On August 25, 2016, the Federal Acquisition Regulatory (FAR) Council published in the Federal Register its highly anticipated Final Rule1 regarding the so-called “blacklisting” procedures for federal contractors President Obama ordered in his Fair Pay and Safe Workplaces Executive Order (EO) Number 13673. Accompanying the Final Rule was separate Final Guidance2 the Department of Labor (DOL) issued to help employers interpret the new Rule. The Rule becomes partially effective on October 25, 2016, with phased-in disclosure requirements, while the paycheck transparency obligations take effect on January 1, 2017.
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