The Transparency Monster Strikes Again: New Reporting Requirements For Executive Compensation And First-Tier Subcontract Awards

On July 8, 2010, the FAR Councils issued an interim rule, effective immediately, that requires contractors to report information regarding executive compensation and first-tier subcontract awards. See 75 Fed. Reg. 39414. The interim rule implements the Federal Funding Accountability and Transparency Act of 2006 (“FFATA”) (Pub. L. No. 109-282), as amended by the Government Funding Transparency Act of 2008 (“GFTA”) (Pub. L. No. 110-252). In accordance with the requirements of FFATA and GFTA, the Government will disseminate the information reported under the interim rule – including the names and total compensation of the contractor’s five most highly compensated executives – to the general public via the USASpending.gov website.

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