New Executive Compensation Limits
Client Alert | 1 min read | 06.28.13
On June 26, 2013, the government issued an interim rule that purports to expand the application of the executive compensation benchmark, currently set at $763,029, from senior executives to all contractor employees performing on contracts awarded as of December 31, 2011, by DoD, NASA, and the Coast Guard. As discussed in our blog posting, this interim rule, which is effective immediately, is intended to make any compensation costs incurred after January 1, 2012, over the benchmark amount unallowable for contracts subject to the FAR cost principles, but challenges to this rule based on the terms of the Allowable Cost and Payment clause might result.
Insights
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.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
Client Alert | 2 min read | 08.19.26
