Industry Feedback Form with PBGC Responses - Draft Solicitation - Public.xlsx
XLSX spreadsheet 26 KB Posted
- Solicitation number
- DRAFT25R0062
- Issued by
-
Pension Benefit Guaranty Corporation
About this file
This is an Industry Feedback Form for a draft solicitation for Fixed Income Investment Services issued by the Pension Benefit Guaranty Corporation (PBGC). The solicitation seeks investment managers to provide services across four primary fixed income product categories: Core Fixed Income, Credit Fixed Income, Global Fixed Income, and Emerging Market Debt. Key requirements include firms managing a minimum of $500 billion in Assets Under Management, having at least two qualifying products, and meeting specific benchmark and performance criteria for each product type.
The draft solicitation is structured in multiple phases, with an estimated final solicitation release in October or November 2025. Offerors must be registered in SAM.gov and submit detailed product qualifications, including performance data, benchmark adherence, and investment strategy information. PBGC emphasizes that the most important evaluation factors will be the strength of the product offering, with non-price factors being more critical than pricing. The solicitation indicates PBGC will likely award contracts on an "all or nothing" basis among products deemed to have fair and reasonable prices, with potential post-award portfolio-specific guideline negotiations.
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| File | Type | Posted |
|---|---|---|
| Industry Feedback Form - Draft Solicitation.xlsx | XLSX spreadsheet | |
| Attachment 6 - DRAFT Solicitation Phase 1 Forms_Amendment 1.docx | DOCX document | |
| Industry Feedback Form - Draft Solicitation.xlsx | XLSX spreadsheet | |
| Attachment 1 - DRAFT Instructions to Offerors.pdf | ||
| Attachment 5 - DRAFT Clauses and Provisions.pdf | ||
| Attachment 2 - DRAFT Evaluation Criteria.pdf | ||
| Attachment 3 - DRAFT Statement of Work.pdf | ||
| Attachment 4 - DRAFT Fixed Income Pricing Template.xlsx | XLSX spreadsheet | |
| Attachment 6 - DRAFT Solicitation Phase 1 Forms.docx | DOCX document | |
| Attachment 8 - DRAFT Data Table Templates.xls | XLS spreadsheet | |
| Attachment 7 - DRAFT Solicitation Phase 2 Forms.docx | DOCX document |
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Reformat Questions Fixed Income Investment Services Draft Solicitation Questions and Responses
| # | TOPIC | ATTACHMENT TITLE | PAGE & SECTION # | QUESTION OR RECOMMENDATION | GOVERNMENT RESPONSE |
| 1 | Offeror Qualifications Form | Attachment+6+-+DRAFT+Solicitation+Phase+1+Forms | Page 2, Question C | Please may we confirm that all Offerors must manage a minimum of 500bn USD in AUM? Or, will Offerors be able to classify as a Specialist where the firm level AUM requirement is a reduced amount, such as 5bn USD as was the case in the previous solicitation? For background, as part of the prior soliciation, PBGC offered two types of classifications for Offerors, including one called a Specialist Global and/or Emerging Market Debt Manager where the firm level AUM requirement was 5bn USD. We ask as we were a previous manager for PBGC but would be excluded from managing a mandate for you under the 500bn USD requirement. | PBGC confirms the requirement that offerors must manage a minimum of $500 billion in AUM. PBGC will not be offering a Specialist classification with different AUM requirements. |
| 2 | Global Fixed Income qualifying product benchmark | Attachment+6+-+DRAFT+Solicitation+Phase+1+Forms | Page 9, Questions A, E & F | While the Qualifying Product is actively managed against the Bloomberg Global Aggregate USD Hedged Index, may the Offeror submit GIPS compliant track records managed against the FTSE World Government Bond Index USD Hedged or Unhedged? | No. |
| 3 | Global Fixed Income qualifying product benchmark | Attachment+6+-+DRAFT+Solicitation+Phase+1+Forms | Page 9, Question B | May the Offeror rely on assets benchmarked to the Bloomberg Global Aggregate Hedged Index, inclusive of indices hedged or unhedged in various currencies, while agreeing to manage the account against the Bloomberg Global Aggregate USD Hedged Index should they win the award? | Yes. PBGC will amend the solicitation language to clarify that submissions for products managed against the Hedged or Unhedged versions of the Bloomberg Global Aggregate index are acceptable. If a submission references an unhedged product, the firm must provide additional information to demonstrate the ability to run the strategy on a hedged basis. |
| 4 | Global Fixed Income qualifying product benchmark | Attachment+6+-+DRAFT+Solicitation+Phase+1+Forms | Page 9, Question B | May the Offeror rely on assets benchmarked to the FTSE World Government Bond Index hedged or unhedged in various currencies for qualification while agreeing to manage the account against the Bloomberg Global Aggregate USD Hedged Index should they win the award? | No. |
