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On January 5, New York City Mayor Zohran Mamdani issued two executive orders aimed at increasing scrutiny of pricing practices that the City views as contributing to affordability concerns. Executive Order 9 addresses certain add-on or post purchase charges commonly referred to as "junk fees," while Executive Order 10 targets subscription enrollment and cancellation practices described by City officials as "subscription tricks and traps."
Executive Order 9 centers on fee transparency. It establishes an interagency task force to coordinate the City's approach to identifying and addressing fees that are allegedly disclosed late in the transaction process or presented in a manner the City considers misleading. The order instructs the Department of Consumer and Worker Protection (DCWP) to investigate such practices, monitor compliance, and pursue enforcement where appropriate under current law. Although the order does not define the scope of covered fees, it signals heightened attention to pricing practices that increase the final cost to consumers beyond the advertised price.
Executive Order 10 focuses on subscription-based business models. The order highlights practices such as automatic renewals following free or discounted trial periods and cancellation processes that require multiple steps or are difficult for consumers to locate. It directs the DCWP to coordinate with other enforcement bodies, including the the New York Attorney General's Office, and to develop recommendations for potential City Council legislation. The order also authorizes DCWP to investigate and enforce alleged violations related to subscription practices using its existing tools.
While neither executive order creates new substantive prohibitions, both direct City agencies to more actively use existing consumer protection authorities to address fee transparency and subscription practices. The orders emphasize investigation, monitoring, interagency coordination, and enforcement under current law rather than the adoption of new regulatory standards.
Putting It Into Practice: The executive orders reflect a broader pattern of state and local regulators asserting consumer protection authority as federal policy continues to shift. Companies operating in New York City, particularly those using subscription models or layered pricing structures, should reassess disclosures, enrollment flows, renewal terms, and cancellation mechanisms for compliance with existing local consumer protection standards.
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