Exit Clause
Every subscription checked against the cancellation rules companies are supposed to follow — and a ready-to-send demand letter the moment one breaks them.
ExitClause
Every subscription checked against the cancellation rules companies are supposed to follow — and a ready-to-send demand letter the moment one breaks them.
Date: 2026-07-30 Form factor: web app Status: Prototype
What it is
ExitClause pulls in your subscriptions and runs each one through the same four-part test the FTC uses for negative-option billing: same-channel cancellation, no extra steps, no forced retention gauntlet, and immediate effect. Anything that fails gets a violation badge, a running refund estimate for the months you were charged after asking to cancel, and a one-click demand letter that cites the exact rule that was broken.
Who it serves
Anyone who has ever tried to cancel a gym, meal box, or beauty subscription online and been rerouted into a phone tree, a chat bot, or a mandatory retention call. ExitClause is built for the person who knows the charge is wrong but doesn't have the time or legal language to fight it — it does the citation lookup and the letter-writing for them.
Why it could be profitable
Freemium subscription: free to track and scan up to 3 subscriptions; a paid tier (~$6.99/mo or $39/yr) unlocks unlimited subscriptions, auto-generated demand letters, and refund-status tracking. A concierge add-on could take a success fee (e.g. 15%) on refunds it helps recover, mirroring existing chargeback-recovery services.
This is timely because enforcement is actively heating back up: the FTC's 2024 Click-to-Cancel Rule was vacated by the Eighth Circuit in 2025 for a procedural defect, but the agency never stopped pursuing the same conduct under Section 5 of the FTC Act and ROSCA — and in March 2026 it opened an Advance Notice of Proposed Rulemaking to revive the rule outright, with comments due April 13, 2026. Recent enforcement includes an $8.5M Care.com settlement and a record $2.5B Amazon settlement, both for making cancellation harder than sign-up. Consumers are still stuck untangling this on their own in the meantime.
Form factor & scope
Single-page web app. This prototype demonstrates the compliance-scoring engine, the dashboard, and demand-letter generation for a fixed sample portfolio of 15 subscriptions — no live billing or email integrations.
How to run it
- Open
index.htmlin any modern browser. - Browse the subscription list, click any card flagged with a violation to see which rule it broke and the estimated refund owed.
- Click "Generate demand letter" on a flagged subscription to see the auto-filled cancellation and refund request, citing ROSCA and the FTC rule.
- Use the "Show violations only" toggle and the sort control to triage the worst offenders first.
What's in this prototype
- A dashboard summarizing total monthly spend, number of subscriptions with violations, and total estimated refund owed
- A card grid of 15 sample subscriptions loaded from
sample-data.json - A rules engine (in
script.js) that checks each subscription against four click-to-cancel/ROSCA requirements: equal-channel cancellation, step parity, no forced retention gate, and immediate effect - A detail panel per subscription showing which specific rule(s) it violates, with citations
- A demand-letter generator that fills in subscription name, cost, and overbilled months into a ROSCA/FTC-citing template
- A "show violations only" filter and a sort-by-refund-owed control
Roadmap
- Real inbox/bank-statement parsing to auto-detect subscriptions instead of manual entry
- Direct e-sign and send integration (email or certified mail API) for generated letters
- State-law overlay (e.g. California's Automatic Renewal Law, proposed NYC rule) stacked on top of the federal ROSCA baseline
- Refund-status tracking with automated follow-up reminders at day 15/30/45
- Concierge dispute filing with card issuers when a merchant ignores the demand letter
Sources
- FTC Revives Click-to-Cancel Rule: New Risks for Subscription Businesses — Jones Day — timeline of the rule's 2025 vacatur, the March 2026 ANPRM to revive it, and recent enforcement (Care.com $8.5M, Amazon $2.5B)
- FTC Click-to-Cancel Rule: Subscription Compliance Guide 2026 — LegalForge — the four core requirements (disclosure, informed consent, simple cancellation, no retention obstacles) and per-violation penalties up to $51,744
Requirements
ExitClause — Requirements
Goals
- Let a user see, at a glance, which of their subscriptions violate click-to-cancel/ROSCA norms.
- Quantify the dollar amount they're plausibly owed back.
- Produce a legally-grounded cancellation/refund demand letter without the user having to know the citations themselves.
- Make the worst offenders (highest refund owed, most overdue) obvious to triage first.
Primary user
A subscriber who has requested a cancellation (or wants to) and suspects the company is dragging its feet, charging through a forced retention process, or requiring a harder channel to cancel than to sign up. They are not a lawyer and don't want to become one — they want a checklist and a letter.
Functional requirements
- FR1: Load subscription records from
sample-data.jsonon page load. - FR2: Render each subscription as a card showing name, category, monthly cost, and status.
- FR3: Evaluate each subscription against four rules: equal-channel cancellation, step parity, no forced retention gate, immediate effect.
- FR4: Show a violation badge and count on any card that fails one or more rules.
- FR5: Compute and display a portfolio-level summary: total monthly spend, number of subscriptions with violations, total estimated refund owed.
- FR6: Estimate refund owed per subscription as
monthsOverbilled × monthlyCostfor subscriptions with acancelRequestedDateset. - FR7: On card click, open a detail view listing exactly which rule(s) were broken, with their citation text.
- FR8: Provide a "Generate demand letter" action that fills a letter template with the subscription's name, monthly cost, cancellation request date, months overbilled, and the specific rule citation(s).
- FR9: Provide a toggle to show only subscriptions with violations.
- FR10: Provide a sort control to order subscriptions by estimated refund owed (descending) or by monthly cost.
- FR11: Persist no data outside the page — this is a demo, not a real account.
- FR12: Work fully offline after initial load (no required network calls except the CDN-free static assets).
User stories
- As a subscriber, I want to see all my subscriptions in one view with a violation flag, so that I don't have to remember which ones gave me trouble.
- As a subscriber, I want to know exactly which rule a company broke, so that I feel confident escalating instead of guessing.
- As a subscriber, I want a dollar estimate of what I'm owed, so that I know whether it's worth the fight.
- As a subscriber, I want a ready-made letter with the right legal citation, so that I don't have to write it myself.
- As a subscriber, I want to filter to only the subscriptions with problems, so that I can triage quickly.
- As a subscriber, I want to sort by refund owed, so that I go after the biggest wins first.
Non-functional requirements
- Runs entirely client-side; no backend, no API keys, no auth.
- Readable on mobile and desktop via responsive CSS (flex/grid + media queries).
- No real personal or financial data is collected or transmitted — sample data only.
- Accessible color contrast for violation/compliant badges (not color-only signaling — icons/text labels included).
Out of scope (for the prototype)
- Real bank/email integration to auto-detect subscriptions.
- Actually sending letters (email/mail API integration).
- State-law-specific overlays beyond the federal ROSCA/FTC baseline.
- User accounts, authentication, or persistent storage.
Open questions
- Should the concierge success-fee tier require binding arbitration agreements, or stay purely advisory (user sends the letter themselves)?
- How would the product detect subscriptions automatically without requiring risky bank-read access (e.g. Plaid-style aggregation)?
- Does a per-state law overlay (CA ARL, proposed NYC rule) change the letter template meaningfully enough to justify at launch, or is the federal ROSCA citation sufficient for v1?
