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SBA Proposes Fundamental Revision to Subcontract Reporting

Client Alert | less than 1 min read | 10.08.15

On October 6, 2015, the SBA issued a proposed rule to change the way prime contractors report how they complied with individual subcontracting plan goals by allowing primes to receive credit for awards made at any subcontracting tier (instead of first-tier only). As part of this proposed change, primes would have to incorporate the subcontracting plan goals of their lower-tier subcontractors into their individual subcontracting plans and would become responsible for ensuring that subcontractors adopt and comply with their plans.


Insights

Client Alert | 5 min read | 09.03.26

DOT Final Rule Narrows Airline Delay and Cancellation Reporting Obligation Under FAA Reauthorization Act of 2024

The U.S. Department of Transportation (DOT) published a final rule amending 14 CFR Part 234 that fundamentally changes how airlines report the causes of flight delays and cancellations. Effective October 19, 2026, the rule implements Section 511(b) of the FAA Reauthorization Act of 2024 by creating a new reporting category, the “Section 511(b) category,” for ten specific events that Congress determined are not attributable to airline control. The rule simultaneously narrows the existing "Air Carrier" reporting category by expressly excluding those same ten events....