Attachment 11 - PBGC Responses to Industry Feedback - OFFICIAL SOLICITATION.xlsx
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- Attached to
- Fixed Income Investment Services (Amendment 2)
- Solicitation number
- 16PBGC25R0062
- Issued by
-
Pension Benefit Guaranty Corporation
About this file
This document is a comprehensive Q&A spreadsheet for a Pension Benefit Guaranty Corporation (PBGC) Fixed Income Investment Services solicitation (16PBGC25R0062). The solicitation seeks investment management services for fixed income strategies, with a focus on Core and Core Plus Fixed Income strategies benchmarked to the Bloomberg US Aggregate Index. Incumbent contractors include Allspring Global Investments, PIMCO, PGIM, Wellington Management, Goldman Sachs Asset Management, and MFS Investment Management.
Key requirements include: firms must have at least $500 billion in total Assets Under Management (AUM) and manage at least $1 billion in the proposed fixed income product as of 6/30/2025. Offerors can submit up to four product forms, with at least two qualifying products. The proposal submission deadline is December 19, 2025, at 9 AM, with the solicitation structured in multiple phases. Evaluators will prioritize Factor 4 and consider non-price factors significantly more important than price. The solicitation encourages vendors to submit their best product, whether Core or Core Plus, and specific investment guidelines will be negotiated post-award.
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Questions Fixed Income Investment Services Industry Questions and PBGC Responses
16PBGC25R0062
| # | TOPIC | ATTACHMENT TITLE | PAGE & SECTION # | QUESTION OR RECOMMENDATION | GOVERNMENT RESPONSE |
| 1 | Minimum AUM Threshold / Response to Questions | Attachment 6: Solicitation Phase 1 Forms (Final) | Page 2 / Item C | Per the RFP proposal, PBGC has set minimum firm-level AUM requirements in the RFP. Can PBGC confirm whether existing managers under current PBGC mandates may submit proposals for strategies where they do not meet the stated firm-level AUM threshold, but DO meet the strategy criteria for at least 2 of the strategies? | The same qualification requirements apply to both incumbents and non-incumbents. |
| 2 | Response Due Date | N/A | N/A | Would you please confirm if the date of submission is 12/19 “Date Offers Due” or 1/3/26 “Inactive Date”? Attachment 1 refers to the “solicitation closing date”. | All necessary materials to be evaluated under Phase 1 are due by the date listed in the announcement, which is currently Friday Dec 19th, 2025 at 9 AM. The Inactive Date is merely for SAM archival purposes. |
| 3 | Product Qualifications | Attachment 6: Solicitation Phase 1 Forms | Pg 5. A. | We have an Intermediate Credit broad composite that includes portfolios that are actively managed to either the Bloomberg Intermediate Corporate or Bloomberg Intermediate Credit indices as their benchmark. The primary benchmark for this composite is an asset-weighted benchmark, which is a blend of the Intermediate Corporate and Intermediate Credit indices based of the weights of the underlying accounts included in the composite. We would consider the asset-weighted benchmark of this broad composite to be a blended benchmark but wanted to make sure that this meets the PBGC’s definition of a blended benchmark. | This meets the PBGC definition of a blended benchmark. |
| 4 | Product Qualifications | Attachment 6: Solicitation Phase 1 Forms | Pg 5. F. | If the broad composite is acceptable, would PBGC permit using either the Intermediate Corporate or the Intermediate Credit Index for characteristic related questions/data in phase 2? The asset weighted benchmark is meant for performance purposes only so that the benchmark relative returns are not skewed in any given direction by selecting only one of these indices since the broad composite includes portfolios actively managed against either. | PBGC has amended the solicitation to clarify that AUM for Credit strategies managed against any of the stated benchmarks may be combined to meet the requirement in Part B of the Product Qualifications Form. However, a firm must choose a product to propose and present its performance history and characteristics to satisfy product specific requirements as state in the solicitation. |
| 5 | Product Qualifications | Attachment 6: Solicitation Phase 1 Forms | Pg 5. A. | Does the PBGC have a preference for using a credit or corporate benchmark for its credit search? And will you consider a manager who proposes a product versus a credit benchmark if the PBGC decides to use a corporate benchmark, or vice versa? | PBGC does not have a preference. PBGC will only consider proposed products for inclusion within the scope of an ensuing contract. The scope of the contract is product specific and not benchmark specific. |
| 8 | Overall Product Proposal | Attachment 3: Statement of Work | Page 2, Section 3 | Would you consider fixed income investments that earn superior returns, which exceed the respective portfolio benchmarks and are consistent with the risk paramaters in the Investment Policy Statement, that are managed via a systematic investment process? | PBGC is not looking for systematic strategies in this RFP. |
| 10 | Data Template | Attachment 8: Data Table Template | Tab "Table 12" | In Row 4, Column B, where it is titled "Date (Quarter End)", are we expected to submit data as of June 30, 2025? | Yes. Please see revised table. Data should represent year-to-date returns as of 6/30/2025. |
| 11 | Data Input | Attachment 8: Data Table Template | Tab "Table 12" | For the rows labeled "High", "Low" & "Difference", are we expected to provide the highest and lowest return for each time period and input the difference? | Yes. |
| 12 | Exemption to Total AUM Requirement | Attachment 6: Solicitation Phase 1 Forms (Final) | Pages 1 & 2 | Offeror Qualifications Form, Section C states: |
The firm has at least $500,000,000,000.00 in Assets Under Management (AUM) as a fiduciary. *(Provide the Firm Annual Report or other published documentation confirming firm level AUM as of 6/30/2025).
