1526851

I am working with a client that would like to terminate their FAAP agreement to move to an establishment based AAP structure. Section II. B. of the agreement states “During an open compliance evaluation of a MB Int. Holdco functional or business unit, OFCCP will extend the term of this Agreement until the evaluation is complete.” The company currently has an open audit for one of their functional plans and we are wondering how to interpret this. Does this mean we have to wait until the audit is over to terminate this agreement? On the one hand, I could read this to mean that if the agreement is ending in general, the OFCCP will allow it to extend beyond the term to complete an audit, but I could also read it to suggest that we cannot terminate this until our audit is over.