Requirements

Cybersecurity Assessment Requirements for Federal Contractors

OVERVIEW


On September 29, 2020, the US Department of Defense (DoD) released the highly anticipated interim rule (“Interim Rule”) amending the Defense Federal Acquisition Regulation Supplement (DFARS) to implement the DoD Assessment Methodology and Cybersecurity Maturity Model Certification (CMMC). This new Interim Rule is effective November 30, 2020, in advance of promulgation of a future final rule. (DFARS Case 2019-D041; 85 FR 61505.)

IN DEPTH


NEW INTERIM COMPLIANCE OBLIGATION: COMPLIANCE CERTIFICATION UNDER NIST 800-171

The most significant change in the Interim Rule is the introduction of the new obligation for federal contractors to either self-certify or obtain a third-party assessment methodology to certify contractor compliance with cybersecurity requirements. (Click here for McDermott’s analysis.) Pursuant to the Interim Rule, beginning November 30, 2020, all contractors and subcontractors who accept contracts containing DFARS clause 252.204-7012 will need to comply with the National Institute of Standards and Technology (NIST) Assessment methodology for initial assessments, and update those assessments every three years.

This framework expands on existing requirements for federal contractors, as set forth by DFARS Clause 242.204-7012 and NIST Special Publication (SP) 800-171.

NIST SP 800-171 ASSESSMENT METHODOLOGY 

The NIST Assessment Methodology is designed to enable the federal government to assess its prime contractors and for the prime contractors to assess their subcontractors.

To qualify for new contract awards after the implementation date of the Interim Rule, contractors and subcontractors are required to have an assessment on record within the last three years (or more recently for certain contracts). (Interim Rule, 85 FR at 61506.)

The methodology provides for three types of assessments. (Assessment Methodology at 3-5.)

  • Basic. Basic Assessments are self-assessments performed by the contractor or the subcontractor against the 110 controls of NIST SP 800-171. A Basic Assessment provides only a minimum level of confidence in the resulting score because it

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Different mortgage rates and requirements

If you’ve been comparing mortgage rates for the purchase of a second home or an investment property, you’re already on a promising path: You’ll either have a place to go for vacations, or you’ll have a place that’ll generate income and put more money in your pocket.



a view of a picnic table: A view from an outdoor patio


© alexandre zveiger/Shutterstock
A view from an outdoor patio

Either way, the opportunity to own more than one property is an enviable position to be in, but how you classify that property makes a difference in how much you’ll pay to finance and own it.

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Second home vs. investment property

Are you buying a second home, or are you making an investment?

This might be confusing, especially if you’re thinking about occasionally renting out the property – using it regularly for vacation, for example, but also making it available on Airbnb for some of the time you’re not using the property and instead are living in your primary residence.

Earning some money from your property doesn’t automatically make it an investment, however. Accurately defining the piece of property depends on how much time you spend in it.

Elliot Pepper, co-founder, certified financial planner and director of tax at Northbrook Financial in Baltimore says that you need to pay attention to what he calls “the 14-day limit rule.”

“Very broadly speaking, if you personally live in your second home for 14 days or fewer – or less than 10 percent of the days it is rented – during a year, then it would be considered a rental property and the income earned would be taxable,” Pepper says, “but you would also deduct the expenses associated with the property.”

On the flip side, if you use the property for more than 14 days or more than 10 percent of the time it’s rented,

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General Contractors Licenses and Requirements

Finding a good general contractor can be challenging. Fortunately, British Columbia’s Homeowner Protection Act is a set of laws and guidelines established by the Homeowner Protection Office (HPO) to ensure builder credentials. These licensing requirements were developed in order to prevent the construction of unsafe or poorly constructed buildings. In British Columbia, provincial licensing is a requirement for many trades including residential building, building envelope renovations, gas piping, gas venting, refrigeration and air conditioning mechanics, sheet metal workers, plumbers, electricians, and gas fitters.

Residential Building

Builders responsible for constructing homes in BC must be a Licensed Residential Builder. These licensed professionals are also required to offer warranties covering the new building for up to 7 years. Moreover, under this license, contractors are responsible for all aspects of construction from permits to landscaping. It is also the responsibility of this contractor to ensure that all subcontractors are also licensed by the province.

Building Envelope Renovation

Contractors who remodel buildings without impacting structural elements are known as envelope renovators. These contractors are licensed similarly to residential building contractors, and they are also required to provide a warranty or insurance on the renovation. Similarly, these contractors must ensure licenses for subcontractors.

Gas Piping

Gas piping licenses are required for individuals who install and test gas piping. These professionals must have a sheet metal trades license and a certification of qualification. The certificate of qualification is a general certification for many trades.

Gas Venting License

This license allows professionals to repair, alter, and install venting for use in high pressure natural gas and propane applications.

Refrigeration and Air Conditioning Mechanics

These professionals install, maintain, and repair residential, industrial, and commercial refrigeration and air conditioning units. This requires a certification of qualification.

Sheet Metal

Sheet metal workers are certified to design, manufacture, install, erect, assemble, …

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