20240523 eDiscovery RFP_Read Me First_Amendment 002.pdf

RFP. No. FDIC-LEGAL-2024-001

Federal Deposit Insurance Corporation 3501 Fairfax Drive, Arlington, VA 22226-3500 Legal Division

REQUEST FOR PROPOSALS 1

FOR 2

DATA HOSTING EDISCOVERY PROVIDERS 3

AMENDMENT 0021 4

1.0 Executive Summary & Key Information. 6

This request for proposals (RFP) is issued by the Federal Deposit Insurance Corporation’s 8 (FDIC) Legal Division. This RFP solicits proposals from all interested and capable cloud-based 9 data-hosting eDiscovery companies to serve as the FDIC’s primary eDiscovery vendor(s). 10

The FDIC anticipates awarding 3 Basic Ordering Agreements (BOAs or Agreements) from 12 this RFP, each with a 5-year ordering period. The FDIC reserves the right to make more or fewer 13 than three awards. The FDIC anticipates making these awards in August 2024. 14

Due Date for Proposals: Proposals are due no later than 30 days after the issuance of this 16

RFP. 17

Agency Contacts: Questions about this RFP should be directed to 19 FDIC Counsel Charles McCarthy (cmccarthy@fdic.gov) and 20 Senior Attorney Michael Pangia (mpangia@fdic.gov). 21 The due date for questions was May 9, 2024 at 3:00 p.m. ET. 23

Eligibility to Bid: This RFP has 3 eligibility criteria, which vendors must satisfy in 25 order to be able to have their proposals considered: 26

• Eligibility Criterion 1: All of the Vendor’s managed hosting and processing of FDIC 28 electronically stored information must (at the time of proposal submission and during 29 BOA performance) be either: 30 o 1.A. performed by a solution/tool that has a Federal Risk and Authorization 32 Management Program (FedRAMP) moderate impact level authorization 33 (FDIC Preferred Approach), 34 or 35 o 1.B. IF proposed solution/tool does not have a current FedRAMP moderate 36 authorization, THEN the hosting and processing of FDIC electronically stored 37 information is performed (1) entirely within a FedRAMP moderate impact 38 level authorized environment, and (2) by a solution/tool that meets the 39 requirements of, and has implemented, NIST 800-53 Rev5, moderate, as 40 validated by an independent third-party assessor. (Less preferred approach) 41

1 Amendment 001 consisted solely of the 1-page FDIC form 3700/56, posted to SAM.gov on May 13, 2024, which extended the due date for proposals to June 3, 2024.

RFP. No. LEGAL-2024-001 2 o Note, this RFP contains a process to request a waiver from this requirement 43 during the Q&A period for compelling circumstances. For example, if an 44 interested vendor was already involved in and had substantially completed the 45 FedRAMP certification process, the FDIC may (but is not required to) 46 consider a waiver under those circumstances. 47

• Eligibility Criterion 2: Vendors must be registered in SAM.gov at the time of 49 proposal submission and must have an “Active” SAM registration by the time of 50 award. See https://www.sam.gov for information on registration. 51

• Eligibility Criterion 3: Vendors must be willing to accept the FDIC’s agreement 53 terms. See Attachment 1, Basic Ordering Agreement. (For example, the Vendor 54 must be willing to invoice the FDIC monthly in arrears, rather than be paid at the time 55 of service). 56

2.0 Background. 58

2.1 About the FDIC. 60

The FDIC is a mixed-ownership government corporation and independent agency of the 62 federal government. Congress created the FDIC under the Banking Act of 1933 to maintain 63 stability and public confidence in the nation’s financial system by insuring deposits, examining 64 and supervising financial institutions, and managing receiverships of failed banks. The FDIC 65 operates in three distinct capacities: corporate, receivership and conservatorship. This RFP is 66 being issued, and the Basic Ordering Agreements are being awarded, in the FDIC’s corporate 67 capacity. Task Orders may be issued in any of the FDIC’s capacities, to be determined at the 68 time of Task Order award. 69

2.2 About the FDIC Legal Division and the Contracting Process. 71 The FDIC is neither an executive branch agency, nor funded by appropriated funds. The FDIC 73 also has independent statutory authority for entering into contracts, 12 U.S.C. § 1819(a). The 74 FDIC’s Legal Division ensures FDIC’s adherence to laws and regulations, interprets laws for and 75 provides advice to FDIC divisions and offices, identifies and assesses risks to the FDIC, and 76 represents and advocates for the FDIC. Relevant to this RFP, the FDIC Legal Division also 77 contracts for legal services and legal support services and has its own delegated procurement 78 authority. 79