| 5 | Proposed Product | Attachment 6: Solicitation Phase 1 Forms | Product Qualifications Form – Emerging Markets Debt Fixed Income - pg 12 | We offer a product that is actively managed in alignment with one of the recommended benchmarks specified in qualification A. According to qualification C, experience managing a tax-exempt client with over $100 million in the proposed strategy is required. We currently have a client who meets this criterion; however, their investment is in another Emerging Markets product provided by our firm and managed by the same team. Please clarify whether our proposal would meet the criteria for consideration under these circumstances. | PBGC will amend the solicitation and remove this reference from mandatory requirements. |
| 6 | AUM Requirement | Solicitation Phase 1 Forms | Page 2, question C | Firm required to have $500bn in AUM. Should this be $5bn? | No, the requirement is for Offerors to manager a minimum of $500 billion in AUM. |
| 7 | Asset Allocation Parameters | Draft Solicitation | n/a | Will PBGC specify minimum/maximum allocations within the portfolio mandate (e.g., Treasuries, corporates, agencies), or is this left to manager discretion under PBGC guidelines? | No, PBGC will negotiate portfolio specific guidelines in the post-award phase. |
| 8 | Performance Benchmarks | Draft Solicitation | n/a | Will PBGC define a specific benchmark such as Bloomberg U.S. Aggregate Index, or will benchmarks vary by sub-portfolio/product? | The benchmarks acceptable to the PBGC by product type are listed in the solicitation. |
| 9 | Reporting Requirements | Draft Solicitation | n/a | Does PBGC require a specific reporting format or software, or can firms use existing tools as long as all data fields are covered? | PBGC does not require specific format or software be used for reporting requirements. However, PBGC expects Offerors to have adequate resources to meet reporting requirements outlined in the solicitation and customized as needed. |
| 10 | Evaluation Factors | Draft Solicitation | n/a | Will evaluation place greater weight on fixed income performance, risk management processes, or cost competitiveness? | PBGC considers Factor 4 - Strength of Product Offering to be the most important factor, and all non-price factors, when combined, to be more important than price. (Language in the draft Evaluation Criteria stating that "PBGC considers Factors 4 and 5 to be the most important" was in error. Factor 5 - Price is less important than non-price factors.) |
| 11 | Travel/Onsite Expectations | Draft Solicitation | n/a | Are periodic onsite meetings at PBGC offices required, or is remote engagement acceptable or preferred? | On-site meetings at PBGC are not required. PBGC will conduct in-person visits at least once a year at the Offeror's offices. |
| 12 | Mandate Size Clarity | Draft Solicitation | n/a | Recommend publishing estimated portfolio size and asset range for mandates to assist firms in capacity and resource planning. | PBGC has provided ranges in the solicitation. PBGC will determine actual allocations in the post-award phase. |
| 13 | Cybersecurity Standards | Draft Solicitation | n/a | Recommend specifying applicable federal cybersecurity standards (e.g., NIST, FedRAMP) to set clear data security expectations. | There are no Government-specific cybersecurity standards here. PBGC does not believe that NIST or FedRAMP apply. |
| 14 | Past Performance | Draft Solicitation | n/a | Recommend clarifying if PBGC will accept international investment management experience or restrict to U.S. federal client experience. | Experience is not restriced to U.S. federal client experience. |
| 15 | Solicitation Timeline | Draft Solicitation | n/a | Recommend providing a minimum 30-day response window after final solicitation release to accommodate registrations and proposal preparation. | The solicitation will be divided into distinct phases, which, in total, will give offerors over 30 days in which to respond. SAM registration is not required until price proposals are submitted, which will be the final submission requirement. |
| 16 | Proposal Instructions | Attachment 1: DRAFT Instructions to Offerors | Section 7.c., page 4 | Are we allowed to submit two different Credit approaches (such as Intermediate Credit and Core Credit) as long as we limit the number of products that we submit to four? | No, each proposal may contain only up to one of each product type. Each offeror may submit only a single proposal. |
| 17 | Fees | Attachment 3: DRAFT Statement of Work | Section 3, page 2 | Will the PBGC provide a specific account size to use for pricing given that a range of potential asset sizes have been provided? | PBGC will not provide specific account sizes. Offerors are encouraged to submit price proposals on a best efforts basis taking into account the asset size ranges provided in the solicitation. PBGC will determine actual allocations in the post-award phase. |
