A01 Escrow and Investment Fund Management Support Services PWS 9-6-2023.pdf

PERFORMANCE WORKSTATEMENT (PWS)

Escrow and Investment Fund Management Support Services

1. Introduction

1.1 United States Department of Agriculture (USDA), Rural Development (RD) Business Center (BC) provides loans for low and moderate-income applicants located in rural geographical areas to assist them in obtaining decent, sanitary, and safe dwellings through Single-Family Housing (SFH), Guaranteed and Multi-Family Housing (MFH) programs.

From within the BC, escrow is serviced by the Servicing Office (SO) and disbursed by the Finance Office (FO). The SO currently services a portfolio of approximately 206,000 SFH loans. The loans are located in each of the 50 states and United States Territories including Puerto Rico, Virgin Islands, Guam and the remainder of the Western Pacific Rim islands.

1.2 In 1996, RD began to centralize its operations in St. Louis, MO and convert its SFH - Direct portfolio to a new mortgage-based servicing system in an effort to provide centralized support and begin to provide escrow related services for new and existing borrowers. As a result, over 1,000 field offices were closed nationwide, and their functions were absorbed into the Centralized Servicing Center. In 2020, the Business Center was created which split the escrow functions between the Servicing Office and the Finance Office. The RD National Office, located in Washington, D.C., continued to provide oversight for the loan programs.

1.3 The SFH loan portfolio has reached approximately 140,000 "escrowed" borrowers. The escrow portion of the monthly payments (principal, interest and escrow) received from these borrowers are retrieved from the U.S. Treasury and directed to an escrow bank account that FO is custodian of for the SFH borrowers.

1.4 FO currently utilizes bank accounts at the Contractor to accumulate and invest the escrow deposits, and other receipts, and later disburse on behalf of SFH borrowers that have a mortgage with RD. An Escrow Concentration Account acts as the "primary" bank account, where escrowed checks are funded from, and other sub-accounts are associated with.

2. Bank Account Operations Background

2.1 The USDA-RD-BC operates and maintains the SFH Direct Loan portfolio using a series of eight (8) interrelated servicing/management accounts. The purpose of the number of accounts used is to isolate and track disbursements based on transaction type and also isolate excess balances for investment purposes.

2.2 The accounts used are as follows:

1) Escrow Concentration Account

2) Escrow Disbursement Account

3) Escrow Concentration Investment Account

4) Net Income Custody Account

5) Net Income Custody Investment Account

6) EFT Account

7) Escrow Voucher Account

8) Emergency Disbursement Account

I. The USDA-RD - Escrow Concentration Account is the primary banking account funded with a monthly ACH reimbursement of borrower funds from the U.S.

Treasury. The Escrow Concentration Account should be capable of receiving and disbursing ACH and wire transfer transactions of approximately $400 Million annually and allow sweeps to/from associated sub-accounts. A balance of $50 million is maintained in the account on a monthly basis. This balance fluctuates based on escrow cash flow, cyclical escrow disbursement projections and short-term investment trends. Balances are invested in a Money Market Mutual Fund that contains 100% U.S. Treasury Securities.

II. The USDA-RD - Escrow Disbursement Account is a controlled disbursement, zero-balance account (ZBA) that checks are drawn against. FO disburses checks daily payable to taxing authorities, insurance carriers, etc., on-behalf of borrowers and other miscellaneous disbursements for RD. There are two check presentment clearings at the contractor bank for the Escrow Disbursement Account each business day. At the end of each day, the gross amount of the check presentments is swept from the Escrow Concentration Account. Currently, an average of 55,000 checks are disbursed annually for a total of approximately $106 million.

III. The USDA-RD Escrow Concentration Investment Account contains borrower escrow funds invested in "second tier" investments (i.e., individual U.S. Treasury Bills and/or a Money Market Mutual Fund that contains 100% U.S. Treasury Securities). The Escrow Concentration Investment Account should be capable of supporting investment balances over $50 Million. The funds invested in this Investment Account are moved to/from the Escrow Concentration Account (greater than the targeted $50 million dollar balance) after receiving written instructions from the FO. As individual investments mature and/or new funds are deposited, the FO will discuss with the service provider's investment advisor a new investment vehicle and maturity.

IV. The USDA-RD Net Income Custody Account contains income from investments less the monthly analysis fees. A balance of $300,000 is maintained in the account monthly.