Under Product Qualifications Form – Core Fixed Income, Section B states:
The firm must manage at least $1,000,000,000.00 USD as of 06/30/2025 in the proposed Core Fixed Income product suitable for a tax-exempt sponsor (AUM for Core and Core Plus strategies may be combined for this purpose). Only fully discretionary assets shall be included in this total. Advisory assets shall not be included. * Provide GIPS performance table(s) or other document(s) that can evidence this.
| As a smaller, diverse investment firm ($11 Billion in AUM), we obviously do not meet the qualifications for total AUM, but easily meet the qualifications for the product. Is it possible to get an exemption to the total firm AUM qualification? | There is no exemption from the total firm AUM requirement. A firm must meet both firm and product requirements to qualify. | |||
| 13 | Incumbents and Invitation to Rebid | N/A | N/A |
Are there any current managers of fixed income, and if so, will they be invited to rebid?
| Yes, the incumbent contractors are Allspring Global Investments, PIMCO, PGIM, Wellington Management, Goldman Sachs Asset Management and MFS Investment Management. All qualified firms are invited to participate. | ||||
| 14 | calculate the average of all rolling 60-month Information Ratios | Attachment 6: Question F | Page 3 | We have a question about how the information ratio should be calculated. |
For attachment 6, question F, which states: “The firm must calculate the average of all rolling 60-month information ratios for the past 10 years or since product inception, whichever is shorter, through 06/30/2025,” should a fund with an inception date of June 1, 2013 calculate its first rolling period as July 2015 to June 2020, or as June 2013 to May 2018?
Thank you for your guidance.
| If the inception date is June 1, 2013, this product would have more than 10 years of performance as of 6/30/2025. As such, the starting rolling 60-month period would be July 1, 2015 through June 30, 2020. | |||||
| 15 | Attachment 6 | Attachment 6: Solicitation Phase 1 Forms | Page 3 | The Final version of the PBGC's Solicitation contemplates the consideration of both Core amd Core Plus Fixed Income Strategies managed against the Bloomberg US Aggregate Index. The instructions state that managers may only propose 1 strategy per category. For managers that offer both Core and Core Plus strategies that meet the PBGC's requirements, does the PBGC have a preference between Core and Core Plus or should we submit for both? | PBGC encourages vendors to submit their best product managed against the Bloomberg US Aggregate Index whether that is a Core or a Core Plus strategy. |
| 16 | Attachment 6 | Attachment 6: Solicitation Phase 1 Forms | Page 3 | For Core Plus portfolios, does the PBGC have any preferred "Plus" sectors or limits on extended sectors that we should be mindful of? | PBGC allows 'plus' sectors in Core Plus portfolios. Specific limits around these sectors are negotiated in gudielines post award. |
| 17 | Product AUM | Attachment 6- Solicitation Phase 1 Form | Page 3- Product Qualifications Form- Item B | Within Attachment 6, you state that the firm must manage at least $1,000,000,000.00 USD as of 06/30/2025 in the proposed product. Could we aggregate our GFI products to meet this minimum? | AUM for fixed income products can be aggregated only in the manner described in Part B for each product. |
| 18 | Federal Contracting Requirements | Attachment 5 – Clauses and Provisions (Final) | N/A | Can you please provide guidance on the federal contracting requirements that apply to investment management contractors, specifically regarding employment practices and compensation standards, required financial documentation (including whether parent-company financials must be submitted), and audit obligations or review processes that contractors must comply with? | Applicable terms and conditions are contained within the solicitation. Applicable labor laws are incorporated by clauses and provisions beginning with 52.222. There are no minimum employee compensation requirements associated with this work. Post-award documentation requirements and review processes are addressed in Attachment 3 - SOW. |