| 18 | Product Qualifications | Attachment 6: DRAFT Solicitation Phase 1 Forms | A. Pg 3 | For the Core Fixed Income product, would the PBGC consider a core bond plus approach, which includes allocations to high yield, or below-investment-grade, and non-US allocations? | PBGC will amend the solicitation langauge to clarify that PBGC will consider Core Plus strategies as long as they are benchmarked agains the Bloomberg U.S. Aggregate Index. |
| 19 | Product Qualifications | Attachment 6: DRAFT Solicitation Phase 1 Forms | G. Page 7 | If we submit a proposal for 50%/50% Blend for Emerging Market Debt, would we be considered for a Local Currency or Hard Currency mandate if the PBGC decides to move away from using a 50%/50% Blend approach? | PBGC will limit the evaluation to one proposal per product type. |
| 20 | Product Qualifications | Attachment 6: DRAFT Solicitation Phase 1 Forms | A. Page 9 | For the Global Fixed Income search, our Global Aggregate approach doesn’t have a GIPS-compliant performance composite for hedged-only mandates. Our standard composite is unhedged and we have a broader composite which includes hedged, unhedged, and partially hedged mandates. Will you accept either of these composites? If the unhedged composite is acceptable, this does include a tax-exempt representative hedged portfolio as US-based clients tend to prefer a full or partial hedge, however the composite remains applicable as a representation of investor skill over time in this approach. | Yes. PBGC will amend the solicitation language to clarify that submissions for products managed against the Hedged or Unhedged versions of the Bloomberg Global Aggregate index are acceptable. If a submission references an unhedged product, the firm must demonstrate ability to run the strategy on a hedged basis. |
| 21 | Product Qualifications | Attachment 6: DRAFT Solicitation Phase 1 Forms | A. Page 12 | Should the alpha column in table 3 be geometric excess returns ( [(1+ portfolio return)/(1 + BM return)] -1 ), as required by Section G. of the Product Qualification Form, or arithmetic excess returns (portfolio return – BM return)? | The Alpha column in Table 3 should be geometric excess returns as required by section G. PBGC will amend the table for clarity. |
| 22 | Product Qualifications | Attachment 8: DRAFT Data Table Templates | Table 1 | For the Key Rate Duration labels provided in Columns J through N, should we include any duration exposures below 2 years in the 2 year column? And likewise, should we include any durations above 20 years in the 20-year category? If not, how should we treat duration exposures that do not fall squarely within the 5 key rate duration options (2, 3, 5, 10, and 20) provided? | Please see revised tables. |
| 23 | Product Qualifications | Attachment 8: DRAFT Data Table Templates | Table 1 | Is it permissible to tailor the Key Rate Duration buckets to best represent the product? | Table for product characteristics should be completed as presented. Fields should be marked as N/A where appropriate. |
| 24 | Product Qualifications | Attachment 8: DRAFT Data Table Templates | Table 2 | Should table 2 be stated in market value terms or another metric (ie CTD, CTSD, CTDTS)? | This table should be completed on a market value basis. |
| 25 | Tax-exempt account requirement | Attachment 6: Solicitation Page 1 Form | Page 3, Section C | Can we submit a tax-exempt carve-out of a broader fixed income strategy to fulfil the requirement of having at least one tax exempt account with at least $100 million USD invested in the qualifying product (strategy or composite) as of 6/30/2025? | PBGC will amend the solicitation and remove this reference from mandatory requirements. |
| 26 | Cover Letter Requirements | Attachment 1 | P. 1 / Section 1 & P. 4 / Section 7 / Subsection a | 1. Adherence to Instructions: Offerors must comply with FAR 52-212-1 which includes cover letter requirements that differ from those outlined in 7. Detailed Proposal Instructions a. Cover Letter. Should we follow the Cover Letter instructions listed in 1. Adherence to Instructions over the requirements in 7. Detailed Proposal Instructions a. Cover Letter? | Offerors must comply with both provision 52.212-1 and the addendum Instructions to Offerors located at Attachment 1. Note that Section 7.a. of Attachment 1 is specific to the cover letter requirements, but paragraph (b) of 52.212-1 refers to the proposal as a whole. While there is significant overlap between the two, PBGC intentionally omitted certain items from the cover letter. For example: |
* the "technical description" identified at 52.212-1 (b)(3), which is covered by Attachment 1 at section 7.c;
* the "terms of any express warranty" identified at 52.212-1(b)(5), which does not apply to these services; and
* "price and any discount terms" at 52.212-1 (b)(6), which is covered by Attachment 1 at section 7.g.
