Transferability (Section 6418 Transfer of Certain Credits) Proposed Rule

SMART and SMACNA address transferability from two perspectives: first, as supporters of compliance with prevailing wage requirements for the protection of workers and to protect signatory contractors who comply with labor standards from underbidding

SMART and SMACNA address transferability from two perspectives: first, as supporters of compliance with prevailing wage requirements for the protection of workers and to protect signatory contractors who comply with labor standards from underbidding by violators of these prevailing wage standards; and second, as supporters of small businesses who will benefit from tax credits and create “good”[1] union jobs in communities. 


Aug 14, 2023 Regulatory Comments

Latest Articles


Joint Comments of SMART and SMACNA to the Proposed Rule on Accountability in Higher Education and Access Through Demand-Driven Workforce Pell

Apr 10, 2026 - April 8, 2026 - Joint Comments of SMART and SMACNA to the Proposed Rule on Accountability in Higher Education and Access Through Demand-Driven Workforce Pell


Joint Comments of SMART and SMACNA - Prohibiting Illegal Discrimination in Registered Apprenticeship Programs

Sep 15, 2025 - Joint Comments of SMART and SMACNA - Prohibiting Illegal Discrimination in Registered Apprenticeship Programs