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White House Delegates Title III DPA Authority to U.S. International Development Finance Corporation

Client Alert | 1 min read | 05.15.20

On May 14, the President issued an Executive Order (EO) delegating funding and loan authority under Title III of the Defense Production Act (DPA) to the U.S. International Development Finance Corporation (DFC) to support domestic production of strategic resources to respond to the COVID-19 outbreak and strengthen domestic supply chains. The DFC’s loan authority under the EO is limited to loans that “create, maintain, protect, expand, or restore domestic industrial base capabilities” supporting “the national response and recovery to the COVID-19 outbreak” or “the resiliency of any relevant domestic supply chains.” Thus, while Congress established the DFC in 2018 to foster America’s investment in overseas development projects, the DFC now is expected to establish a separate investment team to, among other responsibilities, administer loans for this domestic support and to issue new implementing regulations.

Insights

Client Alert | 3 min read | 02.11.26

Clicking All the Right Boxes: FTC Moves to Revive “Click-to-Cancel” Rule Following Eighth Circuit Vacatur

On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates....