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    Dear Professor, Please clarify for me: What are the regulations of FAR of releasing (obligations) funds in the contract? if so how many days after the contract is signed? Any exclusions? Your prompt response would be greatly appreciated. V/r Luz


    FAR 32.7 covers Contract Funding.  Generally, contracts are fully funded, which means the funds are obligated by the contracting officer at the time of award to cover the price or estimated cost of the contract.  See 32.703-1(a).  If the contract is incrementally funded, funds are obligated by the contracting officer to cover the amount allotted and any corresponding increment of fee.  See FAR 32.703-1(b). 

    Detailed acquisition funding requirements are contained in agency fiscal regulations, so I would refer to your SEC Chief Financial Office (CFO) for more detailed requirements.  I have not heard of a 5 day verification compliance of relaease/obligation of funds after the contract has been signed.  It sounds like an internal SEC CFO regulation or policy.  Note that the wording is critical in any discussion with the CFO office and Contracting Office.  They may consider obligation of funds 2 two different things.  Funds availability (the CFO making or releasing funds that the contracting office can then obligate) is also different from obligating funds.

    Other than FAR 32.7, you may want to research the GAO Redbook (Principles of Federal Appropriations), Volume II, Chapter 7, Obligation of Appropriations.

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