Justification - Signed.pdf

JUSTIFICATION

Bureau Enhanced Acquisition Management System

Source Selection Sensitive in accordance with FAR 2.101 and FAR 3.104.

Procurement ID: ePRO-2026- 17059

BEAMS User Guide BEAMS Feedback

Intake Acq Plan Biz Incl Tech QA Justification Local Clauses Evaluation Review Contract Admin

SUMMARY

Procurement Title:

ENF - AgileLaw Contract Program Office:

ENF: Enforcement

Contracting Officer:

Salinas, Jerry (CFPB)

Contract Specialist:

Acquisition Strategy:

Anticipated Award Date:

Base and All Options Value:

$141,000.00 (Total Contract Value)

BR Total Amount:

$0.00

Type Of Action:

New Contract/Agreement

Bureau:

CFPB

Contract Type: Contract Number:

Is it Sole Source?

Yes No

FAR Reference:

6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements �

PERIOD OF PERFORMANCE

Base Period (Months):

Number of Option Periods:

COSTS Note: the Base Amount(s) do not update from the Buy Request after the first time they are copied.

If the Base Amount in the BR changes, you may need to manually update it here.

Life-Cycle Estimated Total:

$141,000.00

Base (From Buy Request 1):

$141,000 Note: You may over-ride the base amount(s).

Base (From Buy Request 2):

If the background color is yellow, the amount does not match the Buy Request.

FAR 6.3

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

(FAR) 6.302

Date Needed:

Nature/Description of Action, Supplies, and Services [FAR 6.303-2(b)(2] and (3):

Display Acq Plan Statement of Need The Consumer Financial Protection Bureau’s (CFPB) Enforcement Division requires an Exhibit Sharing solution to process, search, and share large sets of exhibits during deposition.

This platform will expand Enforcement's suite of legal technologies and solutions that support litigation functions and capabilities. Through such a platform, Enforcement seeks to reduce cost, risks, and errors, while remaining compliant with agreed upon production specifications and timelines.

Statutory Authority Permitting Other than Full and Open Competition [FAR 6.303-2(b)(4)]:

6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements �

Description of Market Research and Results [FAR 6.303-2(b)(6), (8) and (10)]:

Display Acq Plan Market Research The initial market research was conducted in 2020, and involved in-depth analysis of four OTS products. The following products were identified as candidates that may have met requirements outlined by our ENF and Legal divisions. Live Litigation Veritext Exhibit Share eDepoze AgileLaw The first product, Live Litigation, was removed from eligibility based on Cybersecurity concerns. The service was built on Adobe Flash, which is at end-of-life and will not receive future security updates. This product had been reviewed in March of 2020 and the decision to deny its usage was documented in an email from Donna Roy (CIO at the time) on March 24th. The second product, Veritext Exhibit Share, was fairly simplistic and was found to be lacking several functionalities outlined in the requirements and was omitted as a result. For the remaining two products, T&I set up demos and invited Joseph Calvarese and Glenn Melcher from ENF as participants to assist in evaluation of the features. These demos were conducted on August 20 and 21, 2020. The group found that eDepoze met some of the requirements but it did not support two critical criteria: native Excel document rendering, and security options that can restrict which participants can download presented documents. Both of these criteria were exclusively met by the AgileLaw product. ENF in particular has placed high importance on these two requirement criteria due to the restrictive nature of investigational hearings and their use case for Excel files. Market research was re-visited in 2023 to see if there were any new FEDRAMP approved options available. None were found that met the required criteria. The initial set of products was also re-evaluated to see if there were any changes in their features or security which would meet CFPB's needs. Live Litigation is still built on Adobe Flash, so it cannot be considered. Veritext Exhibit Share and eDepoze do not allow native Excel document rendering, and were still missing security options to restrict the users from downloading documents. Because of this, neither of them could be considered. At this time, AgileLaw continues to be the only platform that meets CFPB security and functional requirements.

Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

3/20/26, 4:23 PM Bureau Enhanced Acquisition Management System - ePRO-2026-17059 https://bcfp365.sharepoint.com/sites/proc/_layouts/15/FormServer.aspx?XmlLocation=%2fsites%2fproc%2fePro%2fePRO-2026-17059.xml&CT=1774… 1/3 https://sharepoint.cfpb.local/promgt/procure/eProcurement/Documents/Docs%20Posted%20in%20BEAMS%20Form%20for%20Client%20Use/BEAMS_Client_User_Guide.pdf https://sharepoint.cfpb.local/promgt/procure/eProcurement/Lists/BEAMS%20Feedback%20Tracker/Issue/newifs.aspx?List=d2403db3%2D56d3%2D4191%2Dbfab%2Dc88f7272ab4a&Source=https%3A%2F%2Fsharepoint%2Ecfpb%2Elocal%2Fpromgt%2Fprocure%2FeProcurement%2FLists%2FBEAMS%2520Feedback%2520Tracker%2FAllItems%2Easpx&RootFolder=&Web=c7d7e3f5%2D98d7%2D4224%2Da3d7%2D4365e09d6c7e

Determination of Fair and Reasonable Cost/Price [FAR 6.303-2(b)(7)]: The Contracting Officer determines that the anticipated price(s) will be fair and reasonable based on the following information:

Any Other Facts Supporting the Use of Other than Full and Open Competition [FAR 6.303-2(b)(9)]:

Actions Taken to Remove or Overcome Barriers to Competition [FAR 6.303-2(b)(11)]:

CERTIFICATION

Technical/Requirements Official [FAR 6.303-2(c):

I certify that the facts and representations under my cognizance, which are included in this justification and which form a basis for this justification, are complete and accurate.

Contracting Officer [FAR 6.303-2(b)(12):By signing below, I certify that this justification is accurate and complete to the best of my knowledge and belief.

SIGNATURES Contract and Legal Reviews Policy

Person Decision Approved Date and Time

Senior Program Official (Only applicable under FAR 8.4)

Approve

Technical/Requirements Official Clear

Burton, Theresa (CFPB);

Contracting Officer Clear

Salinas, Jerry (CFPB)

Competition Advocate

Head of Contracting Activity

One of the mandates from the Dodd-Frank Act of 2011 is for the Consumer Financial Protection Bureau (CFPB) to enforce and bring actions against financial institutions when they have not complied with applicable laws and regulations. Investigations conducted by the Bureau often require the taking of testimony via an investigational hearing. Should the investigation lead to litigation, the Bureau often will take testimony via a deposition. These investigational hearings and depositions are conducted by the Bureau, with the assistance of a court reporter, and necessitate the ability to present documents as exhibits. In investigational hearings, these exhibits are submitted to the witness for review during the hearing but must be collected and returned to the Bureau's control at the end of the hearing.

From our market research, AgileLaw was the only available software that meets the Bureau’s requirements for an exhibit sharing application. The Bureau requires an application that meets the following criteria:

1) The ability to for Bureau staff to upload documents, control the timing of sharing of those documents with a witness and opposing counsel and provide the ability for the witness and opposing counsel to independently review the document once shared.

2) When sharing exhibits that are Microsoft Excel files, it must be able to do so natively so that the opposing party can review the content of cells, rearrange columns, and manipulate any sheets. A static view of an Excel file is not sufficient.

3) For investigational hearings the application must not allow the opposing party to download and keep a copy of any exhibit. The Bureau must be able to maintain control of exhibits at all times.

AgileLaw is the only vendor that was found to provide an exhibit sharing solution that meets all of these required criteria.

The Independent Government Cost Estimate (IGCE) will be used to determine fair and reasonable pricing. The IGCE is based on historical pricing from the previous contract

9531CB23C0017.

N/A

The program office will continue to research current and other vendors that can provide the required services.

3/20/2026 4:20:55 PM

3/20/2026 4:23:38 PM

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Senior Procurement Executive

Justification Signature History Stamp

Source Selection Sensitive in accordance with FAR 2.101 and FAR 3.104.

STATUS

Pre-Solicitation Documents in Draft

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HISTORY

Created By:

Burton, Theresa (CFPB) Creation Date:

3/19/2026

Creation Time:

3:51:02 PM

Last Modified By:

Burton, Theresa (CFPB)

Last Modified Date:

3/20/2026

Last Modified Time:

4:23:05 PM

Office of the Chief Procurement Officer Operations Division

Consumer Financial Protection Bureau

||CO Salinas, Jerry (CFPB)has Approved 2026-03-20T16:23:38 ||Technical Requirements Offical Burton, Theresa (CFPB)has Approved 2026-03-20T16:20:55 ||||

Acq Plan

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