The Keeps TRT settlement with the New York Attorney General, concluded August 24, 2026, requires Thirty Madison, Inc. — parent company of Keeps — to pay $400,000 to the state and overhaul how it discloses subscription terms, auto-renewal policies, and cancellation rights. The action follows an investigation by AG Letitia James's office that found the company hid fees, buried auto-renewal terms before checkout, and erected multi-step email barriers to obstruct customers who tried to cancel.
Independently researched · Last updated October 2026 · Alexandru Vieru · Affiliate disclosure
Keeps TRT Settlement: What the NY AG Found
The investigation behind the Keeps TRT settlement centered on three distinct practices the AG's office found violated New York consumer protection law:
1. Hidden subscription terms. Customers were not clearly shown that they were entering a recurring billing subscription before completing payment. The pricing page and checkout flow did not surface the ongoing monthly commitment in a way that met the NY AG's disclosure standard.
2. Undisclosed auto-renewal and non-refundable fees. The existence of auto-renewal — the policy that the subscription renews automatically unless cancelled before a billing date — was not presented at the point of purchase. Non-refundable fee terms were similarly buried. Under New York law, auto-renewal and the fees associated with it must appear prominently before a customer pays.
3. Multi-step cancellation obstruction. To cancel, customers had to complete multiple steps and respond to a series of escalating retention emails before the company honored the cancellation request. The AG's complaint quotes the company's own process as requiring customers to "complete multiple steps to cancel their subscriptions, causing consumers to receive several additional emails before the company honored a request to cancel." The AG identified this pattern as a deliberate barrier to exit — a dark pattern in subscription billing.
The AG's press release describes the overall conduct as "deceiving" customers, a characterization reflected in the official announcement URL.
Keeps TRT Settlement Terms: What Thirty Madison Must Do
The Keeps TRT settlement is not a fine in the traditional sense — it is an Assurance of Discontinuance (AOD), a binding agreement in which the company admits to no wrongdoing but commits to specific operational changes under court supervision. The terms require Thirty Madison to:
- Pay $400,000 to the state of New York within the timeline set by the AG
- Disclose subscription terms before payment: subscription pricing, billing frequency, auto-renewal terms, and non-refundable fee policies must all be shown clearly on the checkout page before a customer clicks to pay
- Process cancellations rapidly, without requiring the customer to navigate multi-step email sequences or respond to retention messages before the cancellation is honored
- Refund subscribers who filed complaints about being billed without clear disclosure
- Provide restitution to customers who were charged after they requested cancellation, or who paid for products that were never shipped
- Automatically process certain categories of refunds without requiring the affected customer to file a separate claim
Notably, the Keeps TRT settlement does not require the company to change its subscription pricing model, exit any product category, or alter clinical protocols. The settlement is entirely about disclosure and cancellation — whether the model was communicated clearly, and whether customers could exit it without obstruction.
Timeline: How the Keeps TRT Settlement Came About
| Date | Event |
|---|---|
| Unknown | NY AG's consumer protection bureau opens investigation into Keeps / Thirty Madison |
| 2026-08-24 | Keeps TRT settlement concluded — Assurance of Discontinuance signed |
| 2026-08-30 | Settlement and regulatory action recorded in our editorial data |
| 2026-10-02 | This article published |
The timeline of the underlying investigation is not disclosed in the AG's press release, which is standard for AOD agreements — the investigation process is confidential until a resolution is announced.
Context: Keeps TRT Settlement in a Wave of Subscription Enforcement
The Keeps TRT settlement is not an isolated action. It is part of a broader enforcement wave targeting online health subscription services that use dark-pattern billing.
FTC vs. Hims & Hers (July 2026): A parallel federal enforcement action filed by the FTC against Hims & Hers in July 2026 alleges structurally identical subscription obstruction — multi-step cancellation loops — alongside a separate allegation that Hims shared patient health data with Meta and Snap advertising platforms. State AG enforcement and federal FTC enforcement address the same consumer harm through different jurisdictions, and both actions were filed or concluded in 2026.
Why online TRT clinics are a target: Subscription health services are high-value enforcement targets for consumer protection regulators because the harm pattern is predictable: a customer signs up for what they believe is a one-time or easily cancellable service, discovers the billing recurs automatically, attempts to cancel, encounters friction, and ends up paying multiple unwanted billing cycles before extraction. When that cycle involves health-related products and the amounts are meaningful, the harm is compounded. The Keeps TRT settlement, the Hims FTC case, and similar actions against non-health subscription services all follow this template.
What the Keeps TRT settlement does not address: The settlement is limited to New York's jurisdiction and concerns billing practices, not clinical quality. It does not make a finding about Keeps' medical protocols, provider network, lab quality, or treatment outcomes.
What the Keeps TRT Settlement Means for Current Subscribers
If you are currently a Keeps subscriber and want to cancel: Under the settlement's binding terms, Thirty Madison must process your cancellation rapidly and without requiring you to navigate a multi-step email sequence. If you encounter resistance — multiple retention emails, a "confirm cancellation" loop, or a billing charge after you submitted a cancellation request — the NY AG's consumer protection bureau is the enforcement authority for the Keeps TRT settlement terms.
