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GSA Proposes to Codify Override of Some Commercial Terms

Client Alert | 1 min read | 06.07.16

GSA issued a proposed rule to amend its acquisition regulation to make unenforceable certain common commercial supplier agreement (CSA) terms, a follow-up to the class deviation (discussed here) released last year. While some of the common commercial terms targeted arguably are, as GSA asserts, inconsistent or create ambiguity with federal law (e.g., provisions imposing non-federal law, arbitration provisions, and indemnification provisions), some likely are not (e.g., provisions giving precedence to government terms, placing restrictions on unilateral termination for breach, and requiring the contractor to provide the text of terms incorporated by reference).

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Client Alert | 3 min read | 09.04.25

Not Just the FAR, SAM.gov Gets Overhauled Too

The System for Award Management (SAM, available at sam.gov) is set to incorporate Revolutionary FAR Overhaul (RFO) changes as early as the first quarter of 2026. The RFO process, which began earlier this year, will trigger matching changes to representations and certifications in SAM.gov....