Ambiguous Instructions Give Disqualified Offeror A Second Chance
Client Alert | less than 1 min read | 06.12.07
The Court of Federal Claims in Heritage of Am., LLC v. U.S. (May 31, 2007) set aside a disqualification of an offeror when the solicitation instructions were unclear about the coverage and labor rates required in the multiple regions solicited, requiring a recompetition with unambiguous instructions. In the prior, related GAO protest, GAO had refused to consider this issue because it was "untimely," but Judge George Miller in this opinion joins the solid majority of the CFC judges holding that GAO timeliness requirements are inapplicable in court protests.
Insights
Client Alert | 7 min read | 09.02.26
OCC and FDIC Redefine “Unsafe or Unsound Practices”: The New Supervisory Framework for Banks
On August 27, 2026, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) jointly issued a final rule that, for the first time, gives the term “unsafe or unsound practice” a binding regulatory definition.[1] With it came a uniform standard for Matters Requiring Attention (MRAs) and revised OCC examination manuals.[2]The Federal Reserve did not join the rulemaking, but has adopted comparable standards through guidance. What that means for holding companies and state-chartered institutions is addressed below.[3] The regulation takes effect November 2, 2026, and the revised OCC examination manuals took effect upon their issuance on August 27.
Client Alert | 4 min read | 09.02.26
The CSC Is Investigating: What Its New NIL Enforcement Memo Means for Institutions
Client Alert | 4 min read | 08.27.26
FCC Clarifies Covered List for Power Inverters and Advanced Robotic Devices
Client Alert | 4 min read | 08.27.26
Power Play: New Executive Order Targets Electrical Grid Equipment
