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section32.1105

Assignment of claims

Overview

This section clarifies that Electronic Funds Transfer (EFT) payment instructions cannot be used as a substitute for a formal assignment of claims conducted under FAR subpart 32.8.

Key Rules

  • Legal Distinction: EFT payment methods and the formal "assignment of claims" process are legally distinct; one does not satisfy the requirements of the other.
  • Third-Party Recipients: If EFT instructions designate a recipient other than the contractor without a properly executed assignment of claims, the government classifies this as "incorrect EFT information."
  • Consequences of Non-compliance: Providing EFT information for a third party without a valid assignment triggers the "Suspension of Payment" provisions under FAR clauses 52.232-33 and 52.232-34.

Practical Implications

  • Contractors cannot redirect payments to lenders or third parties simply by updating banking details; they must complete the rigorous legal documentation required by FAR 32.8.
  • Government certifying officers are authorized to halt payments if they notice a discrepancy between the contractor of record and the bank account holder, protecting the government from liability for improper payment.

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