PBGC RFP 16PBGC25R0052 0002 Attachment 8 - QandA - Final.xlsx
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- Attached to
- PBGC Active EME Investment Management Services
- Solicitation number
- 16PBGC25R0052
- Issued by
-
Pension Benefit Guaranty Corporation
About this file
This document is a Questions and Answers (Q&A) attachment for the Pension Benefit Guaranty Corporation's (PBGC) Request for Proposal (RFP) for Active Emerging Market Equity Investment Management Services, solicitation number 16PBGC25R0052. The Q&A provides detailed clarifications on mandatory requirements, submission guidelines, and key aspects of the procurement.
Key details include a phased submission process with Phase 1 due by June 9, 2025, focusing on a mandatory requirements questionnaire for investment managers. Critical requirements include: having a minimum of $3 billion in Assets Under Management (AUM) in the proposed strategy, offering a commingled fund acceptable to tax-exempt investors (not mutual funds or ETFs), maintaining a rolling 36-month information ratio of at least 0.30, and having a tracking error below 9.0% over 10 years. The RFP also includes an optional Emerging Markets ex-China strategy, for which pricing submission is required but a live track record is not. Offerors must submit comprehensive documentation including GIPS-compliant performance records, financial statements, and detailed responses to technical and firm resource questionnaires.
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Sheet1
| ATTACHMENT 8 |
| Questions and Answers |
| Solicitation Number: | 16PBGC25R0052 |
| Amendment: | 0002 |
| PART # | PARAGRAPH # | PARAGRAPH TITLE | QUESTION | GOVERNMENT RESPONSE |
| PBGC_RFP_16PBGC25R0052_Attachment_2a_-_Phase_1_Mandatory_Requirements_Questionnaire | E | The Offeror must have a minimum of $3 billion in AUM in the proposed strategy | We have a question related to the Mandatory Requirements -E – AUM. |
| We have two EME strategies managed by the same team and process, one of which is more concentrated and each with its own composite. The combined AUM is $3B+. Would this pass the requirement? We typically represent the combined AUM. | In accordance with the Request for Proposal Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph E states, "the Offeror must have a minimum of $3 billion in AUM in the proposed strategy." The Government would not accept the combined AUM of the two strategies for the requirement. One of the strategies needs to have a minimum of $3 billion in AUM to pass the requirement. | ||||
| Active_EME_Mangement_Services_Solicitation_Cover_Letter | N/A | Phase 1 | Please confirm the that only documents required by the May 28, 2025 Phase 1 deadline are (1) Mandatory Requirements Questionnaire and (2) Rolling IR Mandatory Supporting Documentation Excel file. | In accordance with the Request for Proposal Sections L.1.1, L.6, Table L.6.1, and L.7 the Phase 1, Volume 1 - Preliminary Technical Proposal Mandatory Requirements Questionnaire (Factor 1) Instructions provides the requirements for the Phase 1 submission. Prospective offerors must submit a cover letter, the Mandatory Requirements Questionnaire (Attachment 2a) and Attachment 2b as part of the submission to question F of the questionnaire. Offerors are advised to submit ALL supporting documentation required for each question in Attachment 2a - Mandatory Requirements Questionnaire. | |
| Active_EME_Mangement_Services_Solicitation_Cover_Letter | N/A | Phase 1/2/3 | Please confirm if the Organizational Conflict of Interest Statement is due as part of the Phase 1 submission? | In accordance with the Request for Proposal Section L.8.4.1 Phase 2, Volume 3 – Written Business/Price Proposal (Factor 5), the Conflict of Interest Statement submission is in Phase 2. | |
| Phase_2_Technical_Approach_questionnaire,_firm_resources_questionnaire,_corporate_experience_questionnaire | N/A | N/A | With respect to emerging markets ex-China, should we submit separate proposals for EME and EME ex-China OR a single proposal covering the whole of our emerging markets equity capability? | In accordance with the Request for Proposal Section L.8.1, Phase 2, Volume 2, Factor 2 - Technical Approach, the offeror must complete and submit Attachment 3 - Technical Approach Questionnaire as it relates to their proposed Emerging Market Equity strategy. Additionally, per Section L.8. Phase 2, Volume 3 – Written Business/Price Proposal, the offeror must summit all proposed prices using Attachment 1 - Pricing Schedule, which includes the proposed Emerging Markets Equity strategy and an Emerging Markets ex-China strategy. | |
| Active_EME_Mangement_Services_Solicitation_Cover_Letter | N/A | Phase 2 | If possible, could PBGC provide an approximate timeline for Phase 2 deliverables? We are trying to manage workflow, and any guidance would be greatly appreciated. | Offerors that are notified to proceed to Phase 2 may have at least 25 to 30 days to submit Volumes 2 and 3 proposals. | |
| Active_EME_Mangement_Services_Solicitation_Cover_Letter | N/A | Phase 2 | Will offerors have an opportunity to submit additional questions after the Phase 2 instructions and timeline are released? Or must all questions—regardless of phase—be submitted by the May 21, 2025 deadline? | All questions must be submitted by the May 21, 2025 deadline. | |
| Active_EME_Mangement_Services_Solicitation_Cover_Letter | N/A | Phase 1 | Please confirm if the Pricing Schedule is due as part of the Phase 1 submission? | The Pricing Schedule is due in Phase 2 per Section L.8.4 Phase 2, Volume 3 – Written Business/Price Proposal of the Request for Proposal. | |
| Attachment 2a | E | The Offeror must have a minimum of $3 Billion in AUM in the proposed strategy | In the minimum requirements, it is stated that the Offeror must have a minimum of $3 Billion in AUM in the proposed strategy. Does this AUM requirement pertain to the vehicle, as well or is it just at the strategy level? | In accordance with the Request for Proposal Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph E states, "the offeror must have a minimum of $3 billion in AUM in the proposed strategy." This minimum AUM pertains to the proposed strategy, not to the commingled vehicle. | |
