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

Sheppard Mullin Richter & Hampton LLP
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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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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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