CFA, along with the National Consumer Law Center and National Consumers League filed two letters to the Hearing Officer presiding over a series of informal hearings regarding the FTC’s popular Click to Cancel (Negative Option) rulemaking. The groups highlighted weaknesses in the arguments used by trade groups to slow down a rulemaking to address unfair and deceptive subscription practices that drain billions of dollars from consumers without their knowledge or affirmative consent. These comment letters urge the Hearing Officer to reject the biased statements of witnesses hired by trade groups to author a last minute conclusory report about the economic impacts of the Rule and permit the FTC to move forward with its Click to Cancel proposal.