| Attachment 2a | C | The proposed product must be offered to PBGC in a commingled fund |
format acceptable to tax-exempt investors rather than a separate
| account. | Are you considering mutual funds and ETFs as a commingled vehicle? Do you have a vehicle requirement or preference? | In accordance with the Request for Proposal Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph C, the proposed product must be offered to PBGC in a commingled fund vehicle format acceptable to tax-exempt investors. The Government will not consider mutual funds and/or ETFs. | |
| Attachment 2a | C | The proposed product must be offered to PBGC in a commingled fund |
format acceptable to tax-exempt investors rather than a separate
| account. | Will contractual terms (custom agreements or side letters) be required on your side for a direct investment into a mutual fund or ETF? | In accordance with the Request for Proposal Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph C, the proposed product must be offered to PBGC in a commingled fund vehicle format acceptable to tax-exempt investors. While side letters may be required for investment in certain commingled vehicles (such as collective investment trusts and private funds), the Government will not consider mutual funds and/or ETFs for investment. |
| Attachment 2a | FACTOR 1- MANDATORY REQUIREMENTS QUESTIONNAIRE |
| Question E | The Offeror must have a minimum of $3 Billion in AUM in the | |
| proposed strategy. | Our Emerging Markets Strategy with $1.2B in AUM has a highly successful nine-year track record, outperforming the benchmark by +2.8% p.a. net of fees since inception with lower volatility than the index. The strategy’s clients include some large and sophisticated institutions with mandate sizes in the $250M to $500M range. However, we do not meet the RFP mandatory requirement of a minimum of $3B in product AUM which seems high to us and potentially limiting for an active Emerging Markets search where capacity is constrained. Based on our firm and strategy, does it make sense for our firm to participate in the manager bidding process given our current firm AUM of $1.5B? | In accordance with the Request for Proposal Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph E startes, "the offeror must have a minimum of $3 billion in AUM in the proposed strategy." The stated strategy AUM of $1.2 billion would not meet the minimum requirement. |
| Attachment 2a | FACTOR 1- MANDATORY REQUIREMENTS QUESTIONNAIRE |
Question F The proposed product’s rolling 36-month information ratio over the past seven years, or since inception, through December 31, 2024 must
| be at least 0.30. | Does this mean the rolling 36-month information ratio must not be less than 0.3 at any point since inception or over the last seven years? If so, this criterion would appear to us to be very limiting. Based on our analysis, very few managers would satisfy this criterion as we understand it. As of 12/31/2024, our strategy’s realized information ratio since inception was 0.41, and 0.76 for the trailing 7-year period. | As stated in the Request for Proposal Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph F states, "the proposed product's rolling 36-month information ratio over the past seven years, or since inception, through 12/31/24 must be at least 0.30." This minimum IR is meant to be an average of the rolling 36-month IRs over the time period. There can be periods where the 36-month IR is below 0.30 as long as the average over the required time period (either seven years or since inception) is 0.30 or higher. Attachment 2b - Phase 1 Rolling IR Mandatory Supporting Documentation has been extended to 12/31/2024. The attachment has been amended (0001) to reflect data as of 12/31/2024 and has been republished on SAM.gov. The Government will not accept data points after 12/31/2024. Please utilize the amended excel spreadsheet as supporting documentation for the mandatory requirement, paragraph F. | |||
| Attachment 2a - Mandtory Requirements | Factor 1 | E | Requirement E. states that the offeror must have a minimum of $3B in AUM in the proposed strategy. Our Emerging Markets Large Cap has USD $466 million as of 3/31/25. We also have a similarly managed EM All Cap strategy with USD $579 in AUM as well as an Emerging Markets Large Cap Low Volatility Strategy with USD $2 billion in AUM. All three strategies are managed by the same team and utilize the same philosophy and quantitive process. Would the combined USD $3 billion + in AUM across all three of our similarly managed emerging markets strategies meet your minimum qualifications to participate in this search? | In accordance with the Request for Proposal Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph E states, "the Offeror must have a minimum of $3 billion in AUM in the proposed strategy." The Government would not accept the combined AUM of the three strategies for the requirement. One of the strategies needs to have a minimum of $3 billion in AUM to pass the requirement. | |
| Attachment 2a - Mandtory Requirements | Factor 1 | C | Requirement C states that the proposed product must be offered to PBGC in a commingled fund format. We are curretnly contracting with SEI to launch a CIT for our Emerging Markets Large Cap strategy and expect the process to be completed by June 2025. Would our intent to launch a CIT meet your minimum qualifications to participate in this search? | With regards to the requirement that the proposed product be offered in a commingled fund format in Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph C, launching a collective investment trust (CIT) would meet the minimum qualifications. Documentation to support the ability to launch a CIT will be required. This can include any one (or combination) of the following: Draft Declaration of Trust, Preliminary Offering Memorandum/Investment Guidelines, Statement of Additional Information (SAI), CIT Fact Sheet (Draft), ERISA Eligibility Representation, Sample Participation Agreement, or Trustee's Letter of Intent or Certification. |
Attachment 2a has been amended (0002) to reflect the edits to this minimum requirement.
