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Last Chance to Comment on FASC Rule – More Supply Chain Restrictions Coming

Client Alert | 1 min read | 10.28.20

Companies have less than one week to submit comments regarding a recent interim rule that provides the responsibilities, processes, and procedures for the Federal Acquisition Security Council (FASC), established by the Federal Acquisition Supply Chain Security Act of 2018.  Under the immediately effective interim rule, the FASC is responsible for assessing supply chain risk and making removal and exclusion recommendations to the Secretary of the Department of Homeland Security (DHS), Secretary of the Department of Defense (DoD), and Director of National Intelligence (DNI).  Based on these recommendations, DoD, DHS, and the Office of the DNI (ODNI) then have authority to issue exclusion and removal orders for sources and/or covered articles deemed to pose a supply chain risk from certain procurements.

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Client Alert | 3 min read | 02.26.26

FERC Requires Refunds for Late QF Recertification

On February 19, 2026, the Federal Energy Regulatory Commission (FERC) issued Branch Street Solar Partners, LLC et al., 194 FERC ¶ 61,124 (2026) rejecting the refund reports filed in connection with the late filing of recertifications of qualifying facility (QF) status by certain affiliated companies to reflect a change in upstream ownership. FERC’s rearticulation of QF recertification timing requirements and consequences for late QF recertifications has broad and substantial implications for all QF owners. ...