20261016 FDIC Legal Division RFI for Registered Agent Services.pdf

Submission of any information in response to this RFI is voluntary. However, the FDIC may make procurement decisions based solely on responses to this RFI. Responding to this RFI may be the only opportunity a firm has to be considered for this requirement.

Federal Deposit Insurance Corporation

Request for Information:

Nationwide Registered Agent and Process Agent Services

RFI Number: FDIC-LEGAL-2026-004 Issued: October 16, 2026 Questions Due: Thursday, October 22, 2026, by 3:00 p.m. Eastern Time Responses Due: Thursday, October 29, 2026, by 3:00 p.m. Eastern Time Potential Service Commencement: As soon as possible

Submit questions and responses by email to all three contacts:

• Charles McCarthy cmccarthy@fdic.gov

• Michael Pangia mpangia@fdic.gov

• Vicky Bhandari pbhandari@fdic.gov

1.0 PURPOSE AND BACKGROUND

The Federal Deposit Insurance Corporation (FDIC) is a congressionally chartered government corporation and federal agency established to maintain stability and public confidence in the nation’s financial system. Its responsibilities include insuring deposits, examining and supervising financial institutions, and managing receiverships of failed insured depository institutions.

This RFI seeks to identify vendors capable of providing nationwide registered agent and service-of-process receipt and routing services. The FDIC seeks a single, coordinated solution covering all 50 states, the District of Columbia, and applicable U.S. territories, with a secure, unified web-based platform for digitizing, delivering, tracking, and storing served documents. This RFI requests information about vendors’ jurisdictional coverage, operational capabilities, information security, transition support, willingness to accept FDIC contract terms, and estimated pricing.

Responses will inform the FDIC’s assessment of available providers and potential alternatives to its current service arrangement, with potential service commencement in January 2027.

The anticipated solution would provide:

1. Registered agent and service-of-process coverage in all U.S. jurisdictions identified at

Agents for Service of Process | FDIC.gov, including the District of Columbia, Guam, U.S. Virgin Islands, and Puerto Rico.

2. Reliable receipt, identification, digitization, and delivery of documents served on the FDIC.

3. A secure, unified, web-based platform for document access, routing, acknowledgment, reporting, and retention.

4. An orderly transition from the incumbent provider without a gap in coverage or disruption to document delivery. Ideally, this would include preparing and filing a change of agent document in each state and paying any associated state fees for that action.

mailto:cmccarthy@fdic.gov mailto:mpangia@fdic.gov mailto:pbhandari@fdic.gov https://www.fdic.gov/about https://www.fdic.gov/about/agents-service-process

2.0 FDIC CURRENT STATE

The FDIC currently contracts with CT Corporation System to serve as its process agent for service of process in jurisdictions where insured depository institutions are located. The FDIC anticipates continuing to use a single accountable provider offering coordinated coverage across all 50 states, the District of Columbia, and applicable U.S. territories. The FDIC receives documents from numerous jurisdictions and may receive multiple documents on a given day. Historical volumes received through CT Corporation were:

Calendar Year 2025: 513 documents January to August 2026 398 documents

These figures are provided for planning purposes only. They are not guaranteed minimum or maximum volumes. The incumbent provides a secure, web-based portal that allows FDIC personnel to review, search, acknowledge, report on, and store served documents. The portal provides a centralized record and an audit trail of document receipt and acknowledgment.

Documents served on the FDIC may identify the FDIC by different names or in different capacities, including: FDIC, Federal Deposit Insurance Corporation, Federal Deposit Insurance Corp., FDIC-R, FDIC as Receiver for [Bank Name], [Bank Name] through FDIC-R, and FDIC como síndico de [Bank Name]. Documents received in Puerto Rico are often in Spanish. Furthermore, the FDIC’s status as a congressionally chartered corporation, rather than an entity incorporated in a single state, has historically required time-intensive, jurisdiction-specific coordination when establishing or changing agent appointments.

