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FERC/NERC Compliance Guidance Amid Potential Coronavirus Impacts

Client Alert | 1 min read | 03.19.20

The Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC) jointly issued compliance guidance notifying NERC-registered entities that they will consider the impact of the coronavirus outbreak as an acceptable basis for noncompliance with certain NERC Reliability Standards and related activities, as follows: 

  • Noncompliance with obtaining and maintaining personnel certification under PER-003-2, for the period March 1, 2020 through December 31, 2020, except that registered entities must notify their Regional Entities and reliability coordinators when using system operator personnel that are not NERC-certified.
  • Noncompliance with Reliability Standard requirements involving periodic actions that would have to be taken between March 1, 2020 and July 31, 2020, except that registered entities must notify their Regional Entities of any periodic actions that will be missed during this period.
  • Regional Entities will postpone on-site audits, certifications, and other on-site activities through July 31, 2020.
  • Registered entities should communicate any coronavirus-related resource impacts associated with remote activities to their Regional Entities.

Please contact us if you have any questions regarding this 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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