For the reasons stated above, the FDIC Legal Division and this RFP are not governed by the 81

Federal Acquisition Regulation nor by the FDIC’s Acquisition Procedures and Guidance 82 Manual. This procurement of eDiscovery vendors is governed primarily by the terms of this RFP 83 and the Legal Support Services Deskbook. In the event of conflict between this RFP and the 84 Deskbook, the terms of the RFP control; once the Agreements are awarded, they control over 85 any conflicting terms of the Deskbook. For clarity, the following government procurement laws 86 and policies do not apply to this procurement: 87 https://www.fdic.gov/formsdocuments/apgm.pdf https://www.fdic.gov/formsdocuments/apgm.pdf https://www.fdic.gov/about/doing-business/legal-support-services-deskbook/

RFP. No. LEGAL-2024-001 3

• Office of Federal Procurement Policy Act 90

• Competition in Contracting Act 91

• Federal Acquisition Streamlining Act 92

• Contract Disputes Act 93

• Federal Acquisition Regulation 94

• FDIC Acquisition Procedures & Guidance Manual (APGM), except for the specific 95 contract clauses that are expressly incorporated by reference in the awarded Agreements. 96 The Legal Division’s Legal Services and Special Contracts Group (LSSCG) is, functionally, 97 the “contracting office” for this procurement. The Legal Division’s eDiscovery Group (eDG) is, 98 functionally, the program office/requiring activity for this procurement. Within the FDIC’s Legal 99 Division, eDG is responsible for managing and coordinating legal support services at the FDIC 100 relating to electronically stored information (ESI) and for the full spectrum of the FDIC’s 101 eDiscovery needs. 102

2.3 About the Awarded Contracts. 104

Based on vendors’ ability to meet the criteria set forth in this RFP – as demonstrated by 106 written proposals – certain qualified vendors will be selected to execute a BOA. The “ordering 107 period” of the awarded BOAs will be 5 years, meaning the FDIC may issue Task Orders 108 (normally on a competitive basis) for the full spectrum of the FDIC’s eDiscovery needs over the 109 5-year ordering period. 110

An awarded BOA itself is not a contract. Rather, a BOA is a written instrument of 112 understanding between the FDIC and the Contractor for future delivery of unspecified quantities 113 of goods or services. A BOA becomes a binding contract when a Task Order is issued (the Task 114 Order and BOA terms, together, form the contract terms for any given work the Contractor 115 performs). Importantly, award of a BOA itself is not a guarantee that any Task Orders will be 116 awarded to an individual vendor. 117

3.0 Agreement Scope. 119

The purpose of this RFP is to obtain best-in-class eDiscovery cloud-based managed hosting 121 and processing of ESI that may be required by the FDIC, to include during investigations, 122 inspections, examinations, and/or litigation. Although this RFP’s primary objective is to obtain 123 secure data hosting, any awarded BOA(s) will be broadly scoped to include services in relation 124 to any phase of the eDiscovery reference model (EDRM), an industry-standard approach to ESI 125 that incorporates the following phases: information governance, identification, preservation, 126 collection, processing, review, analysis, production, and presentation. 127

The scope of awarded BOA(s) includes, but is not limited to: 129

• managed data hosting, database creation, paper document processing, early data 131 assessment tools, analytics, technology assisted review, managed review, and forensic 132 services; 133

• assistance responding to information requests from many sources, including, for example, 135

Congressional requests for information, third-party subpoenas and audits, FOIA requests, 136 and internal and external investigations; and 137

RFP. No. LEGAL-2024-001 4

• providing assistance to FDIC Legal Division personnel and FDIC outside counsel and 139 other legal support providers to preserve, collect, process, review, analyze, produce, and 140 host electronically stored information as part of unofficial or official discovery in a 141 lawsuit or investigation. 142

More information on the Agreement scope and desired services is contained in BOA 143 Attachment A, Statement of Objectives. 144

