As many of our readers are aware, the SBA proposed regulatory changes last year which purport to make it more difficult for individuals to gain entry into the SBA's 8(a) Business Development program if the individual is not a member of one of the "presumed groups." Specifically, these changes were proposed in response to a number of SBA Office of Hearings and Appeals cases which the SBA felt allowed individuals to establish social disadvantage despite having (in their opinion) a record which lacked sufficient evidence supporting a discriminatory basis for such misconduct. As of today, the SBA has not yet issued a Final Rule (it is anticipated by the end of this month); however, we were surprised to learn (based on an application we are working on) that the SBA has already implemented these changes with respect to the processing of 8(a) applications.
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Alert: SBA Already Implementing 8(a) Regulatory Change Regarding Social Disadvantage Requirement6/27/2016
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On May 31, 2016, the Small Business Administration issued a Final Rule implementing provisions of the 2013 National Defense Authorization Act, which pertain to performance requirements applicable to small business subcontracting, affiliation and joint ventures. Holomua Consulting Group submitted comments in response to the Proposed Rule and we are pleased to note that many of our comments were taken into consideration and our suggestions reflected in the Final Rule. The Final Rule takes effect on June 30, 2016. The following is a summary of the major points of the Final Rule.
Almost All Federal Contractors and Subcontractors Must Now Meet Minimum Cybersecurity Requirements6/11/2016
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