Balances are invested in a Money Market Mutual Fund that contains 100% U.S. Treasury Securities. The interest earnings on all accounts are used to pay the monthly analysis fees. The FO evaluates the monthly statements and, if necessary, prepares an ACH transaction to pay the remaining monthly analysis fees out of the Net Income Custody Account. The FO also provides oversight on the amount of analysis fees deducted from interest earnings.

V. The USDA-RD Net Income Custody Investment Account contains outstanding Net Income Custody funds (in excess of $300,000) which are invested in individual U.S.

Treasury Bills and/or a Money Market Mutual Fund that contains 100% U.S.

Treasury Securities. The income earned from the Net Income Custody Investment Account is automatically credited to this account monthly. As individual investments mature and/or new funds are deposited, the FO will discuss with the service provider's investment advisor a new investment vehicle and maturity. The Net Income Custody Investment Account should be capable of supporting custody services for investment balances over $20 Million.

VI. The USDA-RD EFT Account is the conduit to disburse new loan origination funds via electronic fund transfer (ACH and wire transfer) daily to pre-approved mortgage loan closing agents. SO prepares and FO approves each business day a data file that contains detailed ACH transmission information (i.e., payee name, bank ABA number, payee bank account number, dollar amount of transaction, addenda information, etc.) for mortgage closing agents. A separate "funding" ACH transaction is directed from the USDA-RD FO Disbursements Branch to the EFT Account for the daily gross disbursement dollar amount via Treasury’s Secure Payment System (SPS). The EFT Account should be capable of supporting ACH and wire transfer services for disbursement transactions of at least 6,250 items and totaling $1.3 Billion annually.

VII. Another sub-account utilized by USDA is the USDA-RD Escrow Voucher Account.

The Escrow Voucher Account was established to receive electronic fund transfers (ACH and wire transfer). Escrow Vouchers are requested by the SO and funded by the USDA-NFC. The Escrow Voucher Account allows for ease of receipt, posting, reconciliation and sweep into the Escrow Concentration Account nightly. The Escrow Voucher Account should be capable of supporting ACH and wire transfer receipts of at least 10,000 items and totaling more than $60 Million annually.

VIII. The final sub-account utilized by USDA is the USDA-RD Emergency Disbursement

Account. The Emergency Disbursement Account is a ZBA that has been established to disburse manual checks in a continuing operation (COOP) environment when the loan servicing platform is unavailable, and checks cannot be initiated from the Escrow Disbursement Account. Checks disbursed from this account are funded by the Escrow Concentration Account.

3. Definitions

3.1 Contracting Officer (CO) - The government official responsible for the execution and administration of the contract on behalf of the government.

3.2 Contracting Officer Representative (COR) - The government official designated by the CO and responsible for performance monitoring and quality assurance on behalf of the government.

3.3 Automated Clearing House (ACH) transaction - A credit and debit payment system unlike manual checks and wire transfers. An ACH is an electronic monetary transaction initiated by the originator and credits the receiver sometime in the future (not necessarily same day).

3.4 Electronic Funds Transfer (EFT) - An EFT can be in the form of an ACH or wire transfer and is an electronic movement of funds.

4. Scope of Work

4.1 The contractor shall provide all personnel, compatible software, access to reconciliation tools, financial system administrative set-up, supervision and other items and services necessary to perform the disbursement, banking, custody and investment services, and management reports (i.e., "Full" month-end (M/E) Account Reconciliation Plan (ARP) to include the prior months activity for cleared, voided, stop paid and outstanding checks, miscellaneous bank adjustments, M/E bank statements for each bank account, quarterly investment review for both Custody Accounts, etc.) as defined in this Performance Work Statement (PWS). The contractor shall perform to the standards stated in this contract.

5. Requirement (Objectives)

5.1 The purpose of this contract is to maintain, administer and report USDA-RD's disbursement, banking, custody, and investment activity services as they relate to deposits and disbursements. The Contractor will provide professional banking services, ensure timely and accurate reconciliation of the various investment and disbursement bank accounts and provide professional investment advice to ensure maximum return on investments while preserving principal.

