Compounding The Problem
Client Alert | 1 min read | 09.24.10
On September 22, 2010, the Civilian Agency Acquisition Council and Defense Acquisition Regulations Council issued a proposed rule that would amend the FAR to require compound, rather than simple, interest to be used in calculating damages for violations of the Truth in Negotiations Act (TINA). The proposal follows the problematic analysis in Gates v. Raytheon, 584 F.3d 1062 (Fed. Cir. 2009), which held that, because the Cost Accounting Standards (CAS) statute requires interest on cost impacts for CAS violations to be calculated at the rate established under 26 U.S.C. § 6621, the same rate referenced in the TINA statute, the interest must be compounded in accordance with 26 U.S.C. § 6622, even though the CAS statute does not refer to or incorporate § 6622 by reference.
Insights
Client Alert | 5 min read | 09.02.26
DOJ’s Civil Rights Fraud Initiative Claims Another DEI-Related FCA Settlement
On Tuesday, August 25, 2026, the U.S. Department of Justice (DOJ) announced that Deloitte LLP and several of its subsidiaries agreed to pay, collectively, $21.5 million to resolve allegations that Deloitte violated the False Claims Act (FCA) by failing to comply with new anti-discrimination requirements incorporated into its federal contracts, by discriminating against employees and applicants on the basis of race and sex, and by allocating and seeking reimbursement for costs related to those practices under its federal government contracts. This resolution is the second of its kind under DOJ’s recently launched Civil Rights Fraud Initiative, following a similar settlement by IBM in April 2026.
Client Alert | 4 min read | 09.02.26
Client Alert | 7 min read | 09.02.26
OCC and FDIC Redefine “Unsafe or Unsound Practices”: The New Supervisory Framework for Banks
Client Alert | 4 min read | 09.02.26
The CSC Is Investigating: What Its New NIL Enforcement Memo Means for Institutions
