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SBA Proposes To Relax Employee-Based Size Standard

Client Alert | less than 1 min read | 08.03.07

On July 27, 2007, the U.S. Small Business Administration issued a proposed rule to simplify and relax the way in which it determines whether an entity complies with an employee-based size standard. Instead of the current method, which uses a rolling average of the number of employees over the previous 12 months, the proposed method is based on the average number of employees over the last three completed calendar years and will not only require less frequent updates to an entity's size status but also allow a greater number of contractors that have experienced growth in the past several years to still qualify as small.

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Client Alert | 3 min read | 04.25.24

JUST RELEASED: EPA’s Bold New Strategic Civil-Criminal Enforcement Collaboration Policy

The Environmental Protection Agency’s (EPA’s) Office of Enforcement and Compliance Assurance (OECA) just issued its new Strategic Civil-Criminal Enforcement Policy, setting the stage for the new manner in which the agency manages its pollution investigations. David M. Uhlmann, the head of OECA, signed the Policy memorandum on April 17, 2024, in order to ensure that EPA’s civil and criminal enforcement offices collaborate efficiently and consistently in cases across the nation. The Policy states, “EPA must exercise enforcement discretion reasonably when deciding whether a particular matter warrants criminal, civil, or administrative enforcement. Criminal enforcement should be reserved for the most egregious violations.” Uhlmann repeated this statement during a luncheon on April 23, 2024, while also emphasizing the new level of energy this collaborative effort has brought to the enforcement programs....