FAR Council Finalizes Reporting Requirements for Executive Compensation and First-Tier Subcontract Awards
Client Alert | less than 1 min read | 07.26.12
On July 26, 2012, the FAR Council issued a final rule requiring certain contractors to report executive compensation, first-tier subcontract awards, and executive compensation information for first-tier subcontractors for public release on the USASpending website. While the final rule is very similar to the interim rule issued on July 8, 2010, there is a substantive change to the definition of first-tier subcontract, and the preamble to the final rule contains extensive commentary to guide the implementation of the rule, including discussion of the application of the public company exemption.
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On September 5, 2025, the Federal Trade Commission (“FTC”) withdrew its appeals of decisions issued by Texas and Florida federal district courts, which enjoined the FTC from enforcing a nationwide rule banning almost all noncompete employment agreements. Companies, however, should not read this decision to mean that their noncompete agreements will no longer be subjected to antitrust scrutiny by federal enforcers. In a statement joined by Commissioner Melissa Holyoak, Chairman Andrew Ferguson stressed that the FTC “will continue to enforce the antitrust laws aggressively against noncompete agreements” and warned that “firms in industries plagued by thickets of noncompete agreements will receive [in the coming days] warning letters from me, urging them to consider abandoning those agreements as the Commission prepares investigations and enforcement actions.”
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