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Bad Alchemy: Turning Estimates Into Fraud

Client Alert | less than 1 min read | 02.08.06

Building on comments at the Nash & Cibinic Roundtable, David Bodenheimer challenges the oxymoronic trend of government agencies and qui tam whistleblowers to assert defective pricing or false claims based upon second-guessing poor estimates. In his article "'False' or 'Inaccurate' Estimates" published in the December 2005 Briefing Paper (http://www.crowell.com/pdf/Expertise/GovtContracts/BriefingPapers_Bodenheimer.pdf), he explains that estimating -- due to its inherently risky and predictive nature -- requires judgmental forecasts long recognized as appropriate by government pricing guidelines and not suitable for defective pricing and fraud suits complaining about bad estimates of future events.

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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....

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