Relax a Little – Expiring SAM Deadline Extended

GSA just announced a 180-day extension for organizations with expiring SAM website registrations. Those with registrations expiring between April 1 and September 30, 2021, will automatically be granted an extension. The extension is an effort to alleviate some of the burden during the implementation of the American Rescue Plan Act. (GSA Interact March 29, 2021)

GSA will send an email from samadmin@sam.gov with the subject line “180-Day SAM.gov Extension Granted for [Entity Name/DUNS/CAGE]” to those affected. The extension will not affect first-time registrants. The updated records will be stored within entity management extracts in SAM.gov and available through web services after the records are extended. (ibid)

Need help with your registration? Give us a call.

CTA and Small Businesses

In January, Congress enacted the 2021 National Defense Authorization Act. It includes amendments to the U.S. Anti-Money Laundering Act, the most noteworthy of which is the Corporate Transparency Act (CTA). (JDSupra, March 22, 2021)

The most significant elements of the CTA to know now:

  • CTA legislation requires “beneficial” business owners to report specific information to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). A beneficial owner directly or indirectly controls at least 25 percent of the company. Beneficial owners must report their full name, date of birth, current address, and unique identification number. This information will help  prevent the formation of shell companies and money laundering as well as terrorist organization funding.
  • Unless exempt, all privately held businesses in the U.S. are subject to the CTA reporting requirements.
  • CTA becomes effective 1 January 2022. Businesses formed after that time must submit reports within two years.  All business changes are required to be reported within one year.
  • Businesses should add beneficial owner information collection into their operations especially when there are multiple qualifying beneficial owners, as reporting/update deadlines can be cumbersome.
  • Failure to report or update beneficial owner information may include civil penalties up to $500 per day until the violation is corrected as well as criminal fines up to $10,000 and imprisonment for up to two years. (ibid)

The good news is that business entities have almost a full year to get their CTA reporting controls in place, to meet the 1 January 2022 effective date.

Have some CTA regulation reporting questions? Give us a call.

 

$355M for Women Owned Small Businesses

Over the past 20 years, the government has aimed to award at least 5 percent of contracts to Women-Owned Small Businesses (WOSBs). In FY2020, WOSBs received $561.7 million in contracts. However, GSA has only set aside $354.9 million for WOSB contracts in FY2021. (ExecutiveGov, March 4, 2021)

According to GSA’s Office of Small and Disadvantaged Business Utilization, 10.47 percent of the total FY2020 contracting obligations for women-owned vendors were prime awards. To lend a hand to these vendors, GSA provides support through training resources and Forecast of Contracting Opportunities. These tools and other activities earned GSA a grade of A+ from the Small Business Administration in FY2019 for their work to support small businesses. (ibid)

Are you a Small or Woman-Owned Small Business looking to prime or sub on an upcoming procurement? Give us a call.

FY 2021 SubK Reporting Deadline Extended

The Small Business Administration (SBA) is extending the period for subcontract reporting for fiscal year 2021. The extension allows Federal Contractors (FCs) extra time to correct any issues experienced during the pandemic as well as Federal Agencies (FAs) extra time to review the reports. This will be the final Subcontract Reporting extension. The timeframe for FCs to revise rejected reports is not extended and remains unchanged. (Small Business Administration Notification March 5, 2021)

Extensions provided by the SBA include:

  • 15 days for FC’s report submission due dates and for  the FA’s review periods for the FY 2021 ISRs and SSRs
  • 45 days after the end of the reporting period for FCs to submit their ISR and SSR and 45 days after contract completion if applicable
  • 75 days from the reports’ ending dates for FAs to acknowledge receipt or reject the initial reports
  • 30 days after receipt of a rejection notice, per FAR § 52.219-9(l), for FCs to revise rejected reports
  • 30 days after submittal for FAs to review revised reports

The subcontract report extensions are effective immediately. This pdf contains the formal notice SBA provided for the extension notification. (ibid)

Have questions concerning your ISR or SSR or a rejected report notice? Give us a call.