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OMB Expands FAPIIS to Cover Grants and Cooperative Agreements

Client Alert | less than 1 min read | 07.28.15

On July 22, 2015, OMB issued final guidance that – effective January 1, 2016 – expands the Federal Awardee Performance and Integrity Information System (FAPIIS) to cover federal grants and cooperative agreements. Applicants and recipients will have to disclose significant information about civil, criminal, and administrative proceedings that occurred in connection with the award or performance of a federal grant, cooperative agreement, or contract; for their part, agencies must consider information in FAPIIS prior to award as part of the analysis of the applicant's integrity and performance history.


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....