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OMB Expands FAPIIS to Cover Grants and Cooperative Agreements

Client Alert | less than 1 min read | 07.28.15

On July 22, 2015, OMB issued final guidance that – effective January 1, 2016 – expands the Federal Awardee Performance and Integrity Information System (FAPIIS) to cover federal grants and cooperative agreements. Applicants and recipients will have to disclose significant information about civil, criminal, and administrative proceedings that occurred in connection with the award or performance of a federal grant, cooperative agreement, or contract; for their part, agencies must consider information in FAPIIS prior to award as part of the analysis of the applicant's integrity and performance history.


Insights

Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....