Transaction Fees, Service Fees, and the FTC’s Proposed Ban on Junk Fees
On October 11, 2023, the Federal Trade Commission (the “FTC”) proposed a new rule to prohibit junk fees. “Junk fees” are understood to mean any (a) hidden fees that are otherwise mandatory but not disclosed to customers upfront before a transaction, typically used in the nature of bait-and-switch tactic or to convey an artificial lower […]