If you were charged after a cancellation request: You may be entitled to restitution under the settlement. The Keeps TRT settlement requires Thirty Madison to refund customers who were billed after requesting cancellation, subject to the timeline and claim process set out in the AOD.
If you were billed for products that were never shipped: This is a separate restitution category under the settlement. Contact the AG's office or the company's compliance channel (required by the settlement to be responsive) for the claim process.
Your medical records and prescription history are unaffected. The Keeps TRT settlement covers billing and subscription practices exclusively. Any existing prescription, lab record, or treatment plan held by the clinic is governed by HIPAA and state medical records law, neither of which the settlement touches.
How We Score Transparency in Our Rankings
Our editorial methodology includes a Transparency criterion that covers pricing disclosure alongside regulatory compliance history. The Keeps TRT settlement is a scored event under this criterion: a concluded state AG action that found deceptive billing practices is a material data point about whether a clinic meets the disclosure standard we require for a full Transparency score.
A settlement is a trigger, not a permanent ceiling. Our methodology documents the specific evidence we look for before reconsidering the Transparency score after a regulatory event: the live checkout flow must show subscription terms before payment; the cancellation path must complete in a single step; refunds to affected customers must have been processed as required by the settlement terms. A promise of better practices in a settlement document is not the same as better practices in the production checkout flow — we verify the latter, not the former.
We conduct this review during the monthly maintenance cycle. The next scheduled review of the Keeps TRT settlement lift criteria is the Monthly Strategy run on the first of each month. Until that review produces independent verification of the remediated checkout flow, the Transparency score reflects the settlement finding.
Alternatives With Transparent Pricing
If billing transparency is a deciding factor, these clinics from our current rankings publish their ongoing monthly rates on their public websites before checkout, with no hidden fees reported:
| Clinic | Starting Price | Method |
|---|---|---|
| Male Excel | $99/mo membership + cream from $132/mo | Cream (needle-free) |
| Try Ageless | $129/mo | Injectable / topical / oral |
| Peter MD | $79/mo via our link | Injectable or enclomiphene |
| DudeMeds | $77/mo | Injectable |
| MangoRx | $149/mo | Injectable + oral Kyzatrex |
Our featured pick: Male Excel — needle-free compounded testosterone cream; pricing published on the public website before checkout; month-to-month membership with no multi-step cancellation reported. Male Excel holds the top spot in our overall TRT clinic rankings for pricing transparency alongside clinical oversight.
For a cost comparison across all clinics we have ranked — including those without active affiliate partnerships — see Cheapest Online TRT Clinics 2026 →.
FAQ: Keeps TRT Settlement
What is the Keeps TRT settlement? The Keeps TRT settlement is a binding agreement (Assurance of Discontinuance) between Thirty Madison, Inc. — parent company of Keeps — and the New York Attorney General. Concluded August 24, 2026, it resolves an investigation into hidden subscription fees, undisclosed auto-renewal terms, and multi-step cancellation obstruction. The settlement requires a $400,000 payment to New York State and specific operational changes to how Keeps discloses and processes subscriptions.
Does the Keeps TRT settlement mean Keeps is closing? No. The Keeps TRT settlement does not require Thirty Madison to cease operations, exit the TRT market, or change its clinical model. It requires billing disclosure and cancellation processing changes. Keeps continues to operate under the Titan brand at jointitan.com.
Who is covered by the Keeps TRT settlement refunds? Customers who filed complaints about being billed without clear disclosure, customers charged after requesting cancellation, and customers who paid for products that were never shipped may be eligible for refunds or restitution. The specific claim process is set out in the Assurance of Discontinuance, which the NY AG's consumer protection bureau oversees.
Is the Keeps TRT settlement the same as the Hims lawsuit? No. They involve different companies and different legal frameworks. The Keeps TRT settlement is a state-level AOD between Thirty Madison (Keeps) and the New York AG's office. The Hims case is a federal FTC enforcement action filed in July 2026 against Hims & Hers. Both allege similar subscription dark patterns, but they are separate proceedings involving separate entities.
How does the Keeps TRT settlement affect the clinic's score on this site? A concluded state AG settlement finding deceptive billing practices is a scored input to our Transparency criterion. See the methodology section above for the specific evidence we look for before reconsidering the score.
Related Reading
- Hims TRT Review — FTC Lawsuit Filed July 2026 →
- Best Online TRT Clinics: Full Rankings →
- Cheapest Online TRT Clinics 2026 →
- Male Excel Review: Needle-Free Testosterone Cream →
Affiliate disclosure: Some links in this article are affiliate links. We may earn a commission if you click through them, at no extra cost to you. Our rankings are never influenced by affiliate relationships. Full disclosure →
Regulatory information sourced directly from the New York Attorney General press release (August 24, 2026).
