FFATA Subaward and Executive Compensation Reporting Requirements

The Federal Funding Accountability and Transparency Act (FFATA), “Transparency Act,” requires information disclosure of entities receiving Federal financial assistance through Federal awards such as Federal contracts, sub-contracts, grants, and sub-grants, FFATA § 2(a)(2)(i), (ii). Specifically, the Transparency Act’s section 2(b)(1) requires the Office of Management and Budget (“OMB”) to ensure the establishment of a publicly available website that contains the following information about each Federal award: ● name of the entity receiving the award; ● amount of the award; ● information on the award including transaction type, funding agency, the North American Industry Classification System code or Assistance Listings number, program source, award title descriptive of the purpose of each funding action; ● location of the entity receiving the award and primary location of performance under the award, including city, State, congressional district, and country; ● unique identifier of the entity receiving the award and the parent entity of the recipient, should the entity be owned by another entity; and ● names and total compensation of the five most highly compensated officers of the entity if the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal contracts (and subcontracts), loans, grants (and subgrants), cooperative agreements, and other forms of Federal financial assistance awards; and $25,000,000 or more in annual gross revenues from Federal contracts (and subcontracts), loans, grants (and subgrants), cooperative agreements, and other forms of Federal financial assistance contract awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. §§ 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. See 2 CFR Part 170 for a full reading of the regulations FFATA § 2(b)(1). (To determine if the public has access to the compensation information, see the U.S. Security and Exchange Commission total compensation filings at http://www.sec.gov/answers/execomp.htm.

The latest form for FFATA Subaward and Executive Compensation Reporting Requirements expires 2027-09-30 and can be found here.