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No More "Wait & See" for CMMC: DoD Releases Final Cybersecurity Maturity Model Certification

Client Alert | 1 min read | 02.03.20

The Department of Defense (DoD) has released Version 1.0 of the Cybersecurity Maturity Model Certification (CMMC), Appendices A-F, and an Overview Briefing. While Version 1.0 largely mirrors the draft Version 0.7, the final version includes notable revisions, such as:

  • Process and Practice Descriptions in Appendix B, which include discussions and clarifications for every “practice” within each CMMC Level, including the long-awaited examples for Levels 4 and 5; and
  • Source Mapping in Appendix E, which maps each “practice” across all five Levels –171 in total – to other pre-existing cybersecurity frameworks.

Much, however, remains to be done. In anticipation of the DoD adopting “go/no-go” CMMC certification requirements later this year, a privately-run Accreditation Body is expected to begin training third-party assessors (3PAOs) this spring in conducting those certifications for contractors. Simultaneously, the DoD is expected to issue a proposed rule incorporating the CMMC into DFARS 252.204-7012, to be finalized this fall. 


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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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