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New Rule Prescribes Data Required for Adequate Final Indirect Cost Rate Proposal

Client Alert | 1 min read | 06.02.11

On May 31, 2011, the FAR Council published a final rule governing contract closeout requirements, including the identification of a long list of data items required for a final indirect cost rate proposal to be found "adequate," as well as additional types of data that the government can request to supplement a proposal; clarification of the division of duties between the CO and auditors with respect to auditing and finalizing the proposal; and the requirement that mandatory withholdings be exacted by the CO for contractors who fail to timely submit an adequate proposal. While the rule does not require that proposals be submitted using any particular format in order to qualify as "adequate," it remains unclear what will happen in individual cases if DCAA refuses to commence an audit because the contractor declines to provide the burdensome cost schedules required by the DCAA "model" format.

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Client Alert | 3 min read | 03.24.26

California Considering A Massive Expansion of Its Antitrust Laws

Legislative efforts to significantly expand California’s antitrust laws are working their way through the state legislature. The most comprehensive overhaul is Assembly Bill 1776 — the Competition and Opportunity in Markets for a Prosperous, Equitable and Transparent Economy (COMPETE) Act, introduced by Assembly Majority Leader Cecilia Aguiar-Curry, on March 23, 2026. AB 1776 is modeled closely after draft legislation recommended by the California Law Revision Commission (CLRC) in December. AB 1776 would not only significantly expand potential liability for single-firm conduct and monopolization but would also explicitly decouple California antitrust analysis from certain federal standards. Companies doing business in California should pay close attention to AB 1776 because of its potentially dramatic impact, including increased exposure to antitrust litigation and increased compliance costs....

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