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OHA Authority and Impact Expanded

Client Alert | 1 min read | 02.11.11

On February 2, 2011, the Small Business Administration issued a final rule amending its regulations, effective March 4, 2011, to expand and better define the authority of SBA's Office of Hearings and Appeals (OHA) by allowing for OHA review of all timely appeals of size determinations, whereas traditionally OHA would not review formal size determinations if the contract had been awarded and the issues ripe for review were contract specific, including joint venture issues and violations of the ostensible subcontractor and non-manufacturer rules. Additionally, OHA now has to issue decisions within 60 days of the close of a record, and if OHA affirms a size determination finding a protested concern to be other than small the contracting officer must terminate the contract or not exercise the next option.

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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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