The Executive Branch recently issued its interim rules implementing the Buy American restrictions of the American Recovery and Reinvestment Act of 2009 (the “Recovery Act”). On April 3, 2009, the Federal Acquisition Regulation (FAR) Council issued regulations covering direct federal contracts, 74 Fed. Reg. 14621 (Apr. 3, 2009), and on April 23, 2009, the Office of Management and Budget (OMB) regulations covering grants, cooperative agreements and loans for state and local procurements appeared in the Federal Register, 74 Fed. Reg. 18449 (Apr. 23, 2009).

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