Comment on FR Doc # 2012-11148

A foreign incorporated entity that meets the criteria specified in 6 U.S.C. 395(b), should be prohibited from contracting with the Federal Government (FG). Some of the procedures required when Inverted Domestic Comp. (IDC) get involved are proxy agreements, authorization from National Authorities, security agencies and the involvement of personnel with Counter Intelligence expertise. In addition, the GCA FOCI designee must be appointed by agency head. Security measures must be taken before IDC could be awarded a contract. These measures are very costly to the US tax payer and there are companies in the US who can for fill any requirement. Sub-contracting can remain available. Awarding contracts for a foreign owned company definitely defeats the “Buy American Act”, and raises question as to the overall purpose. All contract types should be “Buy American”. Based upon the information in Section 738 of Division C related to the use of Federally Appropriated Funds for Fiscal Year 2012, contracts between the US and IDC put in place after July 2009,as defined at section835(b) of the Homeland Security Act of 2002 (Pub.L.107-296,6 U.S.C. 395(b) or any subsidiary of such entity shall be terminated. Therefore, regardless of any and all Special Security Agreements (SSA) in place, all mitigation of said entity is null and void due to preservation of National Interests and “the Good of the Nation” from 2012 -2013. Said entities that are effectively owned or controlled by a foreign entity shall have all required documents from or received from the National Authorities that were completed be now considered null and void. There have been no amendments to BAA introduced in the 111th Congress. The ARRA and Stimulus Plan did not amend the BAA. My position is that Prohibition of IDC should stand inclusive of the BAA.