Limitation on Mark-Up of Subcontractor Costs
Client Alert | less than 1 min read | 04.30.07
In an interim rule effective immediately, the Defense Department amended DFARS on April 26, 2007 to permit the Government to "disallow" (including on firm-fixed price contracts) "excessive pass through charges" on subcontracts where the total subcontract costs exceeds 70 percent of the contract value. "Excessive" charges are defined to include costs and profit that the contractor cannot demonstrate to the contracting officer add something other than "no or negligible" substantive value to performance, so any contractor with an accounting practice that allocates G&A to subcontract costs could run afoul of these rules.
Insights
Client Alert | 7 min read | 09.02.26
OCC and FDIC Redefine “Unsafe or Unsound Practices”: The New Supervisory Framework for Banks
On August 27, 2026, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) jointly issued a final rule that, for the first time, gives the term “unsafe or unsound practice” a binding regulatory definition.[1] With it came a uniform standard for Matters Requiring Attention (MRAs) and revised OCC examination manuals.[2]The Federal Reserve did not join the rulemaking, but has adopted comparable standards through guidance. What that means for holding companies and state-chartered institutions is addressed below.[3] The regulation takes effect November 2, 2026, and the revised OCC examination manuals took effect upon their issuance on August 27.
Client Alert | 4 min read | 09.02.26
The CSC Is Investigating: What Its New NIL Enforcement Memo Means for Institutions
Client Alert | 4 min read | 08.27.26
FCC Clarifies Covered List for Power Inverters and Advanced Robotic Devices
Client Alert | 4 min read | 08.27.26
Power Play: New Executive Order Targets Electrical Grid Equipment
