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  3. |A Bold New World? GSA Proposes to Swap Its Price Reduction Clause for Monthly Reporting of All Sales Under Schedule and Other Government-Wide GSA Contracts

A Bold New World? GSA Proposes to Swap Its Price Reduction Clause for Monthly Reporting of All Sales Under Schedule and Other Government-Wide GSA Contracts

Client Alert | 1 min read | 03.06.15

On March 4, 2015, GSA proposed to change dramatically the way it seeks to obtain the lowest and best price for items purchased off Federal Supply Schedule and other Government-wide GSA contracts by largely abandoning the Price Reduction Clause (and the consequent price monitoring of sales to "basis of award" customers) in favor of imposing a requirement that holders of such contracts report, on a monthly basis, specific information on all sales transactions (including unit prices) to authorized users. While the Price Reduction Clause has caused contractors significant compliance difficulties over the years, this proposal, which will be considered at a April 17 public meeting with written comments due May 4, is intended to provide government customers a powerful database tool by which to obtain the best deal from contractors based upon their actual price history and the ability to compare those unit prices with the actual prices being offered by competitors.

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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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