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Offerors Now Must Disclose Information about Owners, Subsidiaries, and Predecessors


On March 7, 2016, the FAR Council issued a final rule that requires offerors to disclose within the Federal Awardee Performance and Integrity Information System any immediate owner or subsidiary and all predecessors of an offeror that held a federal contract or grant within the last three years. The final rule is designed to provide COs with a “more comprehensive understanding of the performance and integrity of the corporation before awarding a Federal contract . . .,” and it may also affect how contractors draft their proposals to explain their corporate family trees.

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For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Peter Eyre
Partner – Washington, D.C.
Phone: +1 202.624.2807

David B. Robbins
Partner – Washington, D.C.
Phone: +1 202.624.2627

Olivia Lynch
Associate – Washington, D.C.
Phone: +1 202.624.2654