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New Rule Prescribes Data Required for Adequate Final Indirect Cost Rate Proposal

Client Alert | 1 min read | 06.02.11

On May 31, 2011, the FAR Council published a final rule governing contract closeout requirements, including the identification of a long list of data items required for a final indirect cost rate proposal to be found "adequate," as well as additional types of data that the government can request to supplement a proposal; clarification of the division of duties between the CO and auditors with respect to auditing and finalizing the proposal; and the requirement that mandatory withholdings be exacted by the CO for contractors who fail to timely submit an adequate proposal. While the rule does not require that proposals be submitted using any particular format in order to qualify as "adequate," it remains unclear what will happen in individual cases if DCAA refuses to commence an audit because the contractor declines to provide the burdensome cost schedules required by the DCAA "model" format.

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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....

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