| What information provided in the submission and RFP is subject to public disclosure? | Pursuant to the 41 U.S.C. § 4702, FOIA Exemption 3 (statutory exemption) and FOIA Exemption 4 (trade secrets and confidential commercial information) submitted proposal information is withheld from public disclosure. The Request for Proposal Section L.1- General, (5), (6) and (7) provides guidance to offerors to mark data that the offeror does not wish to make public. If PBGC determines that any proposal information or information marked confidential may be subject to public disclosure PBGC will initiate the Submitter’s Notice process set forth in Executive Order 12,600 and 29 CFR 4901.24.” | |||
| Section C | C.1 | Background | Could you kindly confirm whether the assets associated with the awarded mandate will be considered retirement assets? | PBGC's Trust Fund receives assets from terminated pension plans and is the source of funds related to this contract. The Trust Fund assets are not considered "retirement assets" in that they are not subject to regulation in the same way as private sector pension plans. However, PBGC's Trust Fund may be invested through group trusts described in Rev. Rul. 81-100, as clarified and modified by Rev. Rul. 2011-1, as stated in the Investment Policy Statement. |
| Attachment 2a - Mandtory Requirements Questionnaire | Section F | N/A | What is PBGC’s flexibility if an investment strategy falls slightly short of the 0.30 rolling 36 month trailing 7-years IR requirement? | Per Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph F, the average of the rolling 36-month information ratios (IRs) over the submitted time period should be 0.30 or higher. Data points should be rounded to two decimals. If the average of the rolling IRs is below 0.30, that would not meet the mandatory requirement. |
| Attachment 2a - Mandtory Requirements Questionnaire | Section H | N/A | What is PBGC’s flexibility considering an investment strategy that falls slightly short of your tracking error requirements? | Per Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph H, the the investment strategy must have a tracking error over 2.5% over 10 years or since inception (whichever is shorter) as of 12/31/24. If the tracking error is below 2.5% over this time period, that would not meet the minimum required to move on to Phase 2. |
| L | 7 | Volume 1 – Preliminary Technical Proposal Mandatory Requirements Questionnaire (Factor 1) Instructions | Our strategy meets all of your stated requirements except the information ratio average of 0.30. Currently, our three year information ratio is 0.68 but as a value manager it has been negatively impacted by the underperformance of value vs. growth over the rolling time periods. Since our information ratio is much improved recently, would you accept our proposal given the style bias over this period? | As stated in Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph F states, "the rolling 36-month information ratio (IR) over the past seven years, or since inception, must be at least 0.30 as of 12/31/24." This number is meant to be an average over the time period submitted, meaning that there can be periods where the 36-month rolling IR falls below 0.30 as long as the average over the total time period submitted is 0.30 or higher. The time period captures a full market cycle. If the average rolling 36-month IR is below 0.30 over the time period, that does not meet the Government's minimum requirement. |
Attachment 2b - Phase 1 Rolling IR Mandatory Supporting Documentation has been extended to 12/31/2024. The attachment has been amended (0001) to reflect data as of 12/31/2024 and has been published on SAM.gov. The Government will not accept data points after 12/31/2024. Please utilize the amended excel spreadsheet as supporting documentation for the mandatory requirement, paragraph F.
| Attachment 2a - Mandtory Requirements Questionnaire | Factor 1 - C | The proposed product must be offered to PBGC in a commingled fund format acceptable to tax-exempt investors rather than a separate account. | The commingled pool vehicle that we are considering for the proposal permits both tax-exempt and taxable investors, and currently includes a small portion of taxable investors. All investors - taxable and tax-exempt - must meet strict Accredited Investor and Qualified Purchaser definitions under securities laws. Would the PBGC be comfortable investing in a vehicle that allows taxable investors? | PBGC can invest in a vehicle that permits both tax-exempt and taxable investors. The offeror must still act as an ERISA fiduciary, regardless of vehicle type. |
| Attachment 2a - Mandtory Requirements Questionnaire | Factor 1 - E | The Offeror must have a minimum of $3 Billion in AUM in the proposed strategy | We have a strong EME quant strategy that has $2.8 billion in AUM at 12/31/24, with an additional $0.5 billion in an EME quant version that has a smaller cap tilt. Both versions are managed by the same investment team utilizing the same investment process and models. On a combined basis, their assets exceed $3 billion, but the specific approach that we would be proposing has $2.8 billion. Would this meet your AUM criteria? | In accordance with the Request for Proposal Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph E states, "the Offeror must have a minimum of $3 billion in AUM in the proposed strategy." The Government will not accept the combined AUM of the three strategies for the requirement. One of the strategies needs to have a minimum of $3 billion in AUM to pass the requirement. |
| Attachment 2a - Mandtory Requirements Questionnaire | Factor 1 - A, C, D, E, F, G, H | Supporting Documentation Required:... | Do you have a preferred format for the supporting documentation that must accompany Attachment 2a? For example, should this information be embedded in the table of Attachment 2a, provided as one separate attachment, or be provided as multiple separate attachments? | The only required supporting documentation format is presented in Attachment 2b - Phase 1 Rolling IR Mandatory Supporting Document. The supporting documentation for the other mandatory requirements may be embedded in the table of Attachment 2a or may be provided as a separate attachment, but must be clearly labeled. |
| Sol_16PBGC25R0052; Section L | 8.4 | The offeror shall submit all proposed prices using Attachment 1 - Pricing Schedule….. | If our EME strategy offers an ex-China version, and we submit the optional fee as indicated in Section B, what materials related to the ex-China version are required to be included in the Volume 2 response? | In accordance with the Request for Proposal Section L.8.4, submission of pricing for optional CLIN for Emerging Markets ex-China is required. The Government does not require a live track record for this strategy but does require a proposed price for an investment strategy. The optional CLIN is optional for the Government to utilize, but pricing submission is required for offerors. The offeror is not required to include any responses related to the Emerging Markets ex-China strategy in Volume 2. Furthermore, the Government will only evaluate Volume 2 responses related to the Emerging Markets strategy in accordance with the Request for Proposal Section M. |
