Justification-redacted-Adv_Cash_Flow-posted-2018Feb09.pdf

a C’ FAR 13.106(b) SOLE SOURCE JUSTIFICATION FOR

ACQUISITIONS UNDER THE SIMPLIFIED ACQUISITION THRESHOLD

A. FINDINGS.

1. Identification of the requesting and contracting activity.

Office of the Comptroller of the Currency (OCC)/Educational Program Development and Acquisition Management (AQM)

2.a A description of the supplies or services required to meet the agency’s needs.

The 0CC requires multiple sessions of a five-day instructor-led Advanced Cash Flow class that is designed for the regulatory community to deepen examiners’ ability to evaluate a borrower’s cash flow and credit risk. One to three sessions will be offered annually to a group of approximately 24 examiners over two years. The training is part of OCC’s credit curriculum targeting National Bank Examiners or experienced Bank Examiners, who evaluate complex commercial credits at Large or Midsize banks. This Contractor-led course will provide OCC’s bank examiners with advanced knowledge and skills to evaluate a borrower’s capacity to generate cash flows as a primary source of repayment as well as assess how changes in cash flow influence enterprise value as a secondary source of repayment.

2.b Name of the Vendor. Paragon Analysis Corp.

2.c Requisition No. 0CCR000230500

3. Estimated dollar value of the acquisition. $140,000.00 4.a Identification of the circumstances that preclude competition under the authority of FAR 13.106(b) (Check the appropriate box that applies).

D Urgency.

Exclusive licensing agreements.

D Brand-name.

D Industrial mobilization X Other: Only one responsible source

4.b Supporting information and facts (i.e. the details surrounding the requirement that supports the selection made in 4.a).

The training curriculum being procured is that which has prior vetting and approval of the 0CC chief national bank examiner and continuing education program offices. The highly specialized Advanced Cash Flow course was previously developed by the subject-matter-expert Contractor and adapted to OCC’s regulatory mission. The course has been vetted with the chief national bank examiner’s office to ensure that the curriculum is consistent with OCC’s policies and practices on cash flow analyses as taught in other pre-commissioned credit courses. Market research indicated that other commercial courses did not meet requirements for subject matter that was consistent with the bank examiner curriculum at 0CC and that addressed the needs of the 0CC bank examiners. The process of review and approvals by the chief national bank examiner’s office is a lengthy process in order for the course to be appropriately integrated into the 0CC bank examiners’ curriculum without conflicting with 0CC policies or other training courses and without repeating other course curriculum. 0CC did not obtain intellectual property rights to the course materials in the past.

Treasury Standard Form —1009 (Rev 10/16)

Prescribed by Treasury: DTAP 1013.106(b)

0 0

0 0

5. Any other information.

0CC vilI negotiate with the Contractor to seek the intellectual property rights to the course materials for future competition of the requirement.

B. Certifications and Approvals.

6.a Program Office Certification (Requiring Activity). I hereby certify that the supporting information and data provided and which form the basis for this justification are accurate and complete to the best of my knowledge and belief.

Name: — flntP! 12/6/17

Signatun

6.b Small Business Specialist Determination (Contracting Activity) [applicable only if the vendor is not a small business]. I have reviewed this justification for an exception to competition, including any attached documentation, if applicable, and concur / do not concur with the findincs

Na — Dale: L2f7/17

6.c Contracting Officer Approval. In accordance with FAR 13. 106-1 (b)( 1), as a warranted contracting officer, I hereby determine that the circumstances of the acquisition make only one source reasonably available for the reasons indicated above; therefore precluding competition and supporting the Government’s determination to solicit and award to the vendor stated herein.

Name: tttOli Date: IZt 2019—

Signature: )<1\OJ( QRzt9in

Treasury Standard Form —1009 (Rev 10/16)

Prescribed by Treasury: PTA? 1013.106(b)

0 C)