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White House and Military Departments Release Guidance as (Another) Budget Deadline Approaches

Client Alert | 1 min read | 01.18.13

In the past week, OMB, DoD, Army, Air Force, and Navy have all released guidance directing their subordinate entities to begin planning for the possibility of sequestration (presently scheduled to result in the cancellation of approximately $85 billion in FY13 budgetary resources) beginning on March 1, 2013, and for the expiration of the FY13 Continuing Appropriations Resolution (which expires on March 27, 2013, and must either be extended or replaced with new appropriations acts to prevent a lapse in appropriations and government shutdown). While the guidance cautions that efforts to prevent sequestration and ensure continued appropriations are underway, the memos acknowledge that, as a practical matter, agencies must begin planning for the possibility that they will need to operate with dramatically reduced budgetary resources.


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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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