Comment on FR Doc # E9-27309

Comments on the proposed rule: 1. Provides employers unprecedented insight into employee private financial data that could unfairly provide the employer with inappropriate leverage in terms of salary negotiations, work conditions and benefits negotiations. This is different from the Government employment system in which the wage scales are fixed and public and compensation is not widely variable on an individual by individual basis. 2. Does not provide employee with any guarantee of information privacy – only says employer must collect and assess the data, not how the data is controlled and protected, and possible disseminate it to the “Government.” 3. It is hard to believe that there are 250,000 contractors performing inherently Governmental activities if the actual legal description of the term is applied. It is actually very narrow in scope. Furthermore, the Government is insourcing much of this workforce anyway. 4. In many cases, it is small firms that may be most affected due to the evolving nature of the organizational restrictions (forcing divestitures) and propensity for small business set asides for this type of work. Small firms are least equipped to handle this type of requirement. 5. Who decides if an OCI exists and rises to a level that disqualifies an employee? Who decides what it takes to remove the OCI or if it is impossible to remove it? Who in the Government does the company report the information to? It should definitely NOT be the direct technical customers for the services. 6. Special assignments of contractors to work on proposal evaluations or procurement activities ALREADY require the contractors to identify potential OCIs (financial interests or employment relationships with any involved offerer, familial relationships of employment with offerers, etc). This vetting process protects the integrity of the procurement process now. The rule writers should identify what activities are NOT already protected and address gaps in th