The FTC After Slaughter: What Businesses Need to Understand | JD Supra

The US Supreme Court overturned the 90-year-old Humphrey's Executor doctrine on 29 June 2026, ruling that the President can remove FTC Commissioners at will rather than only for cause, shifting agency priorities to align with presidential administrations. Businesses now face shorter regulatory cycles, faster settlements, and the risk of reopened consent orders from prior administrations, but also reduced long-term regulatory predictability. Your FTC consent order just became temporary. If you signed one in the last administration and disagree with the current FTC Chair, you now have grounds to reopen it—and the FTC itself will move faster to close cases before the next election. Plan for 10-year orders, not 20.