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NISPOM, Including Revised Personal Reporting Requirements and Reduced FOCI Mitigation Burden, Codified in Code of Federal Regulations

Client Alert | 1 min read | 12.22.20

Yesterday, the Office of the Under Secretary of Defense for Intelligence & Security, Department of Defense (DoD) published a final rule codifying the National Industrial Security Program Operation Manual (NISPOM) (DoDM 5220.22) into 32 C.F.R. Part 117. For the most part, this action simply inserts the long-applicable NISPOM requirements into the CFR, but DoD has taken this opportunity to formalize two additional changes applicable to cleared contractors. First, the new regulation will incorporate mandatory reporting concerning any cleared personnel's foreign contacts and foreign travel, a requirement initially established by Security Executive Agent Directive (SEAD) 3, “Reporting Requirements for Personnel with Access to Classified Information or Who Hold a Sensitive Position” (12 June 2017) for the purpose of more continuously monitoring activities that can affect an individual's national security eligibility. Second, the final rule will implement Section 842 of the 2019 National Defense Authorization Act, which, effective October 1, 2020, removed the requirement that an agency issue a national interest determination (NID) before a foreign-owned entity holding a facility clearance by virtue of a Special Security Agreement may access “proscribed information” (e.g., Top Secret information) where its ultimate and intermediate foreign parents are located in a country within the U.S. national technology and industrial base as defined in 10 U.S.C. § 2500 ( currently Australia, Canada and the U.K.). Comments on the addition of the NISPOM to the CFR may be submitted through February 19, 2021, and the regulation formally becomes effective on February 24, 2021.

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Client Alert | 3 min read | 08.03.26

New Jersey Takes Aim at Algorithmic and Surveillance Pricing: What Landlords and Retailers Need to Know About the FAIR Act and the Fair Price Protection Act

On July 20, 2026, New Jersey Governor Mikie Sherrill signed the Forbidding the Algorithmic Inflation of Rent (FAIR) Act into law, making New Jersey the fourth state to regulate algorithmic rent-setting practices. Three days later, on July 23, 2026, Governor Sherrill signed the Fair Price Protection Act, which targets “surveillance pricing”—the practice of using or collecting personal data about a user and using an algorithm or artificial intelligence to charge different consumers different prices for the same products. Together, these laws represent a significant expansion of New Jersey's consumer protection framework in the algorithmic pricing context....