On December 29,2014, the Small Business Administration (SBA) published its proposed rule to implement provisions of the National Defense Authorization Act of 2013 (NDAA) that change the way firms calculate compliance with the limitation on subcontracting rule on small business set-asides. SBA's proposed rule also proposes changes dealing with the nonmanufacturing rule, affiliation and joint ventures.

This memorandum summarizes the key provisions of the proposed rule. Comments are due to SBA on, or before, February 27,2015. We are continuing to analyze this proposal and the potential impact on small businesses and their large business subcontractors. We would appreciate your thoughts. Please email them to me at pmazza@pilieromazza.com. Any thoughts will be helpful to us as we develop our comments to SBA. We encourage everyone to submit comments on this important rule as SBA carefully considers comments from the community before issuing its final rule.