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    Does the Tongue & Quill guidance for signature blocks trump the guidance I received? Or should a CO's signature block -- when signing any document as the CO -- contain only their name and "Contracting Officer" as on the warrant?


    Answer

    The FAR doesn't specifically address whether or not rank or grade should be included in the signature block.  FAR 4.101 -- Contracting Officer's Signature reads as follows:
     
      Only contracting officers shall sign contracts on behalf of the United States. The contracting officer's name and official title shall be typed, stamped, or printed on the contract. The contracting   officer normally signs the contract after it has been signed by the contractor. The contracting officer shall ensure that the signer(s) have authority to bind the contractor (see specific requirements   in 4.102 of this subpart).
     
    FAR 2.101 defines "signature" as "(meaning) the discrete, verifiable symbol of an individual which, when affixed to a writing with the knowledge and consent of the individual, indicates a present intention to authenticate the writing. This includes electronic symbols."
     
    DFARS doesn't help to clarify this issue either.  DFARS PGI 204.101 Contracting officer's signature states as follows:
     
      (1) Include the contracting officer's telephone number and, when available, e-mail/Internet address on contracts and modifications.
     
      (2) The contracting officer may sign bilateral modification of a letter contract before signature by the contractor.
     
    Bottom line: I was taught the same as you to only include my name and "Contracting Officer" and not include rank/grade in the signature block for documents I was signing as the contracting officer, but the FAR is silent on this issue which to me means that it is not prohibited by the FAR.  The reason rank/grade is not included in the Contracting officer's warrant might simply be for convenience.  A person's rank/grade can change over time while their warrant can last for many years after their rank has changed.  By not including the rank/grade in the warrant, it avoids the problem of having to get the warrant redone whenever the person's rank/grade changes.  While I don't think including the rank/grade in the signature block invalidates the signature, if I were signing as the Contracting Officer, I would prefer my title in the signature block of the contract document to be consistent with the title that's used in my warrant.  However, I think it's more important to ensure that the person signing the contract is authorized to sign and it's their typed name, and title of "Contracting Officer" in the signature block regardless of whether or not the rank/grade is included as well.  There is another Ask a Professor on the same subject entitled, "Contracting Officer Signature Blocks", dated May 4, 2016 (AAP ID #: 124902), which you may also find helpful.
     

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