52.204-17
Ownership or Control of Offeror
FAR 52.204-17 requires offerors to disclose detailed ownership and control information, including CAGE codes and legal names, to ensure transparency and compliance in federal contracting.
Overview
FAR 52.204-17 requires offerors to disclose information about their ownership or control structure as part of the government contracting process. The provision is designed to increase transparency regarding who ultimately owns or controls the entity submitting an offer, which helps agencies assess potential risks, conflicts of interest, or eligibility concerns. Offerors must provide details about their immediate and highest-level owners, including CAGE codes and legal names, and indicate whether their immediate owner is itself owned or controlled by another entity. This information is especially important for joint ventures, where each participant must provide ownership details.
Key Rules
- Disclosure of Immediate Owner
- Offerors must state whether they have an immediate owner and, if so, provide the immediate owner's CAGE code and legal name.
- Disclosure of Highest-Level Owner
- If the immediate owner is owned or controlled by another entity, the offeror must also provide the highest-level owner's CAGE code and legal name.
- Applicability to Joint Ventures
- Each participant in a joint venture must submit ownership information individually.
- Use of Legal Names
- Only legal names (not "doing business as" names) are to be used in disclosures.
Responsibilities
- Contracting Officers: Must ensure offerors complete the provision and review ownership disclosures for compliance and risk assessment.
- Contractors/Offerors: Must accurately disclose ownership/control information, including CAGE codes and legal names, for themselves and any parent entities.
- Agencies: Use the information to verify eligibility, assess risk, and maintain transparency in the procurement process.
Practical Implications
- This provision exists to prevent fraud, conflicts of interest, and improper contract awards by clarifying ownership structures.
- It impacts daily compliance by requiring offerors to maintain up-to-date ownership records and understand their own corporate structure.
- Common pitfalls include failing to provide accurate CAGE codes, using incorrect names, or omitting required ownership layers, which can delay or jeopardize contract awards.