Recipe for a ROSCA violation
From the FTC’s perspective, a certain pattern of online business has become a recipe for consumer injury. Start with a misleading “risk-free” trial offer. Add a hefty undisclosed charge if consumers don’t quickly cancel the “risk-free” trial. Cook up an undisclosed automatic shipment program that sends consumers unordered merchandise. Top with hard-to-follow upsells that add another layer of confusion. Fold in illegal charges to consumers’ credit...