Final Rule Requires Technical Interchange for IR&D Cost Allowability
Client Alert | 1 min read | 11.14.16
On November 4, 2016, DoD issued a final rule requiring contractors performing IR&D projects initiated in FY2017 or later to engage in a technical interchange with DoD, and report the occurrence of this interchange, before the costs for such projects may be deemed allowable (a topic previously discussed here). Although the rule is stated to be intended to promote DoD awareness of IR&D projects and provide feedback to contractors, it is likely to impose an administrative burden on contractors and DoD alike and could have a chilling effect on IR&D investment, particularly because it is silent regarding the allowability of IR&D costs if DoD fails to engage.
Contacts
Insights
Client Alert | 3 min read | 02.11.26
On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates.
Client Alert | 4 min read | 02.11.26
Consolidated Appropriations Act Introduces Sweeping Reforms for Pharmacy Benefit Managers
Client Alert | 3 min read | 02.10.26
UK FCA Proposes New Sustainability Disclosure Rules for Listed Companies
Client Alert | 3 min read | 02.09.26
