Seyfarth Shaw LLP
Press & News
On July 8, 2010, the Federal Government issued an Interim Rule that requires certain Government contractors to report first-tier subcontract awards and the names and total compensation of the contractor’s and first-tier subcontractor’s five most highly compensated executives. This Interim Rule implements 2008 amendments to the Federal Funding Accountability and Transparency Act (P.L. 109-282) which require reporting of Federal contract information to reduce “wasteful and unnecessary spending.” The Government has imposed similar reporting requirements on recipients of American Recovery and Reinvestment Act funds.
Application Of The Reporting Requirements: The first-tier subcontract reporting requirement applies to all Federal contractors, including small businesses and commercial item/commercial-off-the-shelf (COTS) contractors, who had gross revenue of $300,000 or more in the previous tax year. Such contractors must report first-tier subcontracts of $25,000 or more, including options.
Full News Release: http://www.seyfarth.com/index.cfm/fuseaction/news_pub.news_pub_detail/object_id/9ef84674-8bed-400d-beae-c6c191259977/FederalGovernmentContractorsMustReportExecutiveCompensationAndFirst-TierSubcontractAwards.cfm
To see the interim rule "Reporting Executive Compensation andFirst-Tier Subcontract Awards (FARCase 2008–039)" go to: http://edocket.access.gpo.gov/2010/pdf/2010-16691.pdf