| Sol_16PBGC25R0052; Section L | 8.4 | The offeror shall submit all proposed prices using Attachment 1 - Pricing Schedule….. | Does the PBGC require a funded commingled vehicle for the Emerging Markets ex-China strategy? | The Government does not require a funded commingled vehicle for the Emerging Markets ex-China strategy. The only requirement for submission as it relates to the Emerging Markets ex-China strategy is Volume 3 - Business/Price Proposal. Instructions for the Volume 3 submission can be found in the Request for Proposal Section L.8.4 as well as Attachment 1 - Pricing Schedule. |
| Factor 1 - Mandatory Requirements Questionnaire | F | Rolling 36-mo Information Ratio | We do not need the requirement over 5 periods and are wondering if you will still consider our strategy as we meet all other requirements except for F and G? | In accordance with the Request for Proposal Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph F states, "the proposed product's rolling 36-month information ratio over the past seven years, or since inception, through 12/31/24 must be at least 0.30." This minimum IR is meant to be an average of the rolling 36-month IRs over the time period. There can be periods where the 36-month IR is below 0.30 as long as the average over the required time period (either seven years or since inception) is 0.30 or higher. Attachment 2b - Phase 1 Rolling IR Mandatory Supporting Documentation has been extended to 12/31/2024. The attachment has been amended (0001) to reflect data as of 12/31/2024 and has been published on SAM.gov. The Government will not accept data points after 12/31/2024. Please utilize the amended excel spreadsheet as supporting documentation for the mandatory requirement, paragraph F. |
| Factor 1 - Mandatory Requirements Questionnaire | G | 10 year Tracking Error | If a tracking error is ~11% over the 10 year time period requested and will you consider this strategy, whe the offeror has met all other requirements except for F and G? | Per Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph G states, "the investment strategy must have a tracking error below 9.0% over 10 years or since inception (whichever is shorter) as of 12/31/24." If the tracking error is over 9.0% over this time period, that would not meet the Government's requirement to move on to Phase 2. |
| L.1.1 Phase 1 Submission | L.1.1 | A. Volume 1: Preliminary Technical Proposal | Could you please specify the required documents in Phase 1 Submission (Volume 1: Preliminary Technical Proposal)? | In accordance with the Request for Proposal Sections L.1.1, L.6, Table L.6.1, and L.7 the Phase 1, Volume 1 - Preliminary Technical Proposal Mandatory Requirements Questionnaire (Factor 1) Instructions provides the requirements for the Phase 1 submission. Prospective offerors must submit a cover letter, the Mandatory Requirements Questionnaire (Attachment 2a) and Attachment 2b as part of the submission to question F of the questionnaire. Offerors are advised to submit ALL supporting documentation required for each question in Attachment 2a - Mandatory Requirements Questionnaire. |
| L.1.1 Phase 1 Submission | L.1.2 | A. Volume 1: Preliminary Technical Proposal | For phase 1, is there anything else that we need to submit in addition to Attachment 2a- Phase 1, 2b- Phase 1 and the cover letter? | In accordance with the Request for Proposal Sections L.1.1, L.6, Table L.6.1, and L.7 the Phase 1, Volume 1 - Preliminary Technical Proposal Mandatory Requirements Questionnaire (Factor 1) Instructions provides the requirements for the Phase 1 submission. Prospective offerors must submit a cover letter, the Mandatory Requirements Questionnaire (Attachment 2a) and Attachment 2b as part of the submission to question F of the questionnaire. Offerors are advised to submit ALL supporting documentation required for each question in Attachment 2a - Mandatory Requirements Questionnaire. |
| L.1.1 Phase 1 Submission | L.1.1 | A. Volume 1: Preliminary Technical Proposal | Does Attachment 1_Pricing Schedule need to be completed and submitted in Phase 1? | No, Attachment 1 - Pricing Schedule submission is in Phase 2. |
| L.6 Proposal Preparation Instructions | L.6.c | L.6 Proposal Preparation Instructions | Is the Prime UEI number required for phase 1 submission due 5/28 (pg. 70 section C (v)) | No, The UEI is part of the SAM registration. Per FAR Part 52.204-7, SAM registration is required at the time of offer submission and award. Per the Request for Proposal Section L.1 General, SAM registration is required in the Phase 2 submission and at contract award. |
| L.6 Proposal Preparation Instructions | L.6.c | vi. Prime CAGE code | Is the Prime CAGE code required for phase 1 submission due 5/28 (pg. 70 section C (vi)) | No, The CAGE is part of the SAM registration. Per FAR Part 52.204-7, SAM registration is required at the time of offer submission and award. Per the Request for Proposal Section L.1 General, SAM registration is required in the Phase 2 submission and at contract award. |
| L.6 Proposal Preparation Instructions | L.6.c | x. Business size and socio-economic status | What is meant by “socio-economic status” for a privately owned company as opposed to a public corporation (pg. 70 section C (x)) | Socio-economic status refers to the business representation in the context of small business concerns per FAR Part 19 such as Woman-Owned Small Business, Service-Disabled Veteran Owned Small Business, Historically Underutilized Business Zones, and Small Disadvantaged Business to name a few. |
| L.6 Proposal Preparation Instructions | L.6.c | xi. A statement specifying the extent of agreement with all terms, conditions, and |
provisions included in the solicitation and agreement to furnish any or all items upon which prices are
| offered at the price set opposite each item. | We would like clarification on what is meant by “statement specifying the extent of agreement with all terms, conditions, and provisions included in the solicitation and agreement to furnish any or all items upon which prices are offered at the price set opposite each item” (pg. 70 section C (xi)) | This statement means that the offerors have no objection to any of the solicitation's terms, conditions, provisions, and the agreement to provide the services at the agreed upon fees on the price schedule. | |||
| Section J - List of Documents, Exhibits and Other Attachments | Attachment 2b - Phase I ((Pass/Fail) Rolling IR Mandatory Supporting Documentation) | Table 11 - Rolling 36 Month Information Ratio Calculation | Could you provide an updated template which includes the most recently monthly periods through 3/31/2025? Alternatively, can we insert these periods in the current template? | Attachment 2a - - Phase 1 Mandatory Requirements Questionnaire, paragraph F requires that the investment strategy have a rolling 36-month information ratio over the past seven years, or since inception, of at least 0.30 as of 12/31/24. This is the cut-off date for data - Phase 1 submissions that do not meet the requirement as of 12/31/24 will not move to Phase 2. |
Attachment 2b - Phase 1 Rolling IR Mandatory Supporting Documentation has been extended to 12/31/2024. The attachment has been amended (0001) to reflect data as of 12/31/2024 and has been republished on SAM.gov. The Government will not accept data points after 12/31/2024. Please utilize the amended excel spreadsheet as supporting documentation for the mandatory requirement, paragraph F.
