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CAGE code for a holding company


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We became an ESOP last year, and as part of the transaction created a holding company that now owns all of the outstanding stock.  Does that holding company need a CAGE code?  When I'm filling out the ownership information on SAM.GOV do i need to say the ownership information has changed?  The operating company did not change, it still has the same EIN and performs the same type of work.

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See the definition of 'immediate owner' and required representation per FAR 52.204-17 :

"Immediate owner means an entity, other than the offeror, that has direct control of the offeror. Indicators of control include, but are not limited to, one or more of the following: ownership or interlocking management, identity of interests among family members, shared facilities and equipment, and the common use of employees.

(b) The Offeror represents that it  has or  does not have an immediate owner. If the Offeror has more than one immediate owner (such as a joint venture), then the Offeror shall respond to paragraph (c) and if applicable, paragraph (d) of this provision for each participant in the joint venture."

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