4.0 Proposal Instructions and Requirements. 146

4.1 Intention to Bid. 148

Vendors that anticipate submitting a proposal should notify (via email) the FDIC points of 150 contact listed in paragraph 4.2 below of their intention to bid no later than May 9, 2024 at 151 3:00 p.m. ET. While submitting a notice of intent to bid is not mandatory (and the FDIC will 152 accept proposals from vendors that did not previously declare an intention to bid), submitting 153 an intent to bid is in a vendor’s interest and will ensure the vendor continues to receive the 154 most up-to-date information about the RFP. 155

4.2 Proposal Due Date and Submission Method. 157

Proposals must be submitted by email to Charles McCarthy (cmccarthy@fdic.gov) and 159 Michael Pangia (mpangia@fdic.gov). 160 Proposals must reach the FDIC designated recipients by June 3, 2024 at 3:00 p.m. ET. 162 Absent extenuating circumstances, late proposals are likely to be excluded and not considered 163 for award. Each vendor may only submit a single proposal. 164

4.3 Questions from Offerors. 166

Questions about this RFP should be submitted in writing, via email, to the FDIC points of 168 contact listed in paragraph 4.2 above. The due date for questions was May 9, 2024 at 3:00 169 p.m. ET. The answers to questions of general applicability may be provided to all known 170 interested vendors. 171 Vendors may submit a waiver request for Eligibility Criteria 1 during the Question and 173 Answer period. A waiver request should include sufficient justification to permit evaluation. 174

4.4 Proposal Organization. 176

Volume Name Factor Name Page Limit Administrative Proposal Volume

N/A (Use this volume to provide eligibility criteria information and required Attachments C, D, E, and F)

No page limit, and attachments may be provided as separate digitally-signed documents.

Technical Proposal Volume

Technical Factor

- Capacities Subfactor

- Corp. Experience Subfactor

15 page limit (inclusive of any coverpage, TOC, etc.)

Price Volume Price Factor FDIC provided Excel File (No page limit)

RFP. No. LEGAL-2024-001 5

4.5. Administrative Proposal Volume. 177

In the Administrative Proposal Volume, the vendor shall not include marketing material. The 179 vendor shall include: 180

• The vendors full/legal company name, address, and point(s) of contact for the proposal 181

(email and phone); 182

• Confirmation/proof of Eligibility Criterion 1: FedRAMP MODERATE authorization 184 o If a vendor is proposing a solution/tool that does not have a FedRAMP 185 moderate authorization, submit documentation establishing NIST 800-53 rev5 186 moderate compliance, implementation, and third-party validation for the 187 solution/tool (which will ultimately be required for the ATO process of any 188 non-FedRAMP solution/tool, as set forth in paragraph 9.2.1 of the BOA); 189 o Vendors attempting to meet Eligibility Criterion 1.B. should submit System 190 Security Plan and Security Assessment Report completed within the last 9 191 months form the initial RFP issuance. 192

• Confirmation/proof of Eligibility Criterion 2, SAM.gov registration (a screenshot is 194 acceptable); 195

• Acknowledgement of Eligibility Criterion 3, such as a statement that the vendor has 197 reviewed the proposed Basic Ordering Agreement and agrees to its terms if the vendor 198 is selected for award; 199

• FDIC Contractor Representations and Certifications, BOA Attachment E; 201

• FDIC Representations and Certifications For Legal Support Services Provider, BOA 203 Attachment F; 204

• Confidentiality Agreement (For Contractors/Subcontractors/Consultants), BOA Attachment C; 205

• Confidentiality Agreement (For Contractor/Subcontractor/Consultant Personnel), 206 BOA Attachment D (At the time of proposal submission, a Confidentiality Agreement 207 is only required from the vendor’s FDIC Program Manager/POC; additional 208 Confidentiality Agreements and Background Investigation Questionnaires may be 209 requested around time of award and/or during BOA performance). 210

4.6. Technical Proposal Volume. 212

The vendor’s technical proposal volume shall be divided into two sections, Technical 214 Capability and Corporate Experience. The vendor may divide the available 15 page limit 215 for the volume between these two sections using the Vendor’s own discretion. 216 The Technical Proposal Volume shall not include proposed prices, but the Corporate 218 Experience section will necessarily include pricing and/or contract values for the 219 referenced past experience examples. 220