| SOL, Section 6.1.2 | 1 | OPTIONAL-Emerging Markets ex-China Strategy | Would an Emerging Markets ex-China strategy need to meet the requirements as listed in phase 1 mandatory requirements questionnaire (section 2a)? | In accordance with the Request for Proposal Section L.8.4, the only required submission for the optional CLIN for Emerging Markets ex-China is Volume 3 - Business/Price Proposal. Volume 3 is to be submitted in Phase 2. The Government does not require a live track record for this strategy but does require a proposed price for an investment strategy. The optional CLIN is optional for the Government to utilize, but pricing submission is required for offerors. The offeror is not required to include any responses related to the Emerging Markets ex-China strategy in Phase 1, Volume 1 or Phase 2, Volume 2. Furthermore, the Government will only evaluate Volume 2 responses related to the Emerging Markets strategy in accordance with the Request for Proposal Section M. |
| Attachment 2a, Factor 1 | B | Volume 1, Mandatory Requirements Questionnaire | The primary benchmark for our commingled vehicle is the MSCI Emerging Markets IMI (net). Will PBGC accept a strategy managed to the IMI, with performance reporting on the MSCI Emerging Markets Equity Index (net)? | The Government will accept a strategy managed to the IMI; however, the Phase 1 submission must meet the mandatory requirements against the MSCI Emerging Markets Equity Index (Net). |
| Attachment 2a, Factor 1 | J | Volume 1, Mandatory Requirements Questionnaire | Can an Offeror submit one product to evaluate for Emerging Markets Equity and one product for Emerging Markets ex-China Equity? | The Emerging Markets ex-China strategy is not considered a second/redundant product. Offerors are required to submit a Volume 3 - Business/Price Proposal on BOTH an Emerging Markets Equity and Emerging Markets ex-China product. |
However, Volume 1 - Mandatory Requirements Questionnaire and Volume 2 - Technical Proposal should be submitted only as they relate to the Emerging Markets Equity product that is benchmarked against the MSCI Emerging Markets Equity Index.
Per the Request for Proposal Section L.8.4, the only required submission for the optional CLIN for Emerging Markets ex-China is Volume 3 - Business/Price Proposal. Volume 3 is to be submitted in Phase 2. The offeror is not required to include any responses related to the Emerging Markets ex-China strategy in Phase 1, Volume 1 or Phase 2, Volume 2. Furthermore, the Government will only evaluate Volume 2 responses related to the Emerging Markets strategy in accordance with the Request for Proposal Section M. Per RFP Section G.4, the Government may unilaterally exercise the option for the Emerging Markets ex-China service at any time (with written notice to the Contractor). The optional CLIN for Emerging Markets ex-China is optional for the Government to utilize, but pricing submission is required for offerors. The Government does not require a live track record for the optional CLIN but does require a proposed price for an investment strategy.
Attachment 2b F, G and H Volume 1, Phase 1 Rolling_IR_Mandatory _Supporting_ Documents Should the data and formulas be extended to 12/31/2024 (not 9/30/2024), and the information ratio average calculation adjusted to reflect a 7-year range instead of a 10-yr range? Attachment 2b - Phase 1 Rolling IR Mandatory Supporting Documentation has been extended to 12/31/2024. The attachment has been amended (0001) to reflect data as of 12/31/2024 and has been published on SAM.gov. The Government will not accept data points after 12/31/2024. Please utilize the amended excel spreadsheet as supporting documentation for the mandatory requirement, paragraph F.
The data submission is for 7 years of rolling 36-month information ratios (or since inception, whichever is shorter). Given that the first data point is a 3 year IR, the entire data set encompasses 10 years of performance.
