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Compound Interest On CAS

Client Alert | 1 min read | 08.31.07

In Raytheon Co. (Aug. 22, 2007), the ASBCA held that segment closing adjustments under CAS 413 should be treated as "CAS noncompliances," making interest due on the adjustment from the date of the segment closing, and that the interest calculation is to be compounded daily because the Internal Revenue Code (IRC) requires that the IRS interest rate applicable by cross-reference from the CAS statute be compounded daily. It does not appear that the contractor argued -- and the Board therefore did not address -- that the CAS statute incorporates into CAS only the section of the IRC containing the interest rate, 28 U.S.C. 6621, not the section of the IRC requiring compounding daily, 28 U.S.C. 6622, or that the interest rate due for contracts awarded before the cross-reference to the IRC was added to the CAS statute should be subject to the prior rates that applied to those contracts.

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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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