Extract to table

Nonetheless, the disclosure framework must be navigated carefully, as contracting officers may treat the clause as a basis for broader inquiry into VPI's continued contractor responsibility

Contracting officers will nonetheless expect notification of the foreign ownership change, and VPI must comply with broader DFARS and FAR foreign ownership-related provisions

First, it applies at the time of offer submission, when prospective contractors must include the required disclosures as part of their proposal

Accordingly, VPI has the same substantive disclosure obligation with respect to the Ironclad subcontract as it does with respect to its prime contracts, although the notification mechanics differ — VPI must notify Ironclad, which in turn has the obligation to notify the NAVSEA contracting officer

The clause states that the contractor must disclose the required information but does not prescribe a specific number of days within which the disclosure must be made following a change in ownership

However, any pre-closing disclosure must be carefully coordinated with CFIUS counsel to ensure that it does not conflict with CFIUS confidentiality requirements during the review process