1. Home
  2. |Insights
  3. |Proposed Consolidation of Civilian Suspension and Debarment Offices

Proposed Consolidation of Civilian Suspension and Debarment Offices

Client Alert | less than 1 min read | 02.12.13

On February 7, Chairman Issa of the House Oversight Committee released a discussion draft of legislation that would consolidate more than forty civilian agency suspension and debarment offices and functions into one, centralized "Board of Civilian Suspension and Debarment" in GSA on October 1, 2014. The draft Stop Unworthy Spending Act, or SUSPEND Act, would also permit the newly formed board to enter into agreements to perform suspension and debarment activities for entities other than civilian agencies; consolidate the procurement and non-procurement regulations; require heightened public availability to proceedings and administrative agreements; and provide an expedited process for appropriate matters.


Contacts

Insights

Client Alert | 3 min read | 02.11.26

Clicking All the Right Boxes: FTC Moves to Revive “Click-to-Cancel” Rule Following Eighth Circuit Vacatur

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 As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates....