Tag: Tennessee

Gov’t-Watching: Newly Issued Comptroller General Legal Decisions, 27 August 2025

[from the United States Government Accountability Office]

The Government Accountability Office (GAO) today issued the following legal decisions and opinions of the Comptroller General:

Bid Protest Decisions

B-422245.6 [archived PDF], Centuria Corporation, August 1, 2025

Centuria Corporation, a service-disabled veteran-owned small business (SDVOSB) of Reston, Virginia, protests the issuance of a task order to DecisionPoint Corporation, known at the time of proposal submission as EmeSec Inc., a SDVOSB of Gaithersburg, Maryland, under fair opportunity proposal request (FOPR) No. FA8773-23-R-0003, issued by the Department of the Air Force for defensive cyber realization, integration, and operational support services. Centuria argues that the Air Force conducted discussions with the awardee without affording it an opportunity to submit a revised proposal as required by Federal Acquisition Regulation (FAR) section 15.307(b).

We deny the protest.

B-423635 [archived PDF], Helgen Industries d/b/a DeSantis Gunhide, August 26, 2025

Helgen Industries, doing business as DeSantis Gunhide, protests the award of a contract to Safariland, LLC, under request for proposals (RFP) No. SHOP-PR-25-001520, issued by the Department of Justice, Federal Bureau of Investigation (FBI), for concealment and tactical holsters. The protester contends that the awardee is an ineligible large business.

We dismiss the protest.

B-422666.2 [archived PDF], Perimeter Security Partners, LLC—Costs, August 8, 2025

Perimeter Security Partners, LLC (PSP), a small business of Brentwood, Tennessee, requests that our Office recommend that it be reimbursed for the costs of filing and pursuing its protest challenging the issuance of a task order to Low Voltage Wiring, Ltd. (LVW), a small business of Colorado Springs, Colorado, under request for quotations (RFQ) No. W912DY-24-R-0008, issued by the Department of the Army, U.S. Army Corps of Engineers (Corps), for preventative and corrective maintenance services for access control points at 19 Army installations in the northeast region of the United States. PSP argues that it should be reimbursed its protest costs because the agency unduly delayed taking corrective action in response to its clearly meritorious protest.

We grant the request.

Congressional Review Act

B-337397 [archived PDF], U.S. Department of Health and Human Services—Applicability of the Congressional Review Act to Policy on Adhering to the Text of the Administrative Procedure Act, August 27, 2025

On March 3, 2025, the U.S. Department of Health and Human Services (HHS) published in the Federal Register a policy statement titled, Policy on Adhering to the Text of the Administrative Procedure Act (2025 Policy Statement or Policy Statement). The 2025 Policy Statement rescinds a prior policy generally requiring HHS agencies and offices to use Administrative Procedure Act (APA) notice-and-comment procedures for rules relating to public property, loans, grants, benefits, or contracts and establishes a new policy giving HHS agencies and offices discretion whether to use notice-and-comment procedures for such rules.

The Congressional Review Act (CRA) requires that before a rule can take effect, an agency must submit the rule to both the House of Representatives and the Senate, as well as the Comptroller General. CRA adopts the definition of “rule” under APA but excludes certain categories of rules from coverage. We conclude that the 2025 Policy Statement is a rule for purposes of CRA because it meets the APA definition of a rule, and no CRA exception applies. Therefore, the Policy Statement is a rule subject to CRA’s submission requirements.

Economics-Watching: Money Transmitter Regulation: Key to Payments Modernization

[from the Federal Reserve Bank of Atlanta, by Claire Greene, payments risk expert in the Retail Payments Risk Forum]

In October, I wrote about the potential for standards to make business-to-business payments more efficient. Today, let’s talk about standards again, this time for money transfer businesses and the state regulations covering them.

We all know these businesses: Venmo, Western Union, MoneyGram, PayPal, CashApp. The roster seemingly grows by the day. Many crypto firms also are registered money transfer businesses. Money transfer businesses typically are nationwide and global in scope. Nevertheless, these multi-state and multi-national businesses are regulated under the separate licensing rules of individual states and US territories. Federal laws, including the Bank Secrecy Act and the Electronic Fund Transfer Act, also apply to money transfer businesses.

For new and established money transfer businesses and for state regulators, the hodgepodge of state regulations creates headaches. To do business everywhere in the United States, money transfer businesses must register separately in each state and US territory and meet license requirements that can vary from state to state. They can face multiple state examinations, also with different requirements, simultaneously (and annually). During examinations, regulators review operations, financial condition, management, and compliance with anti-money laundering laws.

Fortunately, many states have acted to address this confusing and inefficient situation by adopting the Model Money Transmission Modernization Act (MTMA) [archived PDF], sample legislation developed by the Conference of State Bank Supervisors to establish nationwide standards and requirements for licensed money transmitters. Fourteen states have adopted some version of the MTMA: Arizona, Arkansas, Georgia, Hawaii, Indiana, Iowa, Minnesota, Nevada, New Hampshire, North Dakota, South Dakota, Tennessee, Texas, and West Virginia. In my home state of Massachusetts, the legislature’s Joint Committee on Financial Services heard testimony on a version of this bill just last month. For traditional money transmitters and new fintech entrants, the MTMA aims to reduce the substantive and technical differences among the various state laws and regulations. This kind of change has the potential to reduce compliance burdens, encourage innovation, and remove barriers to entry for new market participants.

The MTMA is important given the prodigious growth in person-to-person, or P2P, payments via apps. Among all US consumers, half of P2P payments were sent using noncash methods in 2022, up from less than 30 percent in 2020 (see the chart). From Massachusetts alone, money transmitters sent $31 billion in 2022, according to the state’s Division of Banks.

Half of P2P payments were made electronically in 2022.

The MTMA also has the potential to create efficiencies for state supervisors. For example, the Conference of State Bank Supervisors (CSBS) has facilitated a collaborative exam program for nationwide payments and cryptocurrency firms to undergo one exam, each facilitated by one state overseeing a group of examiners sourced from across the country. According to the CSBS, transmitters in more than 40 states that have laws addressing core precepts can benefit from the streamlined exams.

The MTMA is another example showing that standards create efficiencies that are good for businesses, good for regulators and, by extension, good for consumers.