Sole Source Justification Form

Version 7.01 Page 1 of 6

Bulletin Reference Number 27-440DFPR-SECRE-B-53771

Requesting Agency/University Department of Financial and Professional Regulation

Sole Source Justification Form - Part I Section I - General Information

Department/Bureau/Section: IDFPR/Division of Banking

Need Identified Date: Aug 5, 2026 Supply/Service Need By Date: September 2, 2026

Project Title: FY27 Anti-Predatory Lending Database Sole Source

Vendor: Catalis Regulatory & Compliance

Provide a description of the supplies or services required:

The Illinois Department of Financial and Professional Regulation (IDFPR) is statutorily mandated to create, maintain, and administer a database herein referred to as the Anti-Predatory Lending Database (APLD). Services include providing the technology, business processes, and support for the APLD in order to track residential mortgage loan transactions that are initiated by licensed loan originators or mortgage brokers in Cook, Kane, Peoria, and Will counties. IDFPR has established standards that trigger required credit counseling based on entered information that is deemed high-risk by the APLD. Other services include management, administration, maintenance of the APLD, providing program management services, customer service functions, technical support, regulatory compliance support, data entry services and program review as required by IDFPR.

Value: Estimated Value of Initial Term, this Change Order or Amendment: 2,090,004

Will this Sole Source amend a Professional or Artistic Services contract? Yes No

*Sole Source may not be used for amendments for Professional or Artistic Services if the amendment would increase the value by more than 5% of the initial award or extend the term by more than 60 days.

Type: New Sole Source

Section II - Proposed Term

One-Time Purchase Term Contract

Estimated Contract Begin Date: Sep 2, 2026

Estimated Contract End Date: 09/01/2027

Number of Potential Renewals: 0

Length of Each Renewal in Months: 0

Total Value of All Renewals: 0

If a Term Contract, does the term, including renewals, exceed 12 months? Yes No

Section III - Funding Source Select the type of funding to be used (Check all that apply): State Appropriate Funds Federal Funds Other (Explain):

Section IV - Sole Source Justification

This purchase is economically only available from a single source primarily because it is: (If "Other" explain in one sentence)

Items are Copyrighted or Patented and the Items are Only Available from the Holder

Version 7.01 Page 2 of 6

Bulletin Reference Number 27-440DFPR-SECRE-B-53771

Requesting Agency/University Department of Financial and Professional Regulation

Are there secondary justification(s) for this sole source? Yes No

Section V - Purchase History

Has the Agency or University Purchased these supplies or services in the past? Yes No

Term Term From Term To Value Description Contract Number Type

1 9/2/2025 9/1/2026 1,486,918 Anti-Predatory Lending Database P-86662 Sole Source

2 Sep 2, 2024 Sep 1, 2025 1,486,918 Anti-Predatory Lending Database P-70187 Sole Source

3 Sep 2, 2023 Sep 1, 2024 1,189,535 Anti-Predatory Lending Database P-55809 Sole Source

4 09/02/2020 09/01/2023 3,064,866.38 Anti-Predatory Lending Database P-20270 Sole Source

5 09/02/2017 09/01/2020 3,256,366.79 Anti-Predatory Lending Database 18DOB94998 Sole Source

If more than 10, or if other comments, explain: N/A

Section VI - Business Rationale

1. Provide a detailed explanation of the need for the supplies or services:

The need for these services are required by statute. Public Act (PA) 94-280 amended the Residential Real Property Disclosure Act, (765 ILCS 77) (Act) and originally established the Predatory Lending Database Pilot Program for designated areas of Cook County. The Act required the Department of Financial and Professional Regulation (Department) to create, maintain, and administer a database created under this program herein referred to as the Anti-Predatory Lending Database (APLD). The APLD must allow brokers, originators, credit counselors, title insurance companies and closing agents to enter borrower application and closing information online as specified by the Act and the Department's administrative rules. The Act requires the Department to determine whether credit counseling is recommended for the applicant-borrower based upon Department standards.

Version 7.01 Page 3 of 6

Bulletin Reference Number 27-440DFPR-SECRE-B-53771

Requesting Agency/University Department of Financial and Professional Regulation

2. Provide a list and describe in detail the specifications required to satisfy the need:

Services to be Provided: Vendor agrees to manage, administer and maintain the APLD which includes providing program management services, customer service functions, technical support, regulatory compliance support, data entry services and program review (collectively referred to as the "System") as required by the Department pursuant to the Act.

Vendor agrees to provide a technical and business solution to enable IDFPR to: Track mortgage application information entered by brokers, originators, credit counselors, title insurance companies and closing agents; Identify and notify applicants for credit counseling based upon IDFPR standards, Vendor shall work with assigned IDFPR DOB staff to document and implement the preferred method of notification to borrowers to meet this requirement; Track mortgage loan closings for compliance; Facilitate the issuing of certifications of compliance as generated by the database; Vendor shall provide quarterly and semi-annual reports as required by IDFPR which will assist IDFPR DOB in the preparation of required reports to the Illinois General Assembly.

Vendor agrees to provide notification and limited training of IDFPR staff, loan originators, title insurance companies, closing agents and credit counselors regarding the requirements of the system.

Vendor agrees to provide a security system to protect confidential information to comply with state and federal law.

Vendor agrees to provide the management reporting system for the APLD.

Vendor shall meet requirements as documented in the contract for Information Access, Process and Issue Private Lender Exempt Certificates as needed, Process and Send Self-Registration Letters to Mortgage Brokers, Process and File Lis Pendens Notices as required by Statute, Data Retention, Optional Services, and System Availability.