| Attachment 6 | all Tables | Volume 2, Attachment 6 | Volume 2, Attachment 3 Technical proposal, D. Performance indicates Table 9 should include "...the composite's stated benchmark (the benchmark used to calculate the information ratio in Volume 1, Mandatories)." However Volume 1 Attachment 2a item F requires MSCI Emerging Markets Equity Index (net). Please confirm Attachment 6 is to be completed with the product's stated benchmark (which may differ from the MSCI Emerging Markets Equity Index (net). | In this instance, the Government requests that Attachment 6 be completed with the MSCI Emerging Markets Equity Index (Net). If an Offeror utilizes another index provider (e.g. S&P, FTSE), performance and characteristic information against the different benchmark would be acceptable. |
| Attachment 2a - Mandtory Requirements Questionnaire | Para D | The proposed strategy must have a GIPS compliant track record of at least five years. | Per the requirement, managers must provide supporting documents with respect to GIPS compliant performance as of December 31, 2024. Given that the GIPS 2024 verification is underway, would it be possible to submit the 2024 returns data by May 28th for the Phase I Preliminary Technical Proposal and subsequently provide the GIPS verification at the earliest possible time (after May 28th). | Per Attachment 2a, paragraph D, the proposed strategy must have a GIPS compliant track record of at least five years. Supporting documentation includes full GIPS disclosures. Independent verification is not required for 2024, however disclosures that adhere to disclosure requirements are acceptable, including a statement describing the return calculation methodology and rules for inclusion of accounts in composites. |
| Attachment_2b_-_Phase_1_Rolling_IR_Mandatory_Supporting_Documentation | Column B | Portfolio (in %) | Do we provide gross and net returns for the portfolio returns being requested in column B. Please clarify. This question also applies to Phase 2 Attachment 6, Table 11 | Attachment 2b - Phase 1 Rolling IR Mandatory Supporting Documentation, column B should reflect gross returns for the proposed strategy. Phase 2 Attachment 6, Table 11 should also reflect gross of fee strategy returns. |
| Attachment 2a | C | Coomingled Fund | Is there a minimum AUM considered as a cut-off, i.e. is there a preference for a commingled fund with a minimum AUM of $500million? Or is AUM not a consideration? | Per Attachment 2a, paragraph E, the offeror must have a minimum of $3 billion in AUM in the proposed strategy. There is no minimum requirement for the commingled investment vehicle. |
| Attachment 2a | C | Coomingled Fund | Is there a preference for a US Mutual Fund, or a Collective Investment Trust (CIT)? | In accordance with the Request for Proposal Attachment 2a, paragraph C, the proposed product must be offered to PBGC in a commingled fund vehicle format acceptable to tax-exempt investors. The Government will not consider mutual funds and/or ETFs for investment. A collective investment trust (CIT) is an acceptable investment vehicle. |
| Attachment 2a | D | GIPS compliant | You have asked for GIPS compliant performance, would you like to see monthly/quarterely/annual/all? | There is no prefered format as long as it is a GIPS compliant presentation of performance. |
| Attachment 2a | F | Information Ratio | Would you like us to submit this excel with our monthly returns in? I noticed your excel spreadsheet is also to June 2024, would you like us to update to 31 December 2024? | Attachment 2b - Phase 1 Rolling IR Mandatory Supporting Documentation should be extended to 12/31/2024. The attachment has been amended (0001) to reflect data as of 12/31/2024 has been published on SAM.gov. The Government will not accept data points after 12/31/2024. Please utilize the amended excel spreadsheet as supporting documentation for the mandatory requirement, paragraph F. |
| Attachment 2a | D&E | GIPS and AUM | Phase one makes it clear that each manager may only submit one strategy. However, other documents have scope for the ‘optional’ inclusion of data on EM ex China strategies. Can you clarify which is correct, and whether the EM ex China strategy requirements are the same. | The Emerging Markets ex-China strategy is not considered a second/redundant product. Offerors are required to submit a Volume 3 - Business/Price Proposal on BOTH an Emerging Markets Equity and Emerging Markets ex-China product. |
However, Volume 1 - Mandatory Requirements Questionnaire and Volume 2 - Technical Proposal should be submitted only as they relate to the Emerging Markets Equity product that is benchmarked against the MSCI Emerging Markets Equity Index.
Per the Request for Proposal Section L.8.4, the only required submission for the optional CLIN for Emerging Markets ex-China is Volume 3 - Business/Price Proposal. Volume 3 is to be submitted in Phase 2. The offeror is not required to include any responses related to the Emerging Markets ex-China strategy in Phase 1, Volume 1 or Phase 2, Volume 2. Furthermore, the Government will only evaluate Volume 2 responses related to the Emerging Markets strategy in accordance with the Request for Proposal Section M. Per RFP Section G.4, the Government may unilaterally exercise the option for the Emerging Markets ex-China service at any time (with written notice to the Contractor). The optional CLIN for Emerging Markets ex-China is optional for the Government to utilize, but pricing submission is required for offerors. The Government does not require a live track record for the optional CLIN but does require a proposed price for an investment strategy.
Pricing for the Emerging Markets strategy should reflect an investment in the commingled fund if there is a difference in price between the commingled vehicle and other investment vehicles (e.g. separately managed accounts).
Pricing Schedule There appears to be options for Active Emerging Markets as well as EM ex China? Given we are to respond with just one product, do you want us to fill this in, purely based on the product we are proposing? There is also the option for segregated pricing, albeit the mandate is for a commingled product – do you still want segregated pricing data? The Emerging Markets ex-China strategy is not considered a second/redundant product. Offerors are required to submit a Volume 3 - Business/Price Proposal on BOTH an Emerging Markets Equity and Emerging Markets ex-China product.
However, Volume 1 - Mandatory Requirements Questionnaire and Volume 2 - Technical Proposal should be submitted only as they relate to the Emerging Markets Equity product that is benchmarked against the MSCI Emerging Markets Equity Index.
Per the Request for Proposal Section L.8.4, the only required submission for the optional CLIN for Emerging Markets ex-China is Volume 3 - Business/Price Proposal. Volume 3 is to be submitted in Phase 2. The offeror is not required to include any responses related to the Emerging Markets ex-China strategy in Phase 1, Volume 1 or Phase 2, Volume 2. Furthermore, the Government will only evaluate Volume 2 responses related to the Emerging Markets strategy in accordance with the Request for Proposal Section M. Per RFP Section G.4, the Government may unilaterally exercise the option for the Emerging Markets ex-China service at any time (with written notice to the Contractor). The optional CLIN for Emerging Markets ex-China is optional for the Government to utilize, but pricing submission is required for offerors. The Government does not require a live track record for the optional CLIN but does require a proposed price for an investment strategy.
