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Comment Period for "Fair Pay and Safe Workplaces" Extended – A Bit

Client Alert | 1 min read | 07.16.15

In response to several requests from industry to extend the a 60-day comment period for the proposed rulemaking (NPRM) and guidance implementing the "Fair Pay and Safe Workplaces Executive Order," the FAR Council and the DoL have extended the comment period to August 11, 2015 (from the current date of July 27, 2015). As discussed previously here, the NPRM and related DOL guidance (available by PDF here and here and explained in more detail on our government contracts blog) would add onerous labor compliance reporting requirements for all contractors and subcontractors on contracts valued over $500,000 (and on non-COTS subcontracts valued over $500,000) and inject uncertainty and subjectivity into the procurement process through the addition of "Agency Labor Compliance Advisors" advising the CO with respect to responsibility determinations based upon a review of the contractor or subcontractor’s labor compliance data over a three-year period, which has prompted many contractors and trade associations to express their concerns about the scope and potential impacts of the Proposed Rule and Guidance.


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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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