3. Provide detail explaining the justification selected in Section IV to explain why the requested supplies or services are the only ones available that can satisfy the agency or university requirements?

The software system and operational support model developed by the vendor that provide all required services under this Contract are proprietary. Illinois is the only state that utilizes, and the Vendor is the only company that currently provides, this type of software and supporting operations. The Vendor is the only provider for maintenance of the system and infrastructure deployed (including hosting) in support of the services.

4. What are the unique features of the supplies or services that are not available in any other product or by any other vendor? Provide specific quantifiable factors/qualifications:

Information security, administration, software maintenance, 24 x 7 x 365 hosting / availability of the system and interfaces with industry servicing systems requires the vendor support team to interact with the system on a routine basis. Operational Support of this program (e.g., handling all calls related to use of the database) also requires our customer service / help desk personnel to access the system on a routine basis.

5. Has the Agency or University considered alternative supplies or services to satisfy their need? Yes No

5a. If yes, name the alternative vendors whose supplies or services were evaluated:

IDFPR is currently executing an IFB (B-50508) and has received multiple bids. The IFB solicitation for a long-term solution is currently in progress and the agency will be transitioning to that long-term solution once that contract and APLD solution are fully in place.

5b. If yes, what were the alternatives for each vendor and why were they unacceptable? Be specific with regard to features, characteristics, requirements, capabilities and compatibility:

IDFPR is currently executing an IFB (B-50508) and has received multiple bids. The IFB solicitation for a long-term solution is currently in progress and the agency will be transitioning to that long-term solution once that contract and APLD solution are fully in place.

5c. Explain how the market evaluation was conducted?

*This evaluation is to determine available options within a market. If the evaluation is to determine quality or best suited option, this is not the appropriate source selection. Under no circumstances shall the evaluation consist of testing alternative options. These activities must be conducted in a competitive transparent environment (i.e. IFB or RFP).

IDFPR is currently executing an IFB (B-50508) and has received multiple bids. The IFB solicitation for a long-term solution is currently in progress and the agency will be transitioning to that long-term solution once that contract and APLD solution are fully in place.

6. Are there resellers or distributors?

Yes No N/A

Version 7.01 Page 4 of 6

Bulletin Reference Number 27-440DFPR-SECRE-B-53771

Requesting Agency/University Department of Financial and Professional Regulation

7. What efforts were made to get the best possible price (i.e. did the agency/university negotiate) and how did you determine the price for this purchase is considered fair and reasonable?

IDFPR requested the incumbent vendor maintains continuity of the current APLD system and services. The vendor agreed to maintain continuity at an increased annual cost. It’s a 40% increase from prior year pricing. Prior year pricing was maintained over a two year period. Prior to that, it was about a 20% increase after they maintained pricing steady for three years. Over a six year period, we've experienced a 60% increase in pricing, which averages out to a 10% increase annually - which is more in-line with annual increases IDFPR experiences with other IT-related solutions. This same calculation can be done over a 10-year period as well - which is how long IDFPR has been executing sole source procurements for this solution. Also, enhanced functionalities and user interface features were applied at IDFPR's request to this APLD solution over the past several years. This involves intaking more data and increases the needs of hosting and back end data storage requirements.

The pricing provided is an annual cost broken into equal monthly invoices. No additional costs or line items will be incurred during the terms of this agreement. Considering systems of this magnitude can cost public and private sectors tens of millions of dollars to solicit, develop, implement, and maintain, the current price is deemed fair and reasonable and this procurement is the best value for IDFPR and the State.

8. Will this purchase obligate the State to this vendor for future purchases such as maintenance, licensing or continuing need?

Yes No

8a. If yes, please provide details regarding future obligations and/or needs:

Since the APLD is a statutorily required solution, IDFPR will need to maintain continuity of the current system and services until the IFB is awarded, that contract is executed, and that APLD solution is implemented. The IFB solicitation for a long-term solution is currently in progress and the agency will be transitioning to that long-term solution once that contract and APLD solution are fully in place.

IDFPR anticipates that implementation to occur during the term of this requested Sole Source, however, if any delays were to occur, IDFPR will need to maintain continuity with the incumbent vendor and APLD solution to maintain compliance.

9. What will be the financial or other impact to the State if this sole source is not approved and a competitive bid is required?

Without these services, not only with IDFPR be in statutory non-compliance but the residents in these four counties (which would account for nearly 80% of the State's population) would be at severe risk of predatory lending behaviors that would escalate to a threat equivalent to the 2008 housing crisis. If this scenario were to occur, it would absolutely devastate the State, its residents, private businesses, and public entities directly and indirectly to various degrees.

10. Is there any additional information you would like to add to justify this sole source?

N/A

Version 7.01 Page 5 of 6

Bulletin Reference Number 27-440DFPR-SECRE-B-53771

Requesting Agency/University Department of Financial and Professional Regulation

Section VII

Requesting Department Representative

Requesting Department Signature Required

I know and understand the contents of this Sole Source Justification and attest that all statements are true and correct and the fairness and reasonableness of the price was adequately confirmed.

Date Aug 19, 2026

Printed Name Brandon Purcell E-mail Address brandon.purcell@illinois.gov

Phone Number 217-299-3562

State Agency Bureau/Division Head or University Purchasing Director Approval and Signature Required

I know and understand the contents of this Sole Source