6. Specific Tasks

6.1 The Escrow Concentration Account must be established and operational by M a y 19, 2024, 8:00 AM (CST) or no more than two weeks after contract award (whichever is earlier). The Escrow Concentration Account will contain both SFH borrower escrow-related funds that have been reimbursed by ACH transmission from the U.S. Treasury. The Escrow Concentration Account will be capable of receiving and disbursing ACH and wire transfers and allow movement of funds (i.e., sweeps, intra-bank transfers, etc.) amongst the other below listed USDA-RD bank and custody accounts. A balance of $50 million is targeted in the account on a monthly basis. This balance fluctuates based on cash flow, cyclical disbursement cycles and short-term investment trends. Balances will be invested in a Money Market Mutual Fund that contains 100% U.S. Treasury Securities. The Escrow Concentration Account shall have overdraft protection. In the event of an overdraft, the contractors Contract Manager, or designee, will "endeavor" to call the FO, to fund the shortfall. At month-end all associated banking fees incurred by the Escrow Concentration Account from services utilized will be deducted from the USDA-RD Net Income Custody Account. All income earned from investments in the Escrow Concentration Account will be moved to the USDA-RD Net Income Custody Account at month-end automatically by contractor.

6.2 The Escrow Disbursement Account must be established and operational by May 19, 2024, 8:00 AM (CST) or no more than two weeks after contract award (whichever is earlier). The Escrow Disbursement Account will be established as a controlled disbursement, ZBA that USDA-RD checks are drawn against. FO routinely disburses checks payable to taxing authorities, insurance carriers, etc., on-behalf of escrow borrowers and other miscellaneous disbursements for RD. There shall be two check presentment clearings for the Escrow Disbursement Account each business day.

At the end of each day, the gross amount of the check presentments is swept from the Escrow Concentration Account. At month-end all associated banking fees incurred by the Escrow Disbursement Account of contractor services utilized will be deducted from the USDA-RD Net Income Custody Account.

6.2.1 Provide monthly images (front and back) of USDA-RD-CFO checks that have cleared the Escrow Disbursement Account and Emergency Disbursement Account that are accessible on-line and compatible with Windows 10 and can be accessed by Microsoft Edge and/or Google Chrome. The contractor shall provide written instructions and the software required to view the check images. The contractor shall provide the monthly images of checks no later than the 15th calendar day of the following month.

6.2.2 Provide on-line access to allow for Escrow Disbursement Account and Emergency Disbursement Account check voids and stop payments processing.

The contractor shall provide written instructions and the software required to accomplish each function on- line. The software shall be compatible with Windows 10 and be accessible by Microsoft Edge or Google Chrome web browser as applicable.

6.3 The USDA-RD Escrow Concentration Investment Account must be established and operational by May 19, 2024, 8:00 AM (CST) or no more than two weeks after contract award (whichever is earlier). The Escrow Concentration Investment Account contains borrower funds and is invested in "second tier" investments (i.e., individual U.S. Treasury Bills and/or a Money Market Mutual Fund that contains 100% U.S. Treasury Securities).

The funds invested in this custody account are moved to/from the Escrow Concentration Account (greater than the targeted $50 million-dollar balance) after receiving written instructions from the FO. As individual investments mature and/or new funds are deposited the FO will discuss with the service provider's investment advisor a new investment vehicle and maturity. All income earned from investments in the Borrowers Escrow Funds Custody Account will be moved to the USDA - RD Net Income Custody Account at month-end automatically by contractor.

6.4 The USDA-RD Net Income Custody Account must be established and operational by May 19, 2024, 8:00 AM (CST) or no more than two weeks after contract award. The funds in the Net Income Custody Account, in excess of $300,000, are invested in the Net Income Custody Investment Account with Money Market Mutual Funds that contain 100% U.S. Treasury Securities. At month-end, all associated custody and asset management fees incurred will be automatically deducted from the income earned each month from the various escrow accounts.

The FO reviews all escrow statements for accuracy and prepares an ACH transaction from the Net Income Custody Account if the fees exceed the income earned.

6.5 The USDA-RD Net Income Custody Investment Account must be established and operational by May 19, 2024, 8:00 AM (CST) or no more than two weeks after contract award (whichever is earlier). The Net Income Custody Investment Account contains net income from interest on escrow and investment earnings. The funds are invested in individual U.S. Treasury Bills and/or a Money Market Mutual Fund that contains 100% U.S. Treasury Securities. As individual investments mature and/or new funds are deposited, the FO will discuss with the service provider's investment advisor a new investment vehicle and maturity. All income earned from investments in the Borrowers Escrow Funds Custody Account will be moved to the USDA-RD Net Income Custody Account at month-end automatically by contractor.

