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SBA Regulatory Changes Affect Relationships Between Small and Large Businesses

Client Alert | 1 min read | 06.09.16

On May 31, 2016, SBA published the final rule, effective June 30, implementing the National Defense Authorization Act of 2013. Considering the critical importance of these changes on size status and teaming relationships between large and small businesses, Crowell & Moring is posting a series of blog posts to cover the wide range of impacts that this rule will have on such topics as limitations on subcontracting, small business subcontracting plans, penalties, affiliation, and the non-manufacturer rule.

Insights

Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...