PBGC will consider tailoring provision 52.212-1 to clarify.
| 27 | Phase I - Pass/Fail Assessments | Attachment 2 | P. 2 / Section d / Subsection i | If an Offeror meets the minimum criteria in Phase 1 with at least 2 products, but has other products that do not meet the minimum criteria, it appears that offeror can advance to Phase 2. Is that correct? | Yes, this is correct. | |
| 28 | Phase I - Pass/Fail Assessments | Attachment 2 & Attachment 6 | [Attachment 2 - P. 2 / Section d / Subsection i] | |||
| [Attachment 6 - P. 2, 5, 8, 11, 14] | If an Offeror has at least 2 products that meet the minimum criteria in Phase 1, how should other products that do not meet their minimum criteria be submitted? Attachment 6 allows for Yes / No answers in the Product Qualifications Form but the signature line requires the Offeror to certify that all qualifications are met. | PBGC will amend the forms to clairfy that vendors are only required to attest that all qualifications are met at the overall proposal level (i.e., that at least two products meet all qualifications). | ||||
| 29 | Contract Awards | Attachment 2 | P. 3 / Section 2 / Subsection b | Paragraph 2 reads “Each contract award will include all products proposed by that offeror at fair and reasonable prices.” Does this mean that Offerors will be awarded either everything they submit for, or none? Could the PBGC elect to hire a manager for a subset of products submitted? | Yes, the decision will be "all or nothing" among products with fair and reasonable prices. By "all," PBGC means that the proposed products will be within the scope of the ensuing contract. PBGC may or may not fund and utilize all products. | |
| 30 | Performance Data | Attachment 6 | P. 3, 7, 10, 13 / Minimum Requirement G. | We typically report performance data such as Information Ratios on a gross of fee basis. However, our compliance department requires net of fee data be provided as well. The net of fee data typically reflects the maximum fee that any client pays and is a higher fee than PBGC would pay for mandates of the proposed size. Can you please advise on how we should incorporate the additional net of fee performance data? Is it permissible to show the net of fee data in the cover letter or as an addition to the spreadsheet? | Offerors may also submit net-of-fee performance data to satisfy any internal compliance requirements. PBGC will not evaluate net-of-fee performance. | |
| 31 | Product Minimum Qualifications | Attachment 6 | P. 3, 6, 9, 12 / Minimum Requirement B. | Is the $1B threshold for each product (Section B in Product Qualifications Form) the AUM as listed in a composite or can it be strategy assets we use in reporting? | The $1B threshold can be met either on a standalone composite basis or by combining AUM for composites benchmarked against the same benchmark. | |
| 32 | Product Minimum Qualifications | Attachment 6 | P. 3, 6, 9, 12 / Minimum Requirement C. | Do non-US tax exempt institutional accounts (i.e. that are tax-exempt in their own jurisdictions) apply for the $100M minimum requirement? | PBGC will amend the solicitation and remove this reference from mandatory requirements. | |
| 33 | Data Table Templates | Attachment 8 | Tab 10 | Are there intended to be two Table 10 tabs in the Attachment 8 excel file? | No. This is an error and will be corrected. | |
| 34 | Product Minimum Qualifications | Attachment 2 | P. 2 / Section d / Subsection i & P. 3 / Section b | Please clarify the process for submitting a strategy in Phase 1 that does not meet the Minimum Qualifications when the Offeror has at least 2 strategies that do meet their respective Minimum Qualifications. Specifically, the offeror is asked to certify the product meets all of the qualifications, however, the proposal indicates that products that do not meet the qualifications may be submitted if the Offeror has at least 2 other products that do. | PBGC will require that vendors attest that all qualifications are met at the overall proposal level. | |
| 35 | Global Fixed Income | Attachment 6 | P. 9 | We have a Global Fixed Income strategy that is managed on an unhedged basis and benchmarked to the Barclays Global Aggregate Unhedged Index. Given our ability to manage the FX risk of this, we have a simulated Hedged return for our strategy. Could we submit that? | Yes. PBGC will amend the solicitation language to clarify that submissions for products managed against the Hedged or Unhedged versions of the Bloomberg Global Aggregate index are acceptable. If a submission references an unhedged product, the firm must demonstrate ability to run the strategy on a hedged basis. Simulated returns are not acceptable. | |
