TrustedSec guidance: FCI and CUI safeguarding obligations do not apply pre-contract, and CMMC cannot be imposed during solicitation
TrustedSec (author Chris Camejo) explains that FCI and CUI safeguarding obligations do not exist during the pre-contract solicitation phase unless the contractor has agreed to a specific pre-contract agreement. Prime contractors, especially large DoD primes, are increasingly pushing CMMC, FAR 52.204-21 and DFARS 252.204-7012/7021 requirem…