On May 4, 2016, the FAR Council’s draft final rules and the Department of Labor’s draft final guidance implementing the “Fair Pay and Safe Workplaces” Executive Order arrived at the White House’s Office of Information and Regulatory Affairs (OIRA) for review, setting in motion the final steps prior to the issuance of burdensome new compliance and reporting obligations for federal contractors and subcontractors (discussed here).  OIRA has 90 days to conduct its review of the rules before sending them to the FAR Secretariat for publication, a period during which OFPP and other OMB offices, contractors, and industry trade groups, may meet with OIRA to share their concerns, in advance of the publication of new FAR rules likely to trigger vigorous legal challenges from industry.