CMMC Update by Glenda R. Snodgrass for The Net Effect
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June 22, 2026

The FAR CUI Rule is Back!

The FAR Revolutionary Federal Acquisition Regulation Overhaul Parts 1, 2, 4, 33, 39, 40, and 53 has been released and it includes the proposed FAR CUI Rule, with only minor revisions. Word on the street says this rule will be final by year-end.

Hot Takes:

  • Better definitions of FCI (now CFI) and CUI
  • CUI must be identified by USG in the new form SF XXX ("Contractors are required to safeguard only the CUI that is identified in the SF XXX")
  • Hard-coded to 800-171r3 not r2
  • The DoD/DoW ODPs must be applied for all r3 requirements
  • Your SSP and POAM must be available upon request

I'll write more when I've had time to digest all 439 pages!

Wanna chat? Reach out.



Glenda R. Snodgrass Sincerely,

Glenda R. Snodgrass, CCP/CCA/Lead CCA
grs@theneteffect.com
The Net Effect, LLC
www.theneteffect.com
251-433-0196 x107

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