GSA Class Deviation Takes Aim at Commercial Terms
Client Alert | 1 min read | 08.26.15
As reported by the Coalition of Government Procurement, GSA recently released a final version of the class deviation it previewed in March that purports to eliminate commercial terms that are inconsistent with federal law. Among other changes, the deviation (1) revises the order of precedence to give solicitation provisions precedence over commercial provisions; (2) rewrites commercial supplier agreement dispute resolution, automatic renewal, and audit right provisions; and (3) places limits on the use and applicability of click-wrap and other comparable commercial contract execution mechanisms.
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Client Alert | 7 min read | 12.17.25
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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