical takeaways for businesses, including the importance of clear disclosures, simple cancellation mechanisms, and careful internal communications regarding subscription and billing practices.

On June 30, 2026, New Jersey enacted legislation A5328 (P.L.2026, c.25), which will expose a broad swath of U.S. companies to data broker registration fees ranging from $5,000 to $1.5 million annually. The new legislation is not limited to data brokers in the conventional sense. It applies generally to any company that sells or licenses personal data of New Jersey residents, including those with direct customer relationships. Much of the law takes effect immediately, so companies should begin reviewing the requirements now to comply.

On June 26, 2026, Florida Attorney General (AG) James Uthmeier and Roku, Inc. announced a negotiated resolution of Florida’s enforcement action filed under the Florida Digital Bill of Rights (FDBR). Under the agreement, Roku will enhance its child protection features by giving parents greater control over their children’s streaming experience. The resolution includes no finding of wrongdoing and no civil fine.

On June 29, 2026, the U.S. Food and Drug Administration (FDA) published a notice of proposed rulemaking (NPRM) titled “Establishment Registration and Product Listing for Tobacco Products,” which would, for the first time, require foreign tobacco product manufacturers to register their manufacturing establishments and list their products with the agency. Domestic manufacturers are already subject to these registration and listing requirements; foreign manufacturers are not. This regulation, if finalized, would close that gap.

Political activities sit at the intersection of law, policy, and reputation. Companies operating in highly regulated industries cannot avoid political law issues, and it is frequently more complex than expected.

This quarterly newsletter highlights a few practical issues we are seeing with clients and a handful of developments worth keeping on the radar.

Signed into law on June 9, 2026, Louisiana’s Click-to-Cancel Act imposes new auto-renewal disclosure, consent, and cancellation requirements on businesses, with compliance required by January 1, 2027.

Louisiana has enacted House Bill 750, officially titled the Click-to-Cancel Act. The act applies broadly to any person conducting business in Louisiana that offers consumers an automatic renewal contract — defined as any paid subscription or purchasing agreement that renews automatically at the end of a definite term or on a recurring basis. Louisiana joins a national trend, alongside California’s comprehensive Auto-Renewal Law and the Federal Trade Commission’s (FTC) federal “click-to-cancel” rulemaking regarding subscription billing. Businesses with recurring-charge models should begin preparing now.

On June 18, 2026, Pennsylvania Attorney General (AG) Dave Sunday announced a settlement with Infinity Dental Management, LLC, which operated as Alpha Dental Excellence, a southeastern Pennsylvania-based dental group, as well as a related entity and the company’s owner, over alleged deceptive sales practices involving elderly and low-income patients.