| 19 | Data Table Templates | Attachment 6 Solicitation Phase 1 Forms | Pages 3, 5; Product Qualification Form - Core and Credit Fixed Income | Item F indicates to complete Table 1 in Attachment 8 to enable PBGC to assess mandatory requirements. Are any additional Tables within Attachment 8 required for Phase 1? We did not see any other mentions of Attachment 8 and Tables 2-15 of that file within the listed Phase 1 materials. | Only Table 1 within Attachment 8 is needed as part of Phase 1 submissions. |
| 21 | Cover Letter | Attachment 1 - Instruction to Offerors | P. 4 / Section 8.a | Should we submit one cover letter for Phase 1 (we will be submitting four strategies) or do we submit a separate cover letter for each product submission? | Only one (1) cover letter is required per volume. Offeror Qualifications is a single volume regardless of the quantity of products proposed. See Attachment 1, Table 1 and Section 8.a. |
| 22 | Mercer NDA | Attachment 9 - Mercer NDA Form | P. 1 | Do we need to submit the Mercer NDA request in Phase 1 or can it be submitted in Phase 2 or 3? | Yes, the Mercer NDA requirement applies to Phase 1 if your firm seeks to protect any proposal information from unauthorized disclosure and marks any portion of the proposal as "confidential" or "proprietary." If a proposal contains such markings but no corresponding NDA has been received by Mercer by the proposal due date and time, PBGC may reject the proposal. See Attachment 1, Section 7, and Attachment 2, Section 1.g., for more information. |
| 23 | Emerging Markets Debt | Attachment 3 - Statement of Work | P. 2 / Section 3 | We will be submitting our EMD HC strategy in our proposal. We also manage an EMD Blend strategy. If we are selected, could PBGC decide to invest in the EMD Blend strategy, or just into the strategy that was submitted (EMD HC)? | PBGC will only consider proposed products for inclusion within the scope of an ensuing contract. The scope of the contract is product specific and not benchmark specific. |
| 24 | Global Fixed Income | Attachment 3 - Statement of Work | P. 2 / Section 3 | We will be submitting our Global Bond strategy. We often customize these mandates for client-specific objectives and constraints. Can the PBGC elect to implement a more customized version of a strategy if we are selected? | Yes, PBGC negotiates custom guidelines for each product in the post award phase. |
| 25 | Offeror Qualifications Form | Attachment 6 - Solicitation Phase 1 | P. 2 / Section D | We have an existing NDA in place with PBGC from a prior RFP, under which we submitted our financial statements. Would PBGC be willing to sign an updated NDA, or alternatively, does the existing NDA suffice? | The NDA must be between the offeror and Mercer, and must cite to this specific solicitation number. PBGC is not a signatory to the NDA. We recommend that offerors utilize the provided template, but offerors are free to negotiate additional details with Mercer as desired. |
| 26 | Investment Guidelines | Attachment 3 - Statement of Work | Page 2, Part I , Section 3 - Scope of Work |
and Page 4, Part II, Section 2 - Investment Requirements We understand that specific portfolio investment guidelines are to be negotiated and established after contract award. We ask if there is any detail that can be shared on the following to help us identify to ideal portfolio structure to meet PBGC's needs:
- Can the portfolios hold non-benchmark allocations (example: securitized and investment grade emerging markets)?
