Hum... To be fair, it's extremely unlikely that something like this, that impacts about every company that sells subscriptions can have an impact lower than $100 million.

I have no idea why the US FTC didn't do an impact analysis. I have no idea even how they decided of deadlines for compliance without one. (It's not easy to write a decision like this without some data.)

But yeah, the US consumer protection is really lacking, and this decision only reinforces it.