RFP. No. LEGAL-2024-001 6

4.6.1 Technical Capability Section. 222

In the Technical Capability section, the Vendor shall describe in detail its technical 224 capabilities and product offerings to provide the 9 types of services listed in paragraphs 225 2.1–2.9 of the Statement of Objectives. 226 Vendors should place an emphasis on fully describing the services listed in paragraphs 228 2.1–2.5 of the Statement of Objectives, as these are the most important scope areas to the 229

FDIC. 230

The pre-trial and trial support listed at SOO paragraph 2.7, and the transcription, 232 translation services, and court reporting services listed at paragraph 2.9 are optional 233 agreement scope, meaning it is acceptable for a vendor to decline to provide/propose 234 these services. 235 Although the FDIC desires to generally avoid the use of too many subcontractors, a 237 vendor may propose to subcontract one or more of the scope areas listed at 2.3, 2.6, 2.7, 238

2.8 or 2.9 if the vendor does not offer those services. Services proposed to be 239 subcontracted must include the identity of the specific subcontractor as well as pricing (in 240 the pricing volume). 241 The Technical Capability section shall also demonstrate the Vendor’s ability to meet the 243 security requirements of the BOA and the Statement of Objective (SOO). 244

4.6.2 Corporate Experience Section. 246

In the Corporate Experience section of the Technical Proposal volume, the vendor shall 248 demonstrate its capacity to successfully perform the requirements contained in the SOO 249 through the use of past experience examples. In the Corporate Experience section, the 250 Vendor shall submit the following information for up to 3 federal or commercial 251 contracts performed by the proposing vendor within the last 3 years since the initial RFP 252 issue date (April 24, 2024). The vendor may also include up to 1 corporate experience 253 example from a proposed subcontractor (creating the opportunity for a maximum of 4 254 experience examples in a given vendor’s proposal). 255 Because certain types of experience examples may be evaluated more favorably than 257 others, the FDIC recommends the vendor review the evaluation criteria in paragraph 258

5.3.2 when selecting its experience examples. 259 For each experience example, the vendor shall include (or state not applicable): 261

a. Name and type of client (federal or commercial); 263

b. Contract name and number; 264

c. Contract dates (performance start and expiration); 265

d. Type of contract (e.g., cost reimbursement, fixed price, T&M, etc.); 266

e. Client and/or contracting organization (name, phone, and email) 267

f. Best point of contact for a reference check; 268

RFP. No. LEGAL-2024-001 7

g. If a government contract, whether the vendor received an agency Authority to 269 Operate (ATO) and the point of contact for questions about that ATO; 270

h. Contract value by year and total contract value; in the case of contract types 271 where the total contract value is different than the value of the work actually 272 performed, for example ID/IQs and BPAs, also provide the value of the work 273 actually performed to date; 274

i. A description of the contract work, including an explanation of how the nature of 275 the work on this experience example is relevant to the FDIC work described in 276 SOO sections 1.0 and 2.0; 277

j. Size of project (e.g., GBs, number of documents reviewed or produced, number of 278 review attorneys, etc.); 279

k. Cure/show cause notices. Include an affirmative statement whether your firm has, 280 or has not, received any cure notices or show cause notices from the government 281 related to this past performance reference. If such notice(s) have been received, 282 provide a copy of those notice(s) and an explanation of the surrounding 283 circumstances. 284

4.7 Price Proposal Volume. 286

The Pricing Proposal Volume shall consist of the Excel File titled “Pricing Workbook” 288 completed and returned by the vendor in Excel format. 289 The vendor may make minor adjustments to the Pricing Workbook to more accurately match 291 its service offerings, but the vendor shall explain any changes made in the Vendor Notes 292 Column (Column D). 293

The Price Proposal Volume must be aligned with the vendor’s Technical Proposal. 295

The prices provided in the Pricing Workbook shall be “not-to-exceed” prices for the duration 297 of the BOA. The FDIC typically requests Task Order specific pricing when awarding Task 298 Orders and Vendors may offer lower prices for individual Task Orders. Vendors will not be 299 able to bill or charge the FDIC for categories of items or services that are not listed in the 300 Vendor’s price proposal, unless a revised Price Proposal is provided and agreed to in writing 301 by the FDIC prior to performance of the task at the new price. 302

The Price Proposal Volume should not assume a minimum term (e.g., 5 years) for hosting nor 304 a minimum number of GBs/TBs to be hosted. 305