- Is there specific allowance for high yield and/or split rated securities?
| - Will the portfolios have strict duration guidelines? | Yes, non-benchmark allocations are generally permitted. Specific sector limits and duration bands are negotiated post award in an effort to calibrate a strategy's ability to meet its performance target with PBGC's risk tolerance. | ||||
| 27 | Data Template | Attachment 8 - Data Templates | Table 7 - Credit Quality | Table 7 asks for Average Quality (Moody’s). Is that asking for just Moody’s ratings, or to identify it in the Moody’s nomenclature (Aaa instead of AAA+)? If the former, if a security doesn’t have a Moody’s rating, can we use S&P and/or Fitch? Assuming PBGC wants to use multiple rating agencies and for the manager to list the average rating in Moody’s nomenclature, then what method should be used to calculate the average rating? Highest of three, middle of three, lowest of three? Guidance here is appreciated to ensure the most accurate data is provided. | |
| For individual securities the following rules apply: | |||||
| i. | Credit ratings for issues/issuers shall be deemed to be the middle rating of the NRSROs long term ratings. | ||||
| ii. | If only 2 of the 3 credit ratings agencies rate the issue/issuer, then the higher of the 2 ratings shall apply; and if rated by only one rating agency, that rating shall apply. |
Moody's nomenclature should be used to show the average rating in Table 7. Note that this is meant to display the average rating of the proposed product for consistency purposes.
| 28 | Data Template | Attachment 8 - Data Templates | Table 8 - Holdings Breakdown | Does Treasuries include issuance from all countries, or just US? i.e., do German bunds go in the Treasuries column? | German Bunds would go in the Treasury column. |
| 29 | Data Template | Attachment 8 - Data Templates | Table 11 - Performance Data | Table 11 – What fee structure would PBGC recommend for managers to use for the net performance data, given that anticipated mandate size ranging from $250 million to $3.0 billion could result in using fees at either the highest or lowest range? | For the purpose of this table, vendors should follow GIPS performance representation methodology. |
| 30 | Data Template | Attachment 8 - Data Templates | Table 14 - Strategy Information | For the subject product, can we use the umbrella strategy? For example, our Global Multi-Sector Bond composite will just have our flagship USD-hedged strategies (mutual fund and Trust), while a large majority of our assets are in other GMS composites (Short Duration GMS, International GMS). Including all accounts/assets under our umbrella strategy is a more accurate representation of the information requested. | For each proposed product, AUM can be combined only as stipulated in Part B of the Product Qualifications Form. |
| 31 | Technical Proposal | Attachment 7 - Solicitation Phase 2 Forms | Page10 - Product Attributes | Phase 2 Solicitation document states: "Although there are no page or word limits associated with this form, PBGC estimates that the responses to Section A should not exceed 8,000." We would like to confirm that this estimate is per strategy proposed, not total across all mandates. |
| Additionally - Given the complexity of the investment products in scope for these proposals, and the sophistication and detail involved in the questions, we feel this might be a conservative/constricting estimate. Will PBGC score proposals that materially exceed 8,000 words negatively, if the information provided is necessary and appropriate for a full, comprehensive response? Would PBGC prefer a manager to complete Attachment 7 as concise as possible taking the 8,000 word estimate into consideration, and provide supplemental information in an Appendix? | PBGC will not penalize any offeror that exceeds a suggested or estimated limit. We encourage submissions that provide concise yet detailed responses, but offerors may exceed the estimated total without use of an appendix. | ||||
| 32 | General Question on Mandates | Attachment 6 - Solicitation Phase 1 Forms | Page 1 - Instructions | Phase 1 Solicitation document states: Although offerors may submit up to four (4) product forms, only two (2) products must qualify for the proposal to be acceptable (see Attachment 2, Section 2.b.). By completing the certification required under Attachment 1 – Instructions to Offerors, Section 8.a.x., the offeror verifies that, to the best of its knowledge and belief, its responses to the below prompts are accurate and that it meets the Government’s minimum requirement of at least two (2) qualifying products. |