6.6 The USDA-RD EFT Account must be established and operational by May 19, 2024, 8:00 AM (CST) or no more than two weeks after contract award (whichever is earlier). The EFT Account is utilized to disburse new loan closing funds via electronic fund transfer (ACH and wire transfer) to pre-approved mortgage loan closing agents. SO prepares and FO approves each business day a data file that contains detailed ACH transmission information (i.e., payee name, bank ABA number, payee bank account number, dollar amount of transactions, addenda information, etc.) for mortgage closing agents. This ACH processing file is transmitted to the contractor each day at approximately noon. A separate "funding" ACH transaction is directed from the USDA-RD FO Disbursements Branch to the EFT Account for each daily ACH disbursement file gross dollar amount. Currently, FO transmits one daily ACH batch file with approximately 520 ACH transactions per month at approximately $200,000 per ACH transaction. At month-end all associated banking fees incurred by the EFT Account from services utilized will be deducted from the USDA-RD Net Income Custody Account.

6.7 The USDA-RD Escrow Voucher Account must be established and operational by May 19, 2024, 8:00 AM (CST) or no more than two weeks after contract award (whichever is earlier). The Escrow Voucher Account is a sub-account of the Escrow Concentration Account. The Escrow Voucher Account was established to receive electronic fund transfers (ACH and wire transfer). Escrow Vouchers are requested by the SO and funded by the USDA-NFC. The Escrow Voucher Account allows for ease of receipt, posting, reconciliation and sweep into the Escrow Concentration Account nightly. At month-end all associated banking fees incurred by the Escrow Voucher Account from services utilized will be deducted from the USDA-RD Net Income Custody Account.

6.8 The USDA-RD Emergency Disbursement Account must be established and operational by May 19, 2024, 8:00 AM (CST) or no more than two weeks after contract award (whichever is earlier). The Emergency Disbursement Account is a sub-account of the USDA-RD Escrow Concentration Account. The Emergency Disbursement Account is a controlled disbursement account that is established to disburse manual checks for continuity of operations (COOP) in an emergency when the loan servicing platform is unavailable and checks cannot be initiated from the Escrow Disbursement Account. Contractor shall provide manual check stock for this purpose. Checks disbursed from this account are funded from the Escrow Concentration Account. At month-end all associated banking fees incurred by the Emergency Disbursement

Account from services utilized will be deducted from the USDA-RD Net Income Custody Account.

6.9 Reporting and Reconciliation - The contractor shall provide an electronic copy to the Finance Office POC email addresses of month-end Account Analysis (i.e., billing statement) of services provided with associated volumes and cost on each bank account established and maintained for USDA-RD. This document will be reviewed by the CFO COR and Finance POC’s, and upon agreement of monthly fees written authorization will be directed to contractor for the total fee amount to be deducted from the USDA-RD Net Income Account.

These electronic reports shall be provided no later than the 15th calendar day of the following month.

6.10 Daily Processing and Monthly Reconciliation Software - The contractor shall provide software, written instructions and training that will allow FO to access all banking requirements listed above over the internet (on-line). The contractor’s system shall allow USDA to import more than one payment file per day (if necessary), allow to process voids (for checks that are returned as undeliverable) and process Stop Pays (for checks that have not been returned and are presumed lost in the mail). Website access is required to research the status of all checks and print an image of a reconciled check converted to a PDF document for USDA’s Customer Service representatives who receive inquiries from their borrowers regarding the status of the check. Any upfront or one-time charges by contractor for this software, training or access should be documented and presented to the CS and CO in the initial proposal.

6.11 RD System Integration and Automation – The contractor shall address the integration of daily processing software with the NowDocs application that USDA-RD utilizes; where transactions are processed from a SQL database and are transmitted to the NowDocs application. The Contractor shall provide any and all necessary software support for ensuring that successful interfacing has been established. If there are any software upgrades during the life of contract, the Contractor is responsible for seeing that the interface can accommodate any changes in the data stream going to the USDA computerized information system.

6.12 ARP Contractor Contacts - The contractor shall provide the names and contact information for the key contact for ARP purposes. An electronic copy to the Finance Office POC email addresses shall be provided of the "Full" ARP reports for the USDA-RD Escrow Concentration, Escrow Disbursement and Emergency Disbursement Accounts monthly.

