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  3. |Making a List and Checking It Twice: New Rule Requires "Adequacy Checklist" with Forward Pricing Rate Proposals

Making a List and Checking It Twice: New Rule Requires "Adequacy Checklist" with Forward Pricing Rate Proposals

Client Alert | less than 1 min read | 01.09.15

On December 11, 2014, DoD issued a final rule to instruct COs to request that contractors submit a Forward Pricing Rate Proposal "Adequacy Checklist" when submitting their FPRP. Under the rule, both the FPRP and the Adequacy Checklist are due at least 90 days before the proposed effective date of the rates, and DoD cautioned that "the proposed rates are based on forecasts and contractors must provide updates whenever the validity of the agreement may be affected."


Insights

Client Alert | 4 min read | 02.20.26

SCOTUS Holds IEEPA Tariffs Unlawful

On February 20, 2026, the Supreme Court issued a pivotal ruling in Trump v. V.O.S. Selections, negating the President’s ability to impose tariffs under IEEPA. The case stemmed from President Trump’s invocation of IEEPA to levy tariffs on imports from Canada, Mexico, China, and other countries, citing national emergencies. Challengers argued—and the Court agreed—that IEEPA does not delegate tariff authority to the President. The power to tariff is vested in Congress by the Constitution and cannot be delegated to the President absent express authority from Congress....