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Wake-up Call: GSA Launches Requirement for Schedule Contractors to Reaffirm TAA Compliance

Client Alert | less than 1 min read | 05.06.16

Concerned with repeated instances of FOIA requests and congressional inquiries exposing contractors offering products not compliant with the Trade Agreements Act on their Federal Supply Schedule contracts, on May 5, 2016, GSA began notifying several contractors that, within five business days, they would need to provide certification that products offered were TAA-compliant or remove them from their offering. The breadth of this initiative continues to unfold, but it serves as a caution for contractors to reevaluate their supply chain and the manner in which they offer products on their FSS contracts under the complex “substantial transformation” rules for establishing country-of-origin under the TAA.

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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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