SSJ Financial Misconduct_Redacted.pdf

This is a Sole Source Justification document for a simplified acquisition over the micro-purchase threshold and up to the simplified acquisition threshold, dated May 14, 2026, for requisition FHF-26-0178.

The Federal Housing Finance Agency (FHFA) seeks to procure independent outside legal counsel from Arnold & Porter to provide strategic legal analysis and advisory services related to potential financial misconduct. The contractor will review Agency-prepared materials, conduct legal research, assess applicable federal laws, prepare a comprehensive written legal advisory memorandum, and recommend courses of action to support FHFA leadership and the Office of General Counsel in determining appropriate response measures. The anticipated cost is not disclosed in the redacted document. The justification selects "Only one responsible source" as the basis for sole source procurement. The rationale emphasizes that this requirement demands specialized, high-level legal expertise in federal enforcement actions, financial misconduct, and FHFA's unique regulatory framework. Arnold & Porter is identified as the only responsible source capable of providing the required specialized services with demonstrated expertise in administrative enforcement actions, complex legal matters, and immediate availability without requiring ramp-up time. The Agency determined that market survey was unnecessary due to the sensitivity of the underlying matter and risk of exposing confidential information. The contracting officer certifies that only one source is available and that pricing will be determined fair and reasonable using standard price analysis techniques per FAR Part 13. The document is signed by Technical Representative Taryn Jones and Contracting Officer Laura Baker, both digitally signed on May 15, 2026.