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NYC Delays Enforcement of Automated Employment Decision Tools Law

Client Alert | 1 min read | 12.13.22

New York City has just announced that it will delay enforcement of Local Law 144, which will require employers and employment agencies using automated employment decision tools to ensure that a bias audit is conducted prior to the use of such tools, and will require notice of the use of such tools to covered candidates or employees.  The NYC Department of Consumer and Worker Protection is planning a second public hearing on the law, due to the high volume of public comments received in response to its proposed rules.  The agency is currently planning to delay enforcement of the rule until April 15, 2023.  We will continue to monitor for updates.

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....