These electronic reconciliations shall be provided no later than the 15th calendar day of the following month.

6.13 Communications Software - The contractor shall provide FO with necessary data transmission configurations and/or software that will allow bank information and transactions to be processed and communicated between contractor and the FO in real time.

All upfront or one-time charges by contractor for this software, training or access should be documented and presented to the CO in the initial proposal. The software shall be compatible with Windows 10 and be accessible by Microsoft Edge or Google Chrome web browser as applicable. In addition, the contractor shall provide afterhours support for their software.

6.14 Contractor Facility Access - The contractor shall cooperate fully with USDA-RD with matters related to the Contract, and can meet on a regular basis with USDA-RD to conduct reviews. However, it should be noted, the contractor must still comply with federal regulations and internal controls. All requests for inspection and reviews should be limited to USDA-RD's information for the commercial services received, and addressed to the Client Manager who will promptly review and respond to the request.

6.15 Meetings - The CO, COR or Finance POC may request a meeting as deemed necessary.

Written minutes of such meetings shall be recorded and signed by the CO, COR or Finance POC. If the contractor does not concur with any portion of the minutes, such non-concurrence shall be provided to the CO, COR or Finance POC within 5 calendar days following receipt of the minutes.

7. Period of Performance

Base Period May 20, 2024 - May 19, 2025 Option Period 1 May 20, 2025 - May 19, 2026 Option Period 2 May 20, 2026 - May 19, 2027 Option Period 3 May 20, 2027 - May 19, 2028 Option Period 4 May 20, 2028 - May 19, 2029

8. Place of Performance

8.1 Normal day-to-day operations will be performed at the offeror’s place of business and/or remotely.

8.2 The Contractor agrees that this is a non-personal services contract and must not represent itself as an agent or partner of, or in joint venture with the Government; and that it will neither supervise nor accept supervision from Government employees.

9. Rehabilitation Act of 1973

9.1 This PWS is subject to Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. 794d) as amended by the Workforce Investment Act of 1998 (P.L. 105-220). Specifically, subsection 508(a) requires that Federal employees and members of the public with disabilities have comparable access to and use of information and data provided to employees and members of the public without disabilities.

10. Electronic Deliveries

10.1 Electronic deliverables items shall be sent to the following Government POC’s:

USDA-RD-COD

Attention: Brookelyn Nelson (CS) E-mail: Brookelyn.Nelson@usda.gov

USDA-RD-COD

Attention: Ryan Shappell (CO) E-mail: Ryan.Shappell@usda.gov

USDA-RD-CFO

Attention: Varsha Shah (COR) Email: varsha.shah@usda.gov

USDA-RD-CFO

Attention: Sharon Maull (Finance POC) Email: Sharon.Maull@usda.gov

USDA-RD-CFO

Attention: Lindsey Syron (Finance POC) Email: Lindsey.Syron@usda.gov

11. Delivery Schedule

11.1 The contractor shall provide on-line access to USDA-RD bank account balances, ACH and wire transfer transmission capabilities, void and stop payment of disbursed checks, positive pay monitoring and action (acceptance or rejection), check presentment totals, etc.

on a daily basis. Account analysis statements, USDA-RD bank statement activity, Account Reconciliation Plan (ARP) reporting shall be provided as an electronic copy to the Finance Office POC email addresses within 15 calendar days after the end of the reported month.

12. Billing

12.1 An account analysis statement (i.e., billing statement) detailing the monthly banking services volumes with the associated contractual fees for services less any offsetting compensating balances must be electronically submitted within 15 calendar days after the end of the reported month. In addition, any custody and investment management fees billed on USDA-RD funds invested in individual U.S. Treasury Bills will be electronically submitted within 15 calendar days after the end of the reported month. T h e account analysis statement (i.e., billing statement) shall be submitted listing the Contract number to the following Government POC’s:

USDA-RD-COD

mailto:Brookelyn.Nelson@usda.gov mailto:Ryan.Shappell@usda.gov mailto:varsha.shah@usda.gov mailto:Sharon.Maull@usda.gov mailto:Lindsey.Syron@usda.gov

Attention: Brookelyn Nelson E-mail: Brookelyn.Nelson@usda.gov

USDA-RD-COD

Attention: Ryan Shappell E-mail: Ryan.Shappell@usda.gov

USDA-RD-CFO

Attention: Varsha Shah (COR) Email: varsha.shah@usda.gov

USDA-RD-CFO

Attention: Sharon Maull (Finance POC) Email: Sharon.Maull@usda.gov

USDA-RD-CFO

Attention: Lindsey Syron (Finance POC) Email: Lindsey.Syron@usda.gov

12.2 NOTE: This contract is administered as a "self-funded" contract where all fees (i.e., banking services, custody and investment management) are paid, after review by the CFO COR and Finance POC’s referenced above, from the accumulated funds in the USDA-RD Net Income Account located at contractor. The CFO COR and Finance POC’s ensure that the fees are legitimate and validated, against the services performed for that month, in accordance with the established fees that are set forth in the contract award.

13. Technical Direction/Contracting Officer’s Representative (COR)

13.1 Performance of the work herein shall be subject to the technical direction of the COR or their duly authorized representative. As used herein, technical direction encompasses directions to the contractor which fill in details or othe1wise complete the general description of the work set forth above. These directions must be within the general scope of the work set forth above and may not be of such a nature as to constitute an increase in the amount of, or time required, for completion of the work under this contract, or affect any other provisions hereof without prior written approval of the CO.

14. Authority to Obligate the Government or Modify the Terms of the Contract

14.1 The Contracting Officer is the only person authorized to approve changes in any of the requirements of this contract.

14.2 This authority remains solely with the Contracting Officer. In the event the Contractor effects any change at the direction of any person other than the Contracting Officer, the change will be considered to have been made without authority and NO adjustment will be made in the contract price to cover any additional cost resulting or incurred as a result thereof.

mailto:Brookelyn.Nelson@usda.gov mailto:Ryan.Shappell@usda.gov mailto:varsha.shah@usda.gov mailto:Sharon.Maull@usda.gov mailto:Lindsey.Syron@usda.gov

15. Special Contract Requirements

15.1 Physical Security:

15.1.1 Safeguarding Personally Identifiable Information (PII) - The contractor shall be responsible for safeguarding all government PII on Single Family Housing (SFH) escrow borrowers including their escrow deposited funds that USDA-RD is custodian over and are held within the bank accounts outlined in this Contract.

15.1.2 Internal Controls - The contractor will be responsible for internal controls on USDA-RD PII and SFH borrower escrow funds as set forth in contractors Data and Information Security Protection policy in its Treasury Services Terms and conditions booklet.

15.2 Hours of Operation - The contractor shall deliver and perform all services during the business hours of 8:00 AM through 5:00 PM (CST), Monday through Friday, excluding the following Federal Government holidays as specified at 5 U.S.C. 6103.

New Year's Day Martin Luther King, Jr.'s Birthday President's Day Memorial Day Juneteenth Independence Day Labor Day Columbus Day Veteran's Day Thanksgiving Day Christmas Day

15.3 News Release Limitation - No news releases pertaining to this contract or subsequent delivery orders shall be made without prior written approval from the USDA-RD, and then only in coordination with the CO.

15.4 Use of USDA’s Name or Contractual Relationship in Advertisement - The contractor agrees not to refer to awards of contracts from USDA-RD in commercial advertising. The contractor also agrees not to distribute or release any information that states or implies that USDA-RD endorses, uses, or distributes the contractor's products or services without prior approval in writing from the CO.

15.5 Information Security - Performance of this contract may require the contractor to have access to and use of data and information that may be considered proprietary by other customers, or that may otherwise be of such a nature that its dissemination or use, other than in performance of this contract would be averse to the interest of the USDA-RD and others. The contractor agrees that the contractor personnel shall not divulge, or release data and information developed or obtained in connection with the performance of this contract, until made public by the USDA-RD, except-to authorize USDA-RD personnel or upon written authority from the

CO.

15.6 Standards of Conduct and Restrictions - The contractor shall conform to the standard of conduct as follows:

15.6.1 The contractor shall not market for or solicit new business opportunities from USDA-RD except through formal procurement channels.

15.6.2 The contractor and its employees shall refrain from discussing with unauthorized persons any information obtained in the performance of this contract or subsequent delivery orders.

15.7 Inspections - The contractor shall keep all USDA-RD (and related) records available for inspection by the CO and/or COR. Original documents and copies will be safeguarded against waste, fraud and abuse.