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Raise Confirmed! DoD Finalizes Doubling of CPSR Threshold

Client Alert | 1 min read | 01.10.20

Effective December 31, 2019, the DoD issued a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to establish a DoD contractor purchasing system review (CPSR) threshold of $50M at DFARS 244.302, doubling the existing $25M threshold at FAR 44.302(a). The final rule adopts the proposed rule (discussed here) without any substantive changes. In response to a comment, the final rule clarifies that contractors whose relevant sales have not reached the new threshold may opt to allow their approval to expire rather than incur the costs to maintain a system that meets the criteria for an approved system; in that case, the Government and contractor would continue with consent packages. But, if an approved purchasing system is necessary to support a particular program, the contractor can work with the contracting officer to obtain a CPSR based on risk or pressing need. The final rule also notes that it is a simple increase in the threshold, and does not impact any existing provisions or clauses.

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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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