TINA Threshold Raised but Broader Data Requests Likely
Client Alert | 1 min read | 10.05.10
Effective October 1, a "clarified" FAR regulation regarding compliance with the Truth in Negotiations Act raises the threshold for providing certified cost or pricing data from $650,000 to $700,000 for covered contract and subcontract awards and modifications. The new regulation, which the Civilian Agency Acquisition and Defense Acquisition Regulations Councils say merely contains clarifications and "neither expands nor diminishes the existing right of contracting officers to request cost or pricing data whether certified or other than certified" appears likely to precipitate expanded and more aggressive contracting officer requests for non-certified judgmental data, even when certified cost or pricing data are required, and, particularly with respect to "excepted" procurements for commercial items and services, for (non-certified) cost data.
Contacts
Insights
Client Alert | 5 min read | 06.11.25
Steel Tariffs Doubled: How the Hike Could Reshape Construction Projects at Home and Abroad
To date the Trump Administration has issued multiple proclamations imposing varying rates of import duties on steel and aluminum and certain derivatives, including construction materials. These measures have added volatility and financial pressures to the construction sector both in the United States and abroad. Most recently, on June 3, 2025, President Donald Trump issued a proclamation under Section 232 of the Trade Expansion Act of 1962, doubling tariffs on imported steel and aluminum from 25% to 50%, effective June 4, 2025. This action aims to counteract the continued influx of lower-priced, excess steel and aluminum imports that, according to the administration, threaten U.S. national security by undermining domestic production capacity. The proclamation notes that while prior tariffs provided some price support, they were insufficient to achieve the necessary capacity utilization rates for sustained industry health and defense readiness. The United Kingdom remains temporarily exempt at the 25% rate until July 9, per the U.S.-U.K. Economic Prosperity Deal.
Client Alert | 5 min read | 06.11.25
The FCPA Pause Is Over: Trump DOJ Issues Long-Awaited FCPA Investigations and Enforcement Guidelines
Client Alert | 4 min read | 06.10.25
Trump Administration Cyber Executive Order Revises Prior Administrations’ Requirements
Client Alert | 19 min read | 06.09.25