3.0 REQUESTED INFORMATION

Organize responses using the section numbers below. Provide specific descriptions of existing capabilities rather than general marketing statements. Identify any capability that would require customization, a third-party service, or development before implementation.

Where applicable, respondents should clearly distinguish among:

• Capabilities currently available;

• Capabilities available through subcontractors or other third parties;

• Capabilities requiring future development; and

• Requirements or jurisdictions the respondent cannot support.

Responses should not exceed 10 pages.

3.1 Company Information and Relevant Experience

3.1.1 Company identity. Provide the company’s legal name, headquarters address, website, jurisdiction of formation, and relevant parent or affiliated companies. Describe whether the company is U.S.-owned or foreign-owned.

3.1.2 Response contacts. Identify the primary and alternate contacts for this RFI, including name, title, telephone number, and email address.

3.1.3 SAM registration. State whether the company has an active SAM.gov registration. If registered, provide its Unique Entity ID. If not registered, confirm whether the company is willing and able to complete a SAM.gov registration as required by the FDIC.

3.1.4 Government experience. Identify current or recent federal, state, or other governmental clients for which the company provides registered agent or service-of-process services. Describe the scope, jurisdictions covered, approximate document volume, and period of performance.

3.1.5 Comparable institutional experience. Provide representative examples of large institutional clients, including Fortune 100 or Fortune 500 companies where appropriate, with nationwide coverage or comparable organizational complexity.

3.2 Technical and Operational Capabilities

3.2.1 Jurisdictional Coverage and Subcontracting

Provide a jurisdiction coverage list/matrix. For each required jurisdiction, identify:

• The legal name of the entity providing local service;

• The physical address at which service would be accepted;

• Whether service is provided directly, through an affiliate, or through a subcontractor;

• Normal service acceptance hours;

• For Puerto Rico, whether Spanish-language documents can be received and processed;

• For affiliate or subcontractor arrangements, explain how the respondent oversees performance, protects documents and information, manages personnel or address changes, and maintains uninterrupted delivery through one unified platform.

3.2.2 Document Intake, Identification, and Routing. Describe the process from physical receipt through electronic delivery, including:

• Recording the date, time, time zone, location, and method of receipt;

• Scanning all pages and associated materials, including envelopes when relevant;

• Checking scan completeness, legibility, and correct document association;

• Identifying and handling duplicate, incomplete, misdirected, or potentially misidentified documents;

• Routing documents to designated FDIC personnel; and

• Resolving exceptions without unnecessary delay.

• Explain how the company handles FDIC name variations and distinguishes the FDIC in its corporate capacity from the FDIC as receiver for particular institutions.

• Explain how uncertain recipient identification would be escalated for FDIC direction, including circumstances that could result in delayed acceptance, rejection, or return of documents.

3.2.3 Delivery Speed. Provide the company’s standard and proposed service levels for the FDIC, including:

• Time from physical receipt to electronic availability;

• Treatment of documents received near closing, after hours, on weekends, or on holidays.

• State whether each timeframe would be a contractual commitment or operating target.

Explain how performance is measured and reported.

3.2.4 Web-Based Platform and Records Management. Describe the proposed platform and its ability to support:

• Multiple FDIC users and role-based permissions;

• A consolidated view across jurisdictions;

• Search by recipient, receivership, jurisdiction, receipt date, case identifier, document type, and acknowledgment status, as available;

• Configurable routing and notification groups;

• Downloading individual documents and exporting records in bulk;

• Operational reports and service-level reporting; and

• Audit records showing document receipt, upload, notification, access, and acknowledgment.

3.2.5 Information Security. Describe security controls applicable to the service, platform, personnel, and subcontractors, including:

• Cybersecurity certifications and accreditations;

• Document hosting locations/countries;

• Multifactor authentication, role-based access, and account administration;

• Separation of client information;

• Personnel screening and security training.