| If PBGC will consider proposals for strategies that do not meet/exceed all requirements as defined in the solicitation document, secondary to a manager’s primary proposal - can PBGC offer guidance on the items most important and will be scored higher? It would be helpful if PBGC could rank by importance: Meeting the IR requirement, Product AUM, PM/product tenure and track record. In these secondary proposals, can a manager highlight the current Portfolio Manager’s rolling IR vs a previous Portfolio Manage? We have products that are compelling, and that meet some of the stated requirements (and close to others) that we would consider proposing should it be beneficial to PBGC. | PBGC will follow the evaluation methodology outlined in the solicitation for all firm and product specific criteria. In accordance with Attachment 2, Section 1.c., PBGC considers Factor 4 to be the most important, and the combined non-price factors to be significantly more important than price. PBGC encourages vendors to submit proposals for all products. While only 2 of 4 products must qualify for the proposal to be acceptable, PBGC will evaluate all products submitted. | |||||
| 33 | Product Qualifications | Attachment 6: Solicitation Phase 1 Forms | Page 5, Section A | For the Bloomberg Credit Index, are you referring to US or Global? | This index refers to US. | |
| 34 | Product Qualifications | Attachment 6: Solicitation Phase 1 Forms | Page 12, Section B | Is the $1,000,000,000 minimum AUM required to be as of 6/30/25? Our strategy would qualify as of today's date but not as of 6/30/25. | PBGC requires all data submitted to be as of 6/30/2025. | |
| 35 | Cover Letter | Attachment 1: Instructions to Offerors | Page 4, Section 8,a,vii | Could you please clarify what you mean by a statement specifying the extent of agreement with all terms, conditions, and provisions included in the solicitation? Are comments allowed? | Offerors must identify any terms or conditions that they will not or may not agree within the scope of the solicitation and ensuing contract. Yes, offerors should explain any exceptions to the extent necessary for PBGC to understand the nature of the objection and any conditions of the offeror. Also see Attachment 10, #46. | |
| 36 | Product Qualification | Attachment 6: Solicitation Phase 1 Forms | Page 9, Section B | If two Emerging Market Debt composites are managed by the same team under the same investment philosophy and process, with meaningful overlap in holdings, but one composite is benchmarked and the other is not, can these be combined to meet the minimum AUM threshold required for the product? | No, this is not permissible. | |
| 37 | Table of Contents | Attachment 1: Instructions to Offerors | Page 3 / Section 8.a.v | Can you give more details into which amendments this is referring to? As well as how this compares to point vii in the Table of contents as well. | PBGC will amend the solicitation posting in SAM to provide updates and/or revisions. The acknowledgement helps to ensure that offerors are responding to, and PBGC is evaluating responses based upon, the most recent information. Section 8.a.vii. asks offerors to specify any terms or conditions (under the final amended solicitation) that they do not agree to. | |
| 38 | Cover Letter | Attachment 1: Instructions to Offerors | Page 4 / Section 8.a.vii | Does a qualification around the terms, conditions, and provsions in this solicitation exclude our proposal from advancing through Phase 1 to Phase 2? Or does this statement require asset managers to affirmatively agree to all terms, conditions, and provisions? | Offeror exceptions to the solicitation will not cause PBGC to reject a proposal in Phase 1, although it may impact an offeror's ratings in Phase 2. PBGC has revised provision 52.212-1 at paragraph (b)(11) to clarify this point. | |
| 39 | Offeror Qualifications Form | Attachment 6: Solicitation Phase 1 Forms | Page 2 / Section A | The size of our ADV is too large to send through email. We intend to provide our submission via email. Can we provide a link to our form ADV on the SEC website? | Yes, a link would be acceptable. | |
| 40 | Offeror Qualifications Form | Attachment 6: Solicitation Phase 1 Forms | Page 2 / Section C | Can an unaudited publicly published quarterly earnings report satisfy part C in the offer qualifications if a audited annual report is provided in part D? | Yes, as long as the data is provided as of 6/30/2025. | |
| 41 | Offeror Qualifications Form | Attachment 6: Solicitation Phase 1 Forms | Page 2 / Section D | Can a year end 2024 annual report satisfy part D? | Yes, that would be acceptable, provided the most recent audited financials are contained in the report. | |
| 42 | Product Qualifications Form | Attachment 6: Solicitation Phase 1 Forms | Page 3 / Section F | Does the calculation methodology need to be shown for IR returns? | No, the methodology does not have to be shown. The PBGC outlined methodology needs to be utilized for this calculation. PBGC will utilize monthly returns to verify calculations. | |
| 43 | Monthly Returns | Attachment 8: Data Table Templates | Table 1 | Column D (Geometric Excess Return) is in a general number format - are we permitted to convert this to percentage format? | Yes, returns should be presented as percentage points, rounded to two decimal points. | |
| 44 | Monthly Returns | Attachment 8: Data Table Templates | Table 1 | In column H (IR for Rolling 60 month period) how many decimal points should we be rounding the IR to? | IR should be rounded to two decimal points. |
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