5.0 Evaluation Process and Criteria. 307

5.1 Individualized Communications. The FDIC may award BOAs based on initial proposals 309 received, without communications or negotiations with Vendors. As the Legal Division uses 310 more of a commercial than federal contracting process, the FDIC reserves the right to 311 communicate with some or all of the proposing vendors, if determined to be in the FDIC’s 312 interest. Following receipt of a proposals – and before or after evaluations – the FDIC may 313 inquire verbally or in writing to better understand any vendor’s proposal, including but not 314 limited to any security related considerations, or to request revisions to a vendor’s proposal. 315

RFP. No. LEGAL-2024-001 8

The FDIC is not obligated to contact any individual vendor and the FDIC may 316 contact/communication/negotiate with one vendor, or some vendors, but not others. 317

5.2. General Process. The FDIC will screen proposals for eligibility criteria and general 319 compliance with RFP instructions. Eligibility/compliant proposals will be evaluated in 320 accordance with the below criteria for the Technical Factor and the Price Factor. A proposal 321 may be found ineligible for award for reasons including but not limited to: 322

• Failing to meet Eligibility Criteria; 323

• Failing to comply with RFP instructions; 324

• Receiving lower than an “Acceptable” rating for either of the Technical Subfactors; 325

• Proposing other than fair and reasonable prices (in the FDIC’s assessment); 326

• Other deficiencies identified either in the vendor’s proposal (such as in the 327

Representations and Certifications) or identified when performing diligence on the 328 Vendor; or 329

• Information received from other federal agencies regarding a Vendor’s prior breach of 330 contract, consistently poor performance, or unlawful activity. 331

5.3 Technical Factor Evaluation. The Technical Capabilities Subfactor and Corporate 333 Experience Subfactor will be evaluated separately and each will receive its own rating. 334

5.3.1 Technical Capabilities Subfactor. 336

The Technical Capabilities Subfactor will assess the degree to which the vendor’s 338 capabilities demonstrate an understanding of and ability to meet the technical 339 requirements of this RFP and SOO. 340 The FDIC will evaluate the vendor’s proposed service offerings to meet SOO paragraphs 342 2.1–2.9 and the vendor’s ability to meet IT security requirements. 343 The FDIC will assign strengths, weaknesses, and deficiencies with respect to the 345 Technical Capabilities Subfactor, as well as assign one of the following overall factor 346 ratings: 347

• Outstanding: Vendor’s proposal demonstrates an exceptional approach to 348 providing the services required by the SOO. 349

• Acceptable: Vendor’s proposal demonstrates an adequate approach to providing 350 the services required by the SOO. 351

• Unacceptable: Vendor’s proposal does not demonstrate an adequate approach to 352 providing the services required by the SOO, or does not meet requirements of the 353 RFP, or is otherwise not awardable. 354

5.3.2. Corporate Experience Subfactor. 356

Sources of Information. When evaluating the Corporate Experience Subfactor, the 358 FDIC may use any information available to it, including but not limited to information 359

RFP. No. LEGAL-2024-001 9 submitted by the vendor, information obtained during reference checks, and information 360 personally known to FDIC subject matter experts. 361

• Recency. For the Corporate Experience Subfactor, the FDIC will first evaluate 363 each experience example for recency (that is, some aspect of performance 364 occurred within the 3 years preceding the RFP release). 365

• Relevancy. Next, the FDIC will evaluate the relevancy of each experience 367 example by comparing the experience example of the requirements of the SOO. 368 o All other aspects of an experience example being the same, the FDIC may 369 consider experience examples from federal government contracts to be 370 more relevant than commercial contracts. 371

• Experience Confidence Rating. After assessing each individual experience 373 example for recency and relevancy, the FDIC will assign one overall Experience 374 Confidence Rating for the Corporate Experience Subfactor, using the following 375 rating definitions: 376 o High Confidence. The FDIC has a high expectation that the vendor will 378 successfully perform the required work. 379 o Satisfactory Confidence. The FDIC has a reasonable expectation that the 380 vendor will successfully perform the required work. 381 o Unsatisfactory/Unacceptable Confidence. The FDIC has a low 382 expectation that the vendor will successfully perform the required work. 383

5.4 Price Evaluation. 385

The FDIC will evaluate the fairness and reasonableness of the proposed prices by using 387 methods including but not limited to: 388

