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Proposed Far Rule Would Require Many Federal Contractors And Subcontractors To Adopt Ethics Program

Client Alert | less than 1 min read | 02.16.07

Proposed changes to the FAR 72 Fed. Reg. 7588 (Feb. 16, 2007) (to be codified at 48 C.F.R. subpart 3.10) would require companies receiving a federal prime contract or subcontract in excess of $5 million to (1) adopt a written code of ethics and business conduct; (2) adopt an employee ethics and compliance training program; (3) adopt an internal control system; and (4) display agency Office of Inspector General hotline posters in common work areas where covered contracts are being performed. Contracts performed outside of the United States, whose performance period is less than 120 days, or that are “commercial item” contracts under FAR Part 12, would be exempt.

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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....