Pricing for the Emerging Markets strategy should reflect an investment in the commingled fund if there is a difference in price between the commingled vehicle and other investment vehicles (e.g. separately managed accounts).
| Phase 1 submission | General | What attachments do we need to submit for Phase 1? Attachment 1, 2a and 2b? | In accordance with the Request for Proposal Sections L.1.1, L.6, Table L.6.1, and L.7 the Phase 1, Volume 1 - Preliminary Technical Proposal Mandatory Requirements Questionnaire (Factor 1) Instructions provides the requirements for the Phase 1 submission. Prospective offerors must submit a cover letter, the Mandatory Requirements Questionnaire (Attachment 2a) and Attachment 2b as part of the submission to question F of the questionnaire. Offerors are advised to submit ALL supporting documentation required for each question in Attachment 2a - Mandatory Requirements Questionnaire. | |
| Attachment 2a | Factor 1 - Mandatory Requirements Questionnaire | D | Our GIPS 2024 compliant presentation is not finalized yet - can we submit our 2023 version? | Per Attachment 2a, paragraph D, the proposed strategy must have a GIPS compliant track record of at least five years. Supporting documentation includes full GIPS disclosures. Independent verification is not required for 2024, however disclosures that adhere to disclosure requirements are acceptable, including a statement describing the return calculation methodology and rules for inclusion of accounts in composites. Performance data should be submitted through December 31, 2024. |
| Attachment 1 | Entire excel | How do we fill in attachment 1 - the fee template? How many periods (base period, option period 1…) do we need to propose? | In accordance with the Request for Propposal Section L.8.4, offerors must submit pricing for all periods (base period, 9 option periods, and FAR 52.217-8 6 month extension option). | |
| Section L.7 Phase 1, Volume 1 – Preliminary Technical Proposal Mandatory Requirements Questionnaire (Attachment 2a) | C | commingled fund format | Is PBGC willing to be a seed investor in a to be launched CIT? | With regards to the requirement that the proposed product be offered in a commingled fund format in Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph C, launching a collective investment trust (CIT) would meet the minimum qualifications. Documentation to support the ability to launch a CIT will be required. This can include any one (or combination) of the following: Draft Declaration of Trust, Preliminary Offering Memorandum/Investment Guidelines, Statement of Additional Information (SAI), CIT Fact Sheet (Draft), ERISA Eligibility Representation, Sample Participation Agreement, or Trustee's Letter of Intent or Certification. |
Attachment 2a has been amended (0002) to reflect the edits to this minimum requirement.
| Section L.7 Phase 1, Volume 1 – Preliminary Technical Proposal Mandatory Requirements Questionnaire (Attachment 2a) | C, G, H | commingled fund format; tracking error | Is composite performance acceptable or does PBGC only want performance and data for an established commingled vehicle? | Composite performance is acceptable. |
| Section L.7 Phase 1, Volume 1 – Preliminary Technical Proposal Mandatory Requirements Questionnaire (Attachment 2a) | C | commingled fund format | For a to be launched CIT, is the Declaration of Trust and a draft Fund Description sufficient for Phase 1 for required supporting documentation? | Yes, the Declaratio of Trust and draft Fund Description is sufficient. |
| Attachment 2a – Mandatory Requirements Questionnaire | Item J | An Offeror must only submit ONE PRODUCT for PBGC to evaluate. | Item J states “An Offeror must only submit ONE PRODUCT for PBGC to evaluate”. However, the Solicitation/Contract/Order form also suggests we may submit an ex-China strategy as another option. |
We have 2 products available; a Global Emerging Markets Core Equity strategy, and a Global Emerging Markets ex China strategy.
| May we submit 2 products as 2 submissions, or is each Offeror strictly to submit one product? | In accordance with the Request for Proposal Section L.8.4, the only required submission for the optional CLIN for Emerging Markets ex-China is Volume 3 - Business/Price Proposal. Volume 3 is to be submitted in Phase 2. The offeror is not required to include any responses related to the Emerging Markets ex-China strategy in Phase 1, Volume 1 or Phase 2, Volume 2. Furthermore, the Government will only evaluate Volume 2 responses related to the Emerging Markets strategy in accordance with the Request for Proposal Section M. The optional CLIN for Emerging Markets ex-China is optional for the Government to utilize, but pricing submission is required for Offerors. The Government does not require a live track record for the optional CLIN but does require a proposed price for an investment strategy. | ||||
| C.6.1.2 OPTIONAL - Emerging Markets ex-China Strategy | 1 | OPTIONAL - Emerging Markets ex-China Strategy | While we do not have an Emerging Markets Equity ex China strategy in an ERISA pooled structure, we would be prepared to launch a fund for PBGC. Please confirm if this would be an acceptable option. | The Government does not require a live track record or existing commingled vehicle for the optional CLIN for Emerging Markets ex-China. Per the Request for Proposal Section L.8.4, the only required submission for the optional CLIN for Emerging Markets ex-China is Volume 3 - Business/Price Proposal. Volume 3 is to be submitted in Phase 2. The offeror is not required to include any responses related to the Emerging Markets ex-China strategy in Phase 1, Volume 1 or Phase 2, Volume 2. Furthermore, the Government will only evaluate Volume 2 responses related to the Emerging Markets strategy in accordance with the Request for Proposal Section M. The optional CLIN for Emerging Markets ex-China is optional for the Government to utilize, but pricing submission is required for offerors. The Government does not require a live track record for the optional CLIN but does require a proposed price for an investment strategy. The only item that will be evaluated regarding the Emerging Markets ex-China strategy is price. | |
| Attachement 2b- Phase 1-Rolling IR_Mandatory Supporting Documentation | NA | NA | Please clarify whether the TE request is for ex ante or ex post TE. | Unless stated otherwise, tracking error should be ex-post tracking error. | |
| Attachment 2a – Mandatory Requirements Questionnaire | Item H | The proposed product’s tracking error can not be below 2.5% over 10 |
years or since inception (whichever is shorter) as of December 31, 2024. The IR and TE numbers for our proposed product satisfy the minimum criteria on an average basis over the period and have spent the majority of time above the minimum. However, there have been isolated periods when they have dipped below the minimum levels. Please confirm that this is acceptable. As stated in the Request for Proposal Attachment 2a, paragraph F, the proposed product's rolling 36-month information ratio over the past seven years, or since inception, through 12/31/24 must be at least 0.30. This minimum IR is meant to be an average of the rolling 36-month IRs over the time period. There can be periods where the 36-month IR is below 0.30 as long as the average over the required time period (either seven years or since inception) is 0.30 or higher. Attachment 2b - Phase 1 Rolling IR Mandatory Supporting Document is an excel spreadsheet that contains the required format and formulas to calculate the average of the rolling information ratios, which will be updated to reflect dates through December 31, 2024.