• Comparison of the prices proposed by different vendors against each other; 389

• Comparison of proposed prices to prices typically paid by the FDIC for similar 390 services; or 391

• Comparison to known market conditions by subject matter experts. 392

The agency reserves the right to reject a proposal that includes prices that the FDIC believes 394 are out of touch with industry standards. 395 In the FDIC’s discretion, the FDIC’s review of proposed prices may be conducted either at a 397 holistic level (i.e. Workbook level), at a category level (e.g. Managed Data Hosting or 398 Document Services), or at the line-item level. 399

RFP. No. LEGAL-2024-001 10

5.5 Award Decision. 402

Technical capability is of paramount concern to the FDIC and the FDIC may obtain additional 404 price competition at the Task Order level. Therefore, the FDIC’s award decision at the BOA-405 level (i.e., which vendors will receive BOA awards) will be based on the Highest Technically 406 Rated proposals with Fair and Reasonable Pricing. 407 The FDIC encourages minority and women owned business (MWOB) to participate in this 409 contract opportunity and may consider that status as part of its award decision. 410 The FDIC reserves the right not to award one or more SOO scope categories to any given 412 vendor based on undesirable technical ability or pricing. 413 The FDIC reserves the right to consider the cybersecurity posture and FedRAMP 415 authorization status of vendors when making the award decision. All vendors that satisfy 416 Eligibility Criterion 1 will not, necessarily, be evaluated equally in this regard; for example, 417 meeting Criterion 1.A. may be viewed more favorably then meeting 1.B. 418

5.6 Post Award “On-Ramping” of New Vendors. 421

Because the Agreements will have 5-year ordering periods and because technology is rapidly 423 evolving, the FDIC may establish future “open periods” where the FDIC uses this RFP (or a 424 substantially similar RFP) to “on-ramp” additional vendors into the FDIC’s stable of 425 eDiscovery providers. The on-ramp procedure may be used for reasons such as to: 426

• promote further competition at the task order level; 427

• obtain access to a vendor with unique capabilities not already in the BOA vendor pool; 428 or 429

• increase contracting opportunities for minority and women owned businesses 430

(especially those that may not meet Eligibility Criteria at the time of initial RFP 431 release). 432

In sum, regardless of the number of initial awardees, the FDIC reserves the right to on-ramp 434 additional BOA awardees at any time during the BOA’s ordering period. 435

6.0 Attachments 437

RFP Attachment 1 Basic Ordering Agreement for Legal Support Services (for vendor 439 review, not required to be submitted with proposal) 440

RFP Attachment 2 FDIC Responses to Vendor Questions 441 BOA Attachment A Statement of Objectives (for vendor review, not required to be 442 submitted with proposal) 443 BOA Attachment B Pricing Workbook (required part of proposal) 444 BOA Attachment C Confidentiality Agreement (For Contractors/Subcontractors/Consultants) 445

(required part of proposal) 446

RFP. No. LEGAL-2024-001 11

BOA Attachment D Confidentiality Agreement (For 447 Contractor/Subcontractor/Consultant Personnel) (required part of 448 proposal for Program Manager/POC) 449

Below listed Attachments E-H made available online and incorporated by reference 450 BOA Attachment E FDIC Contractor Representations and Certifications (required part 451 of proposal) https://www.fdic.gov/formsdocuments/f3700-04a.pdf 452 BOA Attachment F FDIC Representations and Certifications for Experts and Legal 453

Support Services Providers (required part of proposal) 454 https://www.fdic.gov/formsdocuments/f5210-09.pdf 455

BOA Attachment G Background Investigation Questionnaire for Contractors (not 456 required part of proposal; to be completed at FDIC request) 457 https://www.fdic.gov/formsdocuments/f1600-07.pdf 458

BOA Attachment H Background Investigation Questionnaire for Contractor Personnel 459 and Subcontractors (not required part of proposal; to be completed 460 at FDIC request) https://www.fdic.gov/formsdocuments/f1600-461 04.pdf 462 https://www.fdic.gov/formsdocuments/f3700-04a.pdf https://www.fdic.gov/formsdocuments/f5210-09.pdf https://www.fdic.gov/formsdocuments/f1600-07.pdf https://www.fdic.gov/formsdocuments/f1600-04.pdf https://www.fdic.gov/formsdocuments/f1600-04.pdf