| 36 | Investment & Firm Data | Attachment 7 | Unless otherwise stated, should information requested be as of 6/30/25 across all documents, specifically for Attachment 7 Phase 2 forms? | Yes, all data should be presented as of 6/30/2025 unless otherwise noted. | ||
| 37 | Product Qualifications | Attachment 1 | P. 4 / Section 7 / Subsection c | What is the maximum number of strategies that can be submitted? Is it four? | Up to four per proposal, and no more than one per product type. | |
| 38 | EMD Strategy | Attachment 6 | P. 12 | Is PBGC considering separate Hard Currency, Local Currency, and Blend managers for the EMD portion of this proposal? Or does the PBGC team have a preference for a particular strategy? | Yes, PBGC is considering all EMD products listed in the solicitation. | |
| 39 | Product Qualifications | Attachment 6 | Beyond our standard strategies that we plan to submit proposals for, our investment teams also manage customized strategies across all four Fixed Income products. Should we include information on our ability to customize our strategies within each product proposal? | Yes, PBGC encourages vendors to fully describe their capabilities. | ||
| 40 | Product Minimum Qualifications | Attachment 6 | P. 3, 7, 10, 13 / Minimum Requirement G. | Would PBGC consider implementing a band / range or a shorter time period for the Information Ratio Minimum Qualifications, rather than maintaining a single minimum threshold for each product? Adopting a wider range or band would enable a broader set of competitive participants in the search. | No, vendors should follow calculation instructions as outlined in the solicitation. | |
| 41 | Fixed Income Mngmt | Solicitation Phase 1 Forms | Pg 2, Item C | Why can't required firm AUM be $25-$50bln at lower allocation sizes of $250mm? | This consideration is outside the scope of this solicitation. | |
| 42 | Minimum Qualifications - Tax Exempt Institutional Investor | Attachment 6 - Solicitation Phase 1 Forms | Page 6, Question C | We have non-US insurance client accounts within our products that are above $100m USD. We manage the portfolios without consideration to any tax status or tax liabilities. Would these accounts count towards the PBGC’s $100m+ tax-exempt institutional account qualification requirement? | PBGC will amend the solicitation and remove this reference from mandatory requirements. | |
| 43 | Key Rate Duration | Attachment 8 - Draft Data Table Templates | Table 1 | In Table 1 of Attachment 8, Key Rate Duration data is requested for the portfolio and benchmark. Would you please confirm if the KRD should be expressed as market value of the portfolio or as the contribution to duration from each bucket? | KRDs should be expressed on a market value basis. | |
| 44 | Tax Exempt Clients | Attachment 6: Solicitation Phase 1 Forms | All Products | Can you confirm whether tax exempt clients for product requirements need to be US-based? | PBGC will amend the solicitation and remove this reference from mandatory requirements. | |
| 45 | Submission Timeline | Attachment 1: DRAFT Instructions to Offerors | Page 3, Table 1 | Can you confirm that Volume 3 of Phase 2 will be due after Volume 2 of Phase 2? And will those due dates be provided upon the official release? | Yes, both understandings are accurate. | |
| 46 | Coverletter & Contract | Attachment 5: DRAFT Contract Clauses and Solicitation Provisions & Attachment 1: DRAFT Instructions to Offerors | Full Contract | We understand that the cover page should contain a statement explaining the extent to which we can agree to the terms and conditions of the solicitation. Could you please clarify how any comments to the provided contract (Attachment 5) should be formatted (i.e., marked in the original document or outlined in a separate document)? | Within the cover letter, offerors should reference the term or condition as specifically as possible (e.g., by providing the clause number or page and section number, as appropriate), quote the language they take exception to, the reason why, and provide the conditions of their offer. | |
| 47 | Disaster Recovery Requirements | Attachment 3 – Statement of Work | Part II – Tasks, 2.4 – Disaster Recovery Requirements (& Part IV – Deliverables, 2 – Summary of Deliverables) | We consider our disaster recovery/business continuation plan and test results to be proprietary and confidential. Would it be acceptable to provide summaries on request or in a due diligence questionnaire meeting? | This is a post-award requirement. PBGC is not mandating the disclosure of confidential information. | |
