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SBA’s July 2013 Small Business Subcontracting Revisions Finally Implemented in the FAR

Client Alert | less than 1 min read | 07.21.16

On July 14, 2016, DoD, GSA, and NASA published a final rule implementing numerous updates to the FAR to account for regulatory changes affecting the small business subcontracting requirements made by the SBA dating back to July 2013. These changes, which become effective November 1, 2016, range from requiring prime contractors to assign NAICS codes to subcontracts, to providing contracting officers the discretion to establish subcontracting goals at the order level of IDIQ contracts, to protecting subcontractors’ ability to discuss payment or utilization matters with the contracting officer.

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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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