Significant Changes on the Horizon to the Limitations on Subcontracting
Client Alert | 1 min read | 01.14.15
On December 29, 2014, the Small Business Administration issued long overdue proposed amendments to its regulations (with 60 days for comments) to implement many of the provisions of the National Defense Authorization Act of 2013, most notably with a complete overhaul of the calculation of the limitations on subcontracting. Additional proposed revisions include: greater specificity to the identity of interest affiliation test; exemptions from affiliation for small business joint venture members and "similarly situated" subcontractors; a new recertification requirement for mergers/acquisitions occurring after proposal submission but prior to award; changes to the nonmanufacturer rule; and a new reporting mechanism and expanded sanctions related to subcontracting plan compliance.
Insights
Client Alert | 3 min read | 07.18.25
Eighth Circuit Cancels Click-to-Cancel
On July 8, 2025, the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Negative Option Rule, also known as the Click-to-Cancel Rule, on procedural grounds. The Click-to-Cancel Rule, which provided a streamlined path for consumers to cancel subscription services in a few clicks of a mouse, was scheduled to take effect on July 14, 2025, but the Court found that the FTC had failed to follow mandatory procedural requirements.
Client Alert | 9 min read | 07.18.25
U.S. Lifts Most Sanctions on Syria in Major Policy Development
Client Alert | 6 min read | 07.17.25
Client Alert | 3 min read | 07.17.25
(Not the Funniest) Weekend Update: Recap of Recent Developments in the EU-US Tariff Dispute