3.2.6 Business Continuity and Support. Describe:

• Continuity measures for staffing shortages, disasters, office closures, and subcontractor failures;

• Backup and disaster recovery capabilities;

• Methods for continuing document delivery during platform or communications outages; and

• Customer support hours.

3.2.7 Transition and Implementation. Discuss and recommend a proposed transition approach that could support service commencement in January 2027. Identify the earliest feasible start date and any constraints. Address:

• Configuration and testing of routing, notifications, user access, and escalation;

• FDIC user training;

• Risks and dependencies.

• Experience establishing or changing appointments for federally chartered or congressionally chartered entities without a state of incorporation.

3.3 Consent to FDIC Contract Terms. The FDIC is not subject to the Federal Acquisition Regulation (FAR). If your company is selected for this work, the FDIC would require the use of its standard/form contract documents. The resulting contract would consist of:

• FDIC Legal Support Services Deskbook, available here: Legal Support Services Deskbook

• FDIC’s Representations and Certifications for Legal Contractors, available here: 5200/01, Representations and Certifications for Legal Contractors

• Legal Support Services Agreement (template attached)

In your RFI response, confirm that your company has reviewed the FDIC’s contractual requirements (set forth in the above-listed documents) and is prepared to agree to them if selected.

3.4 Pricing

3.4.1 Price Estimate. Provide nonbinding pricing estimates, based on an all-inclusive annual fixed price model, for a potential three-year agreement covering calendar years 2027, 2028, and 2029. The assumed duration is for estimating purposes only and does not commit the FDIC to a particular contract term. Specify any services that are excluded or separately priced.

3.4.2 One-Time and Transition Charges (if separately priced). Separately estimate any one-time transition charge, including preparation and submission of appointment or change-of-agent documents; filing fees and other pass-through expenses; and additional work associated with the FDIC’s federal corporate status.

Note: The FDIC is a congressionally chartered corporation without a single state of incorporation. Historically, this means that even simple changes of agent filings often require multiple back-and-forth engagements with the various state-level secretary of state offices.

3.5 Additional Information

Please feel free to include in this section of your RFI response any additional information you wish the FDIC to consider. In this optional section of the RFI response, the FDIC welcomes your company to provide a short description of the competitive advantage your company has over your nearest competitor(s).

4.0 SUBMISSION INSTRUCTIONS AND ADMINISTRATIVE INFORMATION

• Submit the narrative response as a searchable PDF or Word document of no more than 10 pages, organized according to Section 3.0.

• Questions about this RFI are due by October 22, 2026, by 3:00 p.m. ET.

• Vendor responses to this RFI are due by October 29, 2026, by 3:00 p.m. ET.

• Questions and responses must be submitted via email to FDIC attorneys: Charles McCarthy

(cmccarthy@fdic.gov), Michael Pangia (mpangia@fdic.gov), and Vicky Bhandari (pbhandari@FDIC.gov).

The FDIC may request clarification, conduct demonstrations, or hold discussions with one or more respondents. The FDIC will not reimburse costs incurred in preparing a response, participating in discussions, or providing demonstrations.

We look forward to receiving your response.

https://www.fdic.gov/about/doing-business/legal-support-services-deskbook/lssprint.pdf https://www.fdic.gov/formsdocuments/f5200-01.pdf https://www.fdic.gov/formsdocuments/f5200-01.pdf mailto:cmccarthy@fdic.gov mailto:mpangia@fdic.gov mailto:pbhandari@FDIC.gov

Attachments:

• Attachment 1, Draft/template Legal Support Services Agreement (LSSA) (for vendor review but not required with RFI response)

• Attachment 2 (by hyperlink only), Legal Support Services Deskbook

• Attachment 3 (by hyperlink only), FDIC Form 5200/01, Representations and Certifications for Legal Contractors https://www.fdic.gov/about/doing-business/legal-support-services-deskbook/lssprint.pdf https://www.fdic.gov/formsdocuments/f5200-01.pdf https://www.fdic.gov/formsdocuments/f5200-01.pdf

3.0 REQUESTED INFORMATION