Not sure why this rule is limited to small businesses involved in manufacturing. The business systems rule came to pass because major contractors' business systems were assessed as poor, so a control environment argument is unwarranted. The exposure is clearly greater at major contractors, and major contractors are more likely to use SAP, which abrogates the loan/payback transaction. The CSDR reporting is marginal at best.
Comment on FR Doc # 2012-14289
This is comment on Proposed Rule
Defense Federal Acquisition Regulation Supplements: Item Unique Identifier Update
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