What is the group opinion on the Restore Online Shoppers' Confidence Act?

[Tim Prendo]

 Hi All,

The US congress passed ROSCA in 2010, it states:

ROSCA makes it unlawful for any post-transaction third party seller to charge or attempt to charge a consumer's credit card, debit card, bank account or other financial account for any good or service sold over the Internet, unless the post-transaction third party seller has clearly and conspicuously disclosed to the consumer all material terms of the transaction

http://www.perkinscoie.com/overview-of-the-restore-online-shoppers-confidence-act-01-24-20111/

Doesn't a transfer of credit card data to a third party payment processing provider violate this law?  (well not the transfer itself, but as soon as the new provider charges the customer's card they may be breaking this law)

While i am in full agreement with the market-need and the objectives of this initiative, i am unclear if these legal concerns have been addressed.

Thanks for your thoughts all.

Tim