In March 2022, we reported on a controversial directive issued by the Office of Federal Contract Compliance Programs (OFCCP) that appeared to assert, for the first time, that federal contractors and subcontractors are required to conduct statistical pay equity audits on an annual basis, and also took an aggressive position that documents relating to these audits are likely not protected by the attorney-client privilege or work product doctrine.  In response to widespread criticism from the contractor community, OFCCP, on August 18, 2022, issued a new, “revised” directive that yields ground on some of the prior directive’s more aggressive positions.