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“Fair Pay and Safe Workplaces” Rules Head to White House for Final Review

Client Alert | 1 min read | 05.09.16

On May 4, 2016, the FAR Council’s draft final rules and the Department of Labor’s draft final guidance implementing the “Fair Pay and Safe Workplaces” executive order arrived at the White House’s Office of Information and Regulatory Affairs for review, setting in motion the final steps prior to the issuance of burdensome new compliance and reporting obligations for federal contractors and subcontractors (discussed here). OIRA has 90 days to conduct its review of the rules before sending them to the FAR Secretariat for publication, a period during which OFPP and other OMB offices, contractors, and industry trade groups may meet with OIRA to share their concerns, in advance of the publication of new FAR rules likely to trigger vigorous legal challenges from industry.

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....