SBA Cannot Replace Agency Responsibility Findings with Its Own
Client Alert | less than 1 min read | 09.30.11
In Spiral Solutions & Techs., Inc., the Small Business Administration’s Office of Hearings and Appeals (“OHA”) reversed a size decision finding a violation of the ostensible subcontractor rule because the SBA Area Office improperly made findings on matters of responsibility--matters reserved for the contracting officer. Additionally, OHA explained that Spiral’s hiring of its subcontractor’s incumbent, non-management personnel is no longer indicative of “undue reliance” in light of Executive Order 13,495, which encourages companies to offer a right of first refusal of employment to qualified employees performing under a predecessor contract for similar services at a particular location.
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Client Alert | 5 min read | 07.20.26
On July 6, 2026, the U.S. Department of Justice (DOJ) and the U.S. Department of Homeland Security (DHS) published an Interim Final Rule (IFR) setting up a new federal framework that allows state, local, Tribal, and territorial (SLTT) law enforcement and correctional agencies to detect, track, and, in some cases, disable or seize drones. The rule directly affects SLTT agencies looking to stand up counter-drone programs, as well as drone and counter-drone technology companies whose products will be subject to federal review and approval. Although the IFR bypassed the Administrative Procedure Act’s standard notice-and-comment process on good cause grounds — citing the statutory 180-day deadline and urgent public safety needs — the rule is already legally binding and effective as of July 1, 2026. The Departments are nonetheless accepting post-promulgation comments through September 4, 2026.
Client Alert | 3 min read | 07.20.26
QFMA Introduces International Licensing Regime for Financial Services Firms
Client Alert | 3 min read | 07.17.26
Client Alert | 2 min read | 07.15.26
CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations
