Award SSJ.pdf

SOLE SOURCE JUSTIFICATION FOR CERTAIN COMMERCIAL PRODUCTS AND

COMMERCIAL SERVICES USING SIMPLIFIED ACQUISITION PROCEDURES

Pursuant to the requirements of the Competition in Contracting Act (CICA), the following facts and rationale justify the basis for a noncompetitive contract.

1. I recommend that the Federal Housing Finance Agency (FHFA) use other than full and open competition for the acquisition of television, podcast, and radio media monitoring, alert services, and related media/public relations subject matter expert human support to provide FHFA with timely awareness of relevant coverage across all national cable news networks, including major

Sunday news and public affairs programs, and identified podcast and radio broadcasts. The estimated price, including one (1) base year and one (1) option year, is .

2. Nature and/or description of the action being approved.

The FHFA intends to issue a firm-fixed-price (FFP) purchase order award to:

Locust Street Solutions LLC

The period of performance is intended as follows:

Base Year: 8/14/2026 to 8/13/2027

Option Year One (1): 8/14/2027 to 8/13/2028

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

FHFA’s Office of Congressional Affairs and Communications (OCAC) requires contractor capability and support to provide extensive television, podcast, and radio media monitoring and on-demand delivery to allow the Agency to monitor public media and manage Agency responses to media coverage related to housing and financial markets. These contractor capabilities will complement the Agency’s current suite of social media and digital/print publication monitoring, providing extensive oversight of all media outlets. There is no acquisition history as these are new requirements for FHFA/OCAC.

OCAC requires these services to prevent gaps in media coverage awareness, specifically television, podcast, and/or radio media-based, which can leave the Agency, its leadership, and financial markets vulnerable to misinformation and other media deliberate attempts to obfuscate true Agency priorities and mission objectives. The Agency must maintain awareness of media coverage to ensure appropriate responses are provided timely to internal and external stakeholders.

The Contractor will:

• Provide a solution that provides FHFA with timely awareness of and access to relevant coverage across television, podcast, and/or radio broadcast sources;

• Deliver on-demand, real-time and edited high-definition (HD) (where available) video clips,

• Provide rapid turnaround for clip delivery in reasonable high-quality formatting;

• Provide real-time media monitoring including but not limited to: immediate alerts for relevant media mentions and coverage (as requested), and continuous monitoring of designated television, podcast, and/or radio broadcast sources;

• Allow OCAC to provide various keyword/search term parameters and identified topics of interest for coverage monitoring, and allow for the updating and refinement of such keywords/search term parameters and identified topics of interest throughout contract performance. The Contractor shall not limit OCAC to a certain number of keyword/search term parameters and identified topics of interest it can use;

• Provide monitoring coverage 24 hours per day, 7 days per week including holidays, with delivery of clips to be provided in the window of time specified by OCAC; and

• Provide dedicated human-based media/public relations subject matter expert staff that are available on demand to oversee service delivery, coordinate reporting, manage keyword updates, answer inquiries (beyond standard informational technology help desk troubleshooting), provide quality assurance, and resolve any other reasonably related inquiries or issues.

4. An identification of the statutory authority permitting other than full and open competition.

41 U.S.C. 1901(e)(2), FAR 13.501(a)

5. A demonstration that the proposed Contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited (for sole source acquisitions; also required for unusual and compelling urgency where more than one offer will not be solicited).

Locust Street Solutions LLC is the only source capable of providing the needed, specialized breadth of coverage in television, podcast, and/or radio media monitoring, alert services, and related human-based media/public relations subject matter expert support to provide FHFA with timely awareness of relevant coverage across all national cable news networks, including major

Sunday news and public affairs programs, and identified podcast and radio broadcasts, which are needed to complement the Agency’s current suite of social media and digital/print publication monitoring to provide the most extensive oversight of all media outlets. Locust Street Solutions

LLC’s solution delivery is uniquely qualified to meet FHFA’s requirements through its ability to monitor multiple forms of broadcast media (i.e., television, podcast, and/or radio), provide delivery of clips from these media sources, and provide responsive, human technical expertise to support the delivery and subject matter troubleshooting that may arise from deliverables.

Locust Street Solutions LLC’s solution is the only source found to include 24 hours / 7 days a week editorial analysis support services using qualified human analysts/editorswho possess demonstrated knowledge of the housing finance industry, FHFA’s missions and statutory responsibilities, and the roles of Congress and the Administration in housing finance policy, whereas other related media monitoring solutions rely heavily on technological solutions (e.g., algorithms) without subject matter expert back-end human support. FHFA requires human support/reach-back in its television, podcast, and/or radio media monitoring solution to ensure instantaneous feedback on quality assurance of the media clips within specified search parameters and topics of interest, as well as alignment with FHFA’s monitoring priorities. Other media monitoring solutions with passive/solely technologically based support have proven too slow in their ability to adapt with changing FHFA priorities, search parameters, and topics of interest, which is unacceptable to OCAC’s mission.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable.

FHFA issued a “Special Notice,” a notice of intent to sole source to Locust Street Solutions LLC, on the Governmentwide Point of Entry (GPE), Contract Opportunities on SAM.gov, on July 8th, 2026 with a response deadline of July 15th, 2026 to allow vendors to express their interest in fulfilling the requirement. FHFA received zero (0) responses, capability statements, quotations, or challenges from potential interested vendors.

7. A determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer determines the anticipated price will be fair and reasonable by relying on published price lists and by entering into negotiations with Locust Street Solutions LLC. The

Contracting Officer will determine the anticipated price to be fair and reasonable based on the techniques outlined in FAR 13.106-3(a)(2)(i), (ii), (iii), and/or (vi).

8. A description of the market research conducted and the results or a statement of the reason market research was not conducted.

FHFA currently possesses multiple contractor capabilities to provide media monitoring as it relates to digital, print, and social media mediums. FHFA conducted market research to determine if these current media monitoring contractors (e.g., Cision, Grabien) could provide the capability to monitor television, podcast, and radio-based media and to provide instantaneous, sound and/or video clips and human support to facilitate related details; each of the contractors noted they did not possess such capabilities.

Further, FHFA contacted the following media monitoring contractors with the following results:

• Media Monitors – possessed abilities to provide television media monitoring but did not express its ability to provide podcast and radio monitoring, nor the ability to provide human subject matter expertise support.

• Meltwater – did not provide a response to FHFA’s inquiries.

• News Exposure – possessed abilities to provide television media monitoring but did not express its ability to provide podcast and radio monitoring.

• Rational 360 – during performance of a micro-purchase for substantially similar services, the vendor expressed its inability to meet FHFA’s human subject matter expertise support requirements and could not finish out the micro-purchase period of performance.

• TV Eyes – did not provide the impression it understood FHFA’s requirements and did not express its ability to provide television, podcast, and radio media monitoring capabilities, nor human subject matter expertise support.

Finally, as explained in Section 8 above, FHFA issued a “Special Notice,” a notice of intent to sole source to Locust Street Solutions LLC which received zero (0) responses, capability statements, quotations, or challenges from potential interested vendors.

9. Any other facts supporting the use of other than full and open competition.

None.

10. A listing of sources, if any, that expressed, in writing, an interest in the acquisition.

None.

11. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

As the media broadcast landscape, and the commercial sector’s capabilities to monitor and provide human support services in response to media broadcasts, continues to change, FHFA will reassess the commercial sector’s capabilities to provide television, podcast, and radio media monitoring, alert services, and related human-based media/public relations subject matter expert support. The contemplated award is for a maximum period of performance of two years, which will necessitate FHFA to revisit market research throughout the performance and, if this requirement exists at the end of this contract, again in a maximum of two years.

CERTIFICATIONS

I certify that this justification is accurate and contains complete data necessary to support the recommendation for other than full and open competition.

Date

Supervisory Communications Specialist

FHFA/OCAC

I certify that this justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief. Also, I hereby (1) determine the circumstances cited as the statutory authority apply to this action, (2) determine the anticipated cost to the government will be fair and reasonable, and (3) approve this action.

Date Steven Novotny

Contracting Officer

I determine that this submission is legally sufficient to justify the basis for a noncompetitive contract award.

Date

Assistant General Counsel

Office of General Counsel