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What The Far Council Giveth The Dar Council Taketh Away

Client Alert | 1 min read | 12.20.06

After several years of consideration, the FAR and DAR Councils published three related sets of regulations in the Federal Register on December 12, 2006, addressing controversial issues about time and material (T&M) and Labor Hour (LH) contracts (see notice on left about upcoming webinar on these regulations). The FAR Council published two final rules permitting competitively awarded contracts for commercial items to qualify as commercial item contracts (with important limitations, including unprecedented rights to interview employees as part of a standard audit) and permitting contractors to bill for work performed by subcontractors on T&M/LH contracts in one of three ways (leaving it to each individual agency to decide which method to permit on the agency’s contracts), while the DAR Council published an interim rule adopting the method of billing subcontractor labor that is likely to be least attractive to industry.

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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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