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OMB Directs Agencies to Prepare for Sequestration

Client Alert | less than 1 min read | 12.12.12

OMB has recently issued internal guidance directing agencies to begin preparing for sequestration, prompting numerous agencies to reveal their intent to furlough employees, reduce office hours, and scale back or eliminate contracts should budget cuts occur as scheduled in January 2013. While the White House denied that the guidance signals pessimism about a budget deal, and events over the weekend suggest that the broad outlines of an agreement are coming together, the release of the guidance nonetheless recognizes that the time remaining for negotiating a resolution to avoid sequestration is growing short.


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....