As it relates to Attachment 2a, paragraphs G and H, the tracking error over the entire period submitted (ten years or since inception, whichever is shorter) needs to be between 2.5% and 9.0% as of 12/31/24. Isolated periods within that timeframe that are outside of the range are acceptable as long as the total tracking error is within that range for the submitted time period.
| Zip file; Cover Letter which states Phase 1, Volume 1 | Notice to Offerors | For Phase 1 submission, are the only two documents required the Mandatory Requirements Questionnaire and Rolling IR Mandatory Supporting Document? What about the Pricing Schedule and Organizational Conflict of Interest? These do no state Phase 1 or Phase 2. | In accordance with the Request for Proposal Sections L.1.1, L.6, Table L.6.1, and L.8.4 the Phase 2, Volume 3 - Business/Price Proposal (Factor 5) instructions provides the requirements for the pricing schedule and Organizational Conflict of Interest. | |
| Sol_16PBGC25R0052 | Are we required to submit the Sol_16PBGC25R0052 (Solicitation Order), which states: OFFEROR TO COMPLETE BLOCKS 12, 17, 23, 24, & 30? If so, what phase? | No. | ||
| Pricing Schedule | Paragraph starting on row 273 | "Note: As identified…" | The pricing schedule provides a paragraph at the bottom of the price sheet. Please explain in greater detail what the last two sentences are looking for. | Attachment 1 and Request for Proposal Section M.8 outline how Volume 3 - Price Proposal will be evaluated. The Government will assume an investment of $375 million in the proposed Emerging Markets strategy and an investment of $50 million in an optional Emerging Markets ex-China strategy when evaluating price. However, all breakpoints (if any) should be listed in the pricing schedule, even if they are below or above those AUMs. Please note that while the Emerging Markets ex-China strategy is listed as an "optional" CLIN, submission of pricing is required. |
| Pricing Schedule | Paragraph starting on row 273 | "Note: As identified…" | Are we required to submit a fee schedule for EM ex-China? | Yes, per the Request for Proposal Section L.8.4, submission of Volume 3 - Business/Price Proposal for the optional CLIN for Emerging Markets ex-China is required. Volume 3 is to be submitted in Phase 2. The Offeror is not required to include any responses related to the Emerging Markets ex-China strategy in Phase 1, Volume 1 or Phase 2, Volume 2. Furthermore, the Government will only evaluate Volume 2 responses related to the Emerging Markets strategy in accordance with the Request for Proposal Section M. The optional CLIN for Emerging Markets ex-China is optional for the Government to utilize, but pricing submission is required for Offerors. The Government does not require a live track record for the optional CLIN but does require a proposed price for an investment strategy. |
| 2a - Phase 1 - Mandatory Requirements | I. | The Offeror must act as an ERISA fiduciary under this contract | Would a ’40 Act mutual fund that is eligible to ERISA investors but not managed in accordance with ERISA be an acceptable investment vehicle? | No, in accordance with the Request for Proposal Attachment 2a - Phase 1 Mandatory Requirements Questionnaire, paragraph C, the proposed product must be offered to PBGC in a commingled fund vehicle format acceptable to tax-exempt investors. |
| 2a - Phase 1 - Mandatory Requirements | I. | The Offeror must act as an ERISA fiduciary under this contract | Is either of the following acceptable, a commingled Collective Trust Fund (CIT) or a Group Trust Fund where in either case manager is an ERISA Fiduciary? | A collective trust fund (CIT) is acceptable. |
| 2a - Phase 1 - Mandatory Requirements | G. | The proposed product’s tracking error can not exceed 9.0% over 10 years or since inception (whichever is shorter) as of December 31, 2024. SUPPORTING DOCUMENTATION REQUIRED: List the proposed strategy’s 10 year tracking error (or since inception) as of December 31, 2024. | What is the preferred format to display the Offeror's tracking error for the past 10 years? Demonstrate work in Excel? | There is no preferred format. Offerors may state the tracking error over the submitted time period or provide it in a separate attachment, as long as it is clearly labeled. |
| Section L | 1.1 | Please confirm the following Phase 1 documents required by the 28th May 5pm EST deadline as follows: |
1. 2a Mandatory Requirement Qualifications and supporting docs
2. 2b Rolling IR supporting xls Is a preliminary version of Attachment 3 Technical Approach Questionnaire also due as part of Phase 1?
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