| 48 | Deliverables | Attachment 3 – Statement of Work | Part IV – Deliverables, 2 – Summary of Deliverables | |||
| Policy on Creditors Committee participation and list of participating personnel | We do not have a formal written Policy on Creditors Committee participation. Can we describe our process on how we decide when and whether to join Creditors Committees in a due diligence questionnaire meeting? | This is a post-award requirement. If a specified policy does not exist, vendors are still expected to be able to describe the firm's process of handling occurences on an ad-hoc basis. | ||||
| 49 | Information Ratio Requirement | Atatchment 6 - Solicitation Phase 1 Forms | Product Qualifications Form - Credit Fixed Income (Page 7, Item G) | Is there room to reconsider the rolling 60-month average Information Ratio requirement for the Credit Fixed Income product? This track record period in the first rolling 60-month average composite information ratio will likely include the Covid induced market selloff. Certain track records could be long enough to exert the maximum unprecedented shock from Covid. | No, vendors should follow calculation instructions as outlined in the solicitation. | |
| 50 | Investment Restrictions | Attachment 3 - DRAFT Statement of Work | Page 2 Section 3 | Can the PBGC provide additional context around the statement "avoid securities of companies with underfunded pension plans that the PBGC is likely to terminate"? Will the PBGC provide a list or examples? | PBGC expects Offerors to exercise best efforts to select securities suitable and appropriate to PBGC's corporate |
objective and status as a U.S. Government agency. Diligent effort shall be exercised to avoid the purchase of a security of an issuer that is likely to terminate an underfunded pension plan insured by
PBGC.
| 51 | Investment Guidelines | Attachment 3 - DRAFT Statement of Work | Page 5 Section 2.1.1.6 | At what stage will the PBGC provide investment guidelines for the specific mandates referenced in this RFP? | Guidelines are negotiated on a portfolio basis post award. |
| 52 | General | N/A | N/A | At what point will the PBGC be willing to share a draft IMA with prospective contractors? | Guidelines are negotiated on a portfolio basis post award. |
| 53 | LeapFile Submission | Attachment 1: DRAFT Instructions to Offerors | Page 2 / Section 5 | Are there alternatives to submitting through LeapFile? What if our technology systems do not support us to use LeapFile? Are we able to use Lockbox instead? | Yes, PBGC will consider alternative delivery methods on a case-by-case basis. LeapFile is convenient and secure, but if this option is unavailable to any offerors, they should reach out to the PBGC points of contact to discuss alternatives. |
| 54 | Separate Performance for Each Suggested Index | Attachment 6: Solicitation Phase 1 Forms | Page 6 / Section F | “Offerors shall propose a minimum of two, and no more than four, financial products among Core, Credit, Global, and Emerging Markets Debt.” – Within Attachment 6 of the “Product Qualification Form” subsection F, which asks for performance history. Should proposers provide separate performance for each suggested index within the Credit and Emerging Market Debt sections where they meet the minimum requirements? | No, vendors should submit for consideration one product for each product category. |
| 55 | Supporting Materials Naming Convention | Attachment 1: DRAFT Instructions to Offerors | Page 6 / Section 7D | Will the PBGC provide a naming convention or example for labeling supporting documents? | We will consider it. We initially decided to leave it flexible to avoid being overly prescriptive. |
| 56 | Potential OCI Examples | Attachment 1: DRAFT Instructions to Offerors | Page 6 / Section 7E | Can the PBGC provide examples of what it considers a “potential” OCI? | According to the FAR, "An [OCI] may result when factors create an actual or potential conflict of interest on an instant contract, or when the nature of the work to be performed on the instant contract creates an actual or potential conflict of interest on a future acquisition." Illustrative (non-exhaustive) examples are found at FAR 9.508. |
The Government's primary concerns are preventing (1) the existence of conflicting roles that might bias a contractor's judgment, and (2) unfair competitive advantage. If an offeror believes that even the appearance of such an OCI does (actually) or could (potentially) occur with respect to this acquisition, that offeror must submit an OCI Risk Mitigation Plan. Ultimately, this is a question of judgment and common sense for both the offeror and PBGC.
