A partner's SAM or CAGE record shows only the identifiers and owner information that the record lists on the day you look. Compare each field with what the partner told you, log mismatches as questions, and route ownership, conflict, or foreign-ownership concerns to the person who decides them. The log below is a recommended screening method, not a legal finding.

What the FAR definition gives you to look for

FAR 4.1801 defines the immediate owner concept that owner questions are built around: "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."

Two practical points follow from the wording. First, the list is open ("include, but are not limited to"), and the definition specifies no ownership percentage, so do not turn a percentage into a pass or fail screen. Second, the indicators are observable in ordinary diligence. You can notice a shared office, a shared leadership team or staff who move between two companies during a capability briefing, even when no owner appears in any record. Those observations belong in your log as questions, not conclusions.

Ownership record comparison log

Use one log per prospective partner. Record the partner’s written statement separately from the field you actually observed, with its tool, identifier and date.

PARTNER OWNERSHIP COMPARISON
Partner and pursuit: [name and internal reference]
Field checked: [choose one from the list below]
Partner statement: [written source and date]
Record observed: [tool, identifier, field value and observation date]
Comparison: [match / no match / not listed / not checked]
Open factual question: [question, not a finding]
Responsible reviewer and next action: [name/role, action and due date]

Repeat the record for legal business name; CAGE code and UEI; physical address; any listed immediate or higher-level owner; any listed owner address outside the United States; and any recent name, address or ownership change mentioned by either side. Log observed shared management, facilities, equipment or employees separately as diligence observations, not as a CAGE record field.

The partner can clarify factual discrepancies. Route material ownership, control, conflict or security questions to the responsible contracts, compliance or legal reviewer for your team.

How to read a result:

  • Match means the partner's statement and the record agree on that date. It does not establish eligibility, an organizational conflict of interest outcome, a foreign ownership, control or influence (FOCI) outcome, or a small business affiliation outcome.
  • No match means you have a question. It is not a disqualification. A record can lag behind a change, a name can be abbreviated, or a partner may have given you identifiers for a different location.
  • Not listed means the record you opened shows no entry for that field. Combined with observed control indicators, it is a reason to ask, not a reason to assume either way.

Running the comparison

  1. Ask first, look second. Request the partner's legal business name, CAGE code, UEI and any owner names in writing before you search. Comparing against a written statement is what makes the log useful.
  2. Look up the record you can access. Use the partner's SAM.gov entity record and, if helpful, the DLA CAGE search at cage.dla.mil. Save a dated copy or note of what each field showed. Do not rely on memory of a screen. For why exact legal name matching matters, see how to pass SAM.gov entity validation.
  3. Fill each evidence field. Write not checked for an unreviewed field, rather than none.
  4. Write one question per mismatch or observed indicator. Keep questions factual: "Your statement lists no owner; we noticed shared staff with Company B. Can you describe the relationship?"
  5. Route before you sign. Route material ownership and control questions to your designated reviewer, and foreign-ownership concerns to whoever handles security and ownership review for your team. A field comparison is not a determination of affiliation, conflict or FOCI. Teaming terms that depend on the answers are covered in teaming agreements and joint ventures in federal contracting.
  6. Repeat the lookup close to signing. Records change, and a stale check is easy to overlook.

Illustration (hypothetical)

Partner statement (email, 2026-11-02): no immediate owner. Record shows (2026-11-06): no immediate owner listed. Match on the record field. Diligence note: capability briefing presenters included two staff introduced as employees of another firm at the same street address. Indicators observed: shared facilities, possible common use of employees. Question routed to counsel 2026-11-06. Teaming agreement on hold pending answer.

The record and the statement agreed, yet the log still surfaced a question that a field-only check would have missed. That is the point of recording diligence observations alongside the record.

Next step

Explore public federal contracting opportunities on FedFinder. Review current terms on the pricing page.

Sources

  • Federal Acquisition Regulation Subpart 4.18, Commercial and Government Entity Code, section 4.1801 Definitions. Acquisition.gov. https://www.acquisition.gov/far/subpart-4.18. Retrieved 2026-11-06. Page showed FAC 2026-01, effective 2026-03-13; confirm applicability in the actual solicitation.