UDRI First-Tier Subcontractor Transparency Act Reporting Form Guidance
FAR 52.204-10 Reporting Executive Compensation and First-Tier Subcontract
Awards (Oct 2016)
Subcontractor's Compensation Reporting Guidelines
Upon award of any Subcontractor award of $30,000 or more, and annually thereafter, UDRI as the prime contractor
mu
st report the total compensation and names of the Subcontractor’s top five most highly compensated executives
if:
(a) In the Subcontractor’s preceding fiscal year, the Subcontractor received:
(i) 80% or more of its annual gross revenues from Federal contracts (and subcontracts), loans, grants
(and subgrants) and cooperative agreements, and other forms of Federal financial assistance; and
(ii) $25,000,000 or more in annual gross revenues from Federal contracts (and subcontracts), loans,
grants (and subgrants) and cooperative agreements, and other forms of Federal financial assistance; and
(b) The public does not have access to information about the compensation of the executives through
period reports filed under
section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 USC
78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.
If a Subcontractor in the previous tax year had gross income from all sources under $300,000, the prime
contractor does not need to report awards for that subcontractor.
This information will be reported through the Federal Funding Accountability and Transparency Act Subaward
Reporting System. The public may view first-tier subcontract award data at http://usaspending.gov.
Definitions
As used in FAR 52.204-10:
Executive means officers, managing partners, or any other employees in management positions.
First-tier subcontract means a subcontract awarded directly by the Contractor for the purpose of acquiring supplies or
services (including construction) for performance of a prime contract. It does not include the Contractor's supplier
agreements with vendors, such as long-term arrangements for materials or supplies that would benefit multiple contracts
and/or the costs of which are normally applied to a Contractor’s general and administrative expenses or indirect cost.
Total compensation means the cash and noncash dollar value earned
by the executive during the Contractor's preceding
fiscal year and includes the following (for more information see 17 CFR 229.402(c)(2)):
(1) Salary and bonus.
(2) Awards of stock, stock options, and stock appreciation rights. Use the dollar amount recognized for financial
statement reporting purposes with respect to the fiscal year in accordance with the
Financial Accounting
Standards Board's Accounting Standards Codification (FASB ASC) 718, Compensation-Stock Compensation.
(3) Earnings for services und
er non-equity incentive plans. This does not include group life, health,
hospitalization or medical reimbursement plans that do not discriminate in favor of executives, and are available
generally to all salaried employees.
(4) Change in pension value. This is the change in present value of defined benefit and actuarial pension plans.
(5) Above-market earnings on deferred compensation which is not tax-qualified.
(6) Other compensation, if the aggregate value of all such other compensation (e.g., severance, termination
payments, value of life insurance paid on behalf of the employee, perquisites or property) for the executive
exceeds $10,000.
Further information about the Transparency Act is available at:
www.USAspending.gov & www.whitehouse.gov/omb/open