| 57 | Fidelity Bond Insurance | Attachment 3: DRAFT Statement of Work | Page 7 / Section 2.3.1 | We are able to meet the requirement 2.3.1. That said, given the size of our firm’s balance sheet, we would like to know if there is flexibility to adjust certain parameters of the policy limits (i.e. removal of the deductible)? | No, there is no such flexibility. | |
| 58 | Changes in Federal Regulations / Executive Orders during Contract Term | Attachment 5: DRAFT Contract Clauses and Solicitation Provisions | N/A | How will the PBGC handle changes in federal regulations or Executive Orders during the contract term? | Once the contract is awarded, the terms are final except in very rare events in which the FAR Council or Congress instructs otherwise, or if the contract parties otherwise agree to a change. | |
| 59 | Updated Clauses | Attachment 5: DRAFT Contract Clauses and Solicitation Provisions | N/A | Are there any clauses that PBGC expects to update before final RFP release? | PBGC expects some changes as a result of the legal review process and any FAR updates that occur between now and solicitation release, but cannot identify anything specific at this time. | |
| 60 | New Clarifying Questions | N/A | N/A | Will PBGC allow for clarifying questions after Phase 1 submissions if new issues arise? | Yes, PBGC anticipates allowing Q&A periods at each phase. | |
| 61 | Minimum Qualifications | Attachment 6: Solicitation Phase 1 Forms | Page 1, 2nd paragraph | The instructions state, "At a minimum, offerors must submit three forms in this phase: the Offeror Qualifications Form and at least two (2) of the following Product Qualifications Forms" As it relates to the Product Qualifications Forms, there are many firms that meet all the minimum qualifications for one (1) product, but may not meet the minimum qualifications for at least two (2) of the listed products. Will PBGC consider amending this requirement to allow firms to participate if they only meet the minimum qualifications of one (1) of the listed products? | No. | |
| 62 | Minimum Qualifications | Attachment 6: Solicitation Phase 1 Forms | Page 2, Section C | This Offerer qualification states, "The firm has at least $500,000,000,000.00 in Assets Under Management (AUM) as a fiduciary." Will PBGC consider lowering the minimum AUM to expand the opportunity set and allow smaller qualified firms to compete for the mandate? | No. This consideration is outside the scope of this solicitation. | |
| 63 | Core Fixed Income Product Proposal | Attachment+6+-+DRAFT+Solicitation+Phase+1+Forms | p.3, Product Qualifications Form - Core Fixed Income | We would propose that the PBGC considers breaking down the Global Aggregate exposure into its underlying components (government, credit, securitized, etc.) and have respective managers propose their capabilities to manage individual pieces. We believe that breaking the proposed strategy out into invidiual components would give the PBGC the flexibility to over/underweight different components of the Agg and retain greater control over their risk exposure at any given point in time, should they want to. We have seen other large clients of the firm dis-aggregate multi-sector exposures in this way. | This approach does not meet PBGC's requirements at this time. | |
| 64 | Overall Product Proposal | Attachment+6+-+DRAFT+Solicitation+Phase+1+Forms | p.1, Instructions | We would suggest that given the current credit market environment and corresponding growth in systematic fixed income investing, the PBGC should consider carving out an allocation to a systematic manager for one or more of the four exposures outlined in the Soliciation Document, in addition to fundamentally focused strategies. | This approach does not meet PBGC's requirements at this time. | |
| 65 | Product Qualification | Attachment 6: Solicitation Phase 1 Forms | Page 6, section B | Does the GIPS composite have to have over $1 bn in order to meet the minimum asset qualification? | ||
| In a few instances, we have over $1bn invested in an overall strategy, but not necessarily in each individual composite as some strategies hold accounts which can’t fit into the same composite due to client restrictions. | The $1B threshold can be met either on a standalone composite basis or by combining AUM for composites benchmarked against the same benchmark. | |||||
| 66 | # of Product Offerings | Attachment 6: Solicitation Phase 1 Forms | Page 1 | Would PBGC permit an asset manager to submit only one qualifying product, rather than the two products currently required? | No. | |
| 67 | Company AUM | Attachment 6: Solicitation Phase 1 Forms | Page 2 | The solicitation specifies that offerors must have at least $500 billion in firm-level assets under management. Would PBGC consider lowering this requirement in order to broaden the pool of qualified managers, particularly for firms with strong institutional experience and significant product-level AUM in the requested strategies? | No. | |
