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GSA Lease Terminations and DOGE: Limits, Landlord Rights and Remedies, Risk Mitigation Strategies

Recording of a 90-minute premium CLE video webinar with Q&A

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Conducted on Thursday, June 26, 2025

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This CLE webinar will examine the new administration's GSA lease termination process and limits to when GSA leases may be terminated. The panel will also discuss what landlords should be doing to mitigate the risk of termination for default or other reasons that may allow for an early lease termination and what remedies landlords may have if a lease is terminated.

Description

As part of the new administration’s cost reduction efforts, the Department of Government Efficiency (DOGE) and the U.S. General Services Administration (GSA) have targeted federal government leases in commercial buildings across the country causing concern and confusion for landlords with tenants under GSA leases.

While some government contracts allow federal agencies to terminate for convenience, the same is not true of GSA leases. GSA leases typically include two lease terms—the "soft term" during which the GSA may terminate the lease without penalty, and the "firm term" during which the GSA has no right to terminate the lease early unless there is another allowable reason, such as termination for default where the lessor will not or cannot cure.

Counsel and their landlord clients should understand the impact of these lease cancellations, what they should be doing to mitigate the risk of default or other actions that could allow for lease termination even during the firm term, and what rights they may have when leases are terminated.

 Listen as our expert panel examines the new administration's GSA lease termination process and provides an overview of landlord rights and best practices for risk mitigation.

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Outline

  1. Introduction: DOGE and GSA lease terminations
    1. Policy history: EOs, decisions, rules
    2. Purpose
    3. Potential market impact
  2. GSA lease termination limits
    1. Firm term vs. soft term
    2. Termination for convenience vs. termination for cause
    3. Termination for default
    4. Other reasons for termination
  3. Landlord risk mitigation strategies
    1. Lease review to ensure compliance
    2. Maintenance requirements
    3. Security measures or services
    4. Vacancy clauses
    5. Holdover rights
    6. Other considerations
  4. Landlord rights upon lease termination
  5. Practitioner takeaways

Benefits

The panel will review these and other important considerations:

  • When and under what circumstances may GSA leases be terminated?
  • What should counsel and landlord clients be doing now to mitigate the risk of a lease termination during the firm term?
  • What remedies do landlords have when GSA leases are terminated?

Faculty

Gallo, Ferdinand
Ferdinand J. Gallo, III
Partner
Morgan, Lewis & Bockius

Mr. Gallo’s practice covers all aspects of real estate investment, acquisition, development, financing, and...  |  Read More

Griffin, Gordon
Gordon Griffin
Partner
Holland & Knight

Mr. Griffin is a government contracts attorney with a practice focused on federal leases and other real estate...  |  Read More

McCarthy, Michael
Michael J. McCarthy
Partner
Morgan, Lewis & Bockius

A veteran real estate finance lawyer, Mr. McCarthy advises institutional lenders, borrowers, and investors on a variety...  |  Read More

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