> could they argue that they require someone to physically come out to turn off service?
In the case of in-person consent the rule requires that they also offer an online or telephone cancellation option.
> Could they make the signup and cancel process worse at the same time [...]
"must be at least as easy to use as the mechanism the consumer used
to consent to the Negative Option Feature.". I read that it must hold true for every specific consumer based on how hard it was for them to consent.
The rules also sets general restrictions to the online and phone options in addition to the "at least as easy" restriction. For Online the cancellation option must be "easy to find" and explicitly bars forced interaction with representatives or chatbots during cancellation unless they were part of the sign-up process. For Telephone the cancellation must be prompt, the number must be answered or accept voice messages, must be available during normal business hours, and must not be more costly than a call used to sign up.
In the case of in-person consent the rule requires that they also offer an online or telephone cancellation option.
> Could they make the signup and cancel process worse at the same time [...]
"must be at least as easy to use as the mechanism the consumer used to consent to the Negative Option Feature.". I read that it must hold true for every specific consumer based on how hard it was for them to consent.
The rules also sets general restrictions to the online and phone options in addition to the "at least as easy" restriction. For Online the cancellation option must be "easy to find" and explicitly bars forced interaction with representatives or chatbots during cancellation unless they were part of the sign-up process. For Telephone the cancellation must be prompt, the number must be answered or accept voice messages, must be available during normal business hours, and must not be more costly than a call used to sign up.