The Department of Defense issued a final rule adding the National Industrial Security Program Operating Manual (NISPOM) to the Code of Federal Regulations (CFR) and making other changes relevant to contractors that access...more
What makes the current economic crisis unique is that it is systemic. Despite businesses historically being well managed, not being overly leveraged, innovating in the marketplace and not facing a large litigation judgment,...more
As the Coronavirus Disease 2019 (COVID-19) continues to impact our nation, financial institutions are finding themselves in a situation wherein their customers are unable to, or are at risk of being unable to, make timely...more
On March 22, 2020, in response to the growing anticipation for loan modifications necessitated by the implications of the Coronavirus Disease 2019 (“COVID-19”), the Federal Reserve, Federal Deposit Insurance Corporation,...more
On March 22, federal banking regulators, including the board of governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration, the Office of the...more
Machiavelli – yes, that Machiavelli – knew a thing or two about working with a powerful government. In his most well-known writings, Machiavelli opined on both the application of power and importance of intellect when...more
You no doubt have heard by now about GSA’s 23 June effort to “embrace modern technology while moving away from outmoded practices” – specifically, its implementation of the new Transactional Data Reporting Rule (“TDR Rule”)...more
The General Services Administration (GSA) recently issued a Final Rule as part of its long-term aim to modernize reporting for cost and price data related to government-wide contracts, such as Federal Supply Schedules. Under...more
GSA’s final transactional data rule fundamentally alters the basis for negotiation and pricing of commercial items on Federal Supply Schedule (FSS) contracts and subsequent orders, with immediate impact on some of the largest...more