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Third Time’s Not a Charm; Disparate Compensation Evaluation Leaves Navy Stranded

Client Alert | 1 min read | 12.07.17

On November 20, 2017, the Government Accountability Office released its decision in Fluor Federal Solutions, LLC, B-410486.9, sustaining a protest challenging the Navy’s third award decision for an 8-year contract to provide base operations support services on the island of Guam. Following a sustained protest challenging the Navy’s discussions and proposal evaluations (CFS-KBR Marianas Support Services, LLC; Flour Federal Solutions LLC, B-410486, et al., Jan. 2, 2015 (Round 1)), and an outcome prediction ADR in which GAO advised that it would sustain the protester’s second protest challenging the Navy’s evaluation of the awardee’s exempt employee compensation plan (Round 2), the Navy again selected the same awardee. In this protest (Round 3), GAO found that the Navy engaged in disparate treatment when it downgraded the protester for proposing reduced compensation of exempt employees while overlooking similar risk in the awardee’s proposed plan, which involved replacing exempt employees with new hires at reduced compensation through multiple hiring cycles.

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Client Alert | 6 min read | 08.11.26

Lending Against Digital Assets: Five Key Takeaways for Lenders After a Year of Regulatory and UCC Change

Over the past 18 months, the federal banking agencies have clarified supervisory expectations for banks’ crypto-asset activities, and several of the largest U.S. banks have announced programs accepting Bitcoin and Ether as loan collateral. Separately, on June 3, 2026, New York’s enactment of the 2022 amendments to the Uniform Commercial Code took effect, changing the rules governing the perfection of a security interest in digital asset collateral in New York, the jurisdiction whose law governs most institutional credit documentation. Together, these developments may create significant opportunities for lenders navigating the complexities to comply with the newly enacted statutes. This alert surveys the current landscape, from regulatory permissibility and perfection through custody, structuring, and compliance, for institutions active in this market or considering entering it....

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