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Setting the Floor: New FAR Rule Defines Minimum Contractor Information System Safeguarding

Client Alert | 1 min read | 05.17.16

Shifting approaches, on May 16, 2016, the FAR Council concluded a long-running rulemaking with a final rule and a new clause, FAR 52.204-21, that will establish minimum security controls pulled from NIST Special Publication 800-171 over contractor information systems that may process, store, or transmit “Federal contract information,” defined as information provided to or generated under any government contract (except for COTS) that is not intended for public release. Future rules will address more specific controls applicable to more sensitive information such as Controlled Unclassified Information (CUI), but this rule focuses instead on establishing those baseline controls the FAR Council believes any prudent business would implement in relation to its information systems and does not replace more stringent security requirements like those in the DFARS Safeguarding Rule.

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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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