In a departure from its prior precedent, the Armed Services Board of Contract Appeals (ASBCA) recently held in Kamaludin Slyman CSC, ASBCA Nos. 62006, 62007, 62008, that a typed name at the end of an email satisfies the certification requirement under the CDA, so long as it is: (1) discrete; (2) verifiable; and
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A Friendly Reminder…Women-Owned Small Business Self-Certification is Coming to an End Soon
The Small Business Administration’s (SBA’s) October 15, 2020 elimination of the self-certification process for Women-Owned Small Businesses (WOSBs) and Economically Disadvantaged WOSBs (EDWOSBs) is rapidly approaching. A WOSB is a small business (based on the applicable NAICS code determination) that is 51% directly and unconditionally owned and controlled by one or more women. An EDWOSB…
Cybersecurity Supply Chain Developments – What’s Next for CMMC?
It is now June 2020. The Department of Defense (DoD) initially projected that, this month, it would issue ten pilot Requests for Information (RFIs) as part of its efforts to develop the means for its implementation of the Cybersecurity Maturity Model Certification (CMMC) under DoD contracts. To date we have not seen any of the…
PPP Forgiveness Application Certification May Lead to Enforcement Headaches
I. Introduction
The Paycheck Protection Program (PPP) was enacted as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act on March 27, 2020. Unfortunately, the path to providing PPP loan relief has not been smooth. Instead, it has been paved with uncertainty. While the CARES Act laid out specific requirements for PPP…
New Paycheck Protection Program FAQs Released This Week
On April 6, 2020 the Small Business Administration, in conjunction with the Department of Treasury, issued additional set of Frequently Asked Questions (FAQs) to address questions regarding the Paycheck Protection Program (PPP). Among other things, these FAQs provide yet another “clarification” of the eligibility provisions under the SBA interim final regulation – some businesses with …