1. Home
  2. |Insights
  3. |Equality For All - OMB Instructs Agencies To Ignore GAO And Give Equal Consideration To Three SBA Programs

Equality For All - OMB Instructs Agencies To Ignore GAO And Give Equal Consideration To Three SBA Programs

Client Alert | less than 1 min read | 07.23.09

On July 10, 2009, OMB instructed agencies to continue to adhere to the SBA's "parity" regulations despite two recent GAO decisions-Mission Critical Solutions, 2009 CPD ¶ 93, and Int'l Program Group, Inc., 2008 CPD ¶ 172-that required agencies to prioritize Historically Underutilized Business Zone ("HUBZone") small businesses over 8(a) Program participants and Service Disabled Veteran Owned Small Businesses in satisfying the agencies' acquisition requirements. OMB explained that the GAO decisions were not binding and instead instructed agencies to consider multiple small business programs pursuant to their existing contracting practices and the SBA's "parity" policies.

Insights

Client Alert | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....