| 68 | Credit Fixed Income Benchmark | Attachment 6: Solicitation Phase 1 Forms | Page 6 | How strict is the requirement that a Credit Fixed Income strategy be managed against one of the specified Bloomberg credit indices? Must the strategy’s primary benchmark be one of these indices, or would PBGC also accept proposals for strategies managed to a total return target (e.g., cash + 4%) | Yes, the proposed product must be managed against one of the benchmarks stipulated in the solicitation. | |
| 69 | Credit Fixed Income Investment Universe | Attachment 6: Solicitation Phase 1 Forms | Page 6 | Are there any restrictions on the investment universe, such as required exclusions or limits on allocations to specific asset classes? | Specific guideline paramaters are negotiated for each portfolio post award. | |
| 70 | Benchmarks | Attachement 6 | Page 7/10/13, Question G | The instructions for the mandatory minimum IR comparison for each of Credit, Global Aggrate and EMD is the US Aggregate. Is this correct, or should the IR be compared against the relevant benchmark noted in each respective Question A? For example, should the IR for Global Agg be measured against US Aggregate or Bloomberg Global Aggregate Hedged Index? We would reccomend the test be against the product's own benchmark. | This has been corrected in an amendment to the solicitation. | |
| 71 | Benchmarks | Attachement 6 | Page 6, Question A | Is the Bloomberg Long U.S. Corporate Bond Index in scope for the credit fixed income mandate? We see that the plan has exposure to long credit/corporate managers and it is unclear if the benchmark given (Bloomberg Credit Index, Bloomberg Corporate Index) is specific to the standard/full spectrum index or also to include the separate "Long" index? | The Bloomberg Long U.S. Corporate Bond Index is not in scope. | |
| 72 | AUM | Attachement 6 | Page 12, Question C | Would an institutional separate account for an insurance company be an acceptable client to meet the AUM test, or is it necessary to have a tax-exempt client? Do these need to be US entities? We would recommend that all insitutional separate account clients, where the client is an asset owner, be considered for the AUM test, regadrless of tax-status or domicile. | PBGC will amend the solicitation and remove this reference from mandatory requirements. | |
| 73 | AUM | Attachement 6 | Page 12, Question C | Certain of our instituional clients have investment restrictions (ie: ESG) which keep them out of the main composite, however they share a similar benchmark and objective. We would need to look to one of these to meet the AUM test, would this be acceptable? | This would be acceptable as long as the benchmark is the same as the proposed product. The $1B threshold can be met either on a standalone composite basis or by combining AUM for composites benchmarked against the same benchmark. | |
| 74 | Attachement 6 | Page 13, Question G | Further to 4, above, our strategy had a change to the approach and portfolio managers that are in place today While the main composite retains the full track recod of the startegy prior to the changes, certain accounts are more representative of the current approach - which targets IR. We would propose to provide data which supports the IR test from the date of this change. Would such an approach be acceptable? | No, PBGC will have to evaluate the IR track record of the product as per the instructions in the solicitation. | ||
| 75 | Minimum Qualifications | Attachement 6 | Page 1 | Regarding the below minimum requirment - can you confirm if we are required to submit at least two products for this RFP? At a minimum, offerors must submit three forms in this phase: the Offeror Qualifications Form and at least two (2) of the following Product Qualifications Forms: • Core Fixed Income |
• Credit Fixed Income
• Global Fixed Income
| • Emerging Market Debt | Yes, vendors are required to propose at least two products for this RFP. | |||||
| 76 | Minimum Qualifications | Attachement 6 | Page 2 | Is the AUM requirement final? We manage north of $240B in AUM as a firm and have partnered with large institutions of similar size. We also manage at least $1,000,000,000.00 USD as of 06/30/2025 in the proposed Core Fixed Income product. | PBGC confirms the requirement that offerors must manage a minimum of $500 billion in AUM. | |
| 77 | Offeror Qualifications Form | Attachment 6: Solicitation Phase 1 Forms_Amendement 1 | 2 / Section C | We took note of the $500 billion AUM threshold for managers and wanted to confirm the accuracy of this number. When we bid for the existing contract, the number was $50 billion. If $500 billion is the new threshold will there be any consideration given to existing PBGC managers who fall under this AUM number? | PBGC confirms the requirement that offerors must manage a minimum of $500 billion in AUM. PBGC will not vary the requirement. |
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