Sam Registration for second company

[PATRICK3]

Quick question. One company is registered in SAM, but the award is going to be given to their other company. Think of Lockheed Martin as the main company and Lockheed Martin Germany as the company that wants the award. Both are under the same entity. Question is, does Germany need to be registered in SAM as well, or do we use the the main company's SAM registration for award? As long as Lockheed Martin Germany has a Cage Code and DUNS, is that enough to award to them without SAM registration? Thanks 

[ji20874]

Please refer to FAR 52.204-7, System for Award Management.

You need to decide whether the two concerns are parts of one company, or two separate companies.

[PATRICK3]

Thank you @ji20874

[Fara Fasat]

Your facts are confusing. You talk about a "main company" but then say that both that and the company in Germany are "under" the same entity. Do you mean that both are subsidiaries of a parent company?

Anyhow, it probably doesn't matter in the end. A SAM registration is required for each separate legal entity, and each separate division or branch of an entity. SAM considers a division or branch as a separate entity, even though in the legal sense it is not. Back when the ownership reporting came out, we questioned DLA about this, and their answer was that subsidiaries, divisions, and branches are all considered entities. The "owner" of a division is the next level up in the corporate hierarchy.

Besides, from a practical standpoint, you want the Germany company to have its own registration even if it is a division and not a separate legal entity. All of its administrative information, address, banking information, points of contact, etc, will be different from that of the "main" company that you want to use. Just register it, and get an NCAGE too.

[PATRICK3]

Thanks @Fara Fasat