DE Under 3: FAR Council Seeks to Require Federal Contractors to Report First-Tier Subcontractor Information, Including Potentially Executive Compensation Data
DE Under 3: OMB Announced Finalized Overhaul to Federal Race & Ethnicity Data Collection Standards
DE Under 3: OFCCP Resurrects Proposal for Monthly CC-257 Employment Utilization Reports for Construction Contractors
DE Under 3: FAR Council Submitted for OMB Approval Proposed Rule on “Pay Equity and Transparency in Federal Contracting”
DE Under 3: Surprises Lurk Throughout OMB's 2023 Spring Regulatory Agenda
DE Under 3: OFCCP’s Controversial “Pre-Enforcement Notice & Conciliation Procedures” Final Rule Coming Soon
DE Under 3: President Biden Issued "Modernizing Regulatory Review" Executive Order
DE Under 3: OMB’s Initial Proposal to Overhaul Federal Race & Ethnicity Data Collections
DE Under 3: OMB Publishes Its Fall 2022 Regulatory Agenda
DE Under 3: Big Changes Coming to OFCCP's Supply & Service Contractor ICRs
DE Under 3: Employment Poster Requirements & the U.S. DOJ’s First-Ever Criminal Anti-Trust Prosecution
DE Under 3: Data Gathering & Data Delivery
DE Under 3: New Data Collection Burdens, NLRB’s Ruling Regarding Union Election Dismissals, and OMB’s Tech Modernization Fund
Biden’s Modernizing Regulatory Review – A New Paradigm?
DoD Cyber: A Conversation with Melissa Vice, COO for DoD’s Vulnerability Disclosure Program
Is it the End of the EB-5 World as We Know it? How to Prepare for Potential Changes
I-14: Update on EEO-1 and I-9 Forms, Employer Obligations After a Hurricane or Other Natural Disaster, and Attorney Jason Barsanti on Meal and Rest Breaks
The Small Business Administration (“SBA”) has officially discontinued use of the Loan Necessity Questionnaire previously required for forgiveness of Paycheck Protection Program (“PPP”) loans of $2 million or more...more
As per our earlier articles, in late 2020, the SBA began requiring borrowers with First Draw PPP loans $2 million or greater to complete a PPP Loan Necessity Questionnaire (Form 3509 (For Profit Borrowers) or Form 3510...more
On the roller coaster ride that is the interpretation of the Paycheck Protection Program (“PPP”) by the U.S. Small Business Administration (“SBA”), on October 26th, the SBA issued a notice to the Office of Management and...more
For-profit and non-profit borrowers of PPP loans of $2MM or more are now required to submit additional forms. On October 26, 2020, the SBA published a notice seeking Office of Management and Budget (OMB) approval of new...more
On October 26, 2020, the Small Business Administration (SBA) published a proposed Paycheck Protection Program (PPP) Loan Necessity Questionnaire for both for-profit and nonprofit borrowers in the Federal Register. This...more
On October 26, 2020, the U.S. Small Business Administration (SBA) issued a notice that it is seeking approval from the Office of Management and Budget (OMB) to collect and use certain borrower information to evaluate the...more
Over the course of the last week, the Small Business Administration (SBA) has reportedly begun quietly questioning borrowers who had received Paycheck Protection Program (PPP) loans about the “necessity” of their loans. On...more
This is the third in a series of Cooley client alerts that discuss issues raised during the Borrower Defense to Repayment (BDTR) Negotiated Rulemaking. Our first alert discussed the Negotiated Rulemaking itself, and the...more
Since opening its doors for business, behavioral economics has played a central role in the CFPB’s regulatory agenda. Behavioral economists posit that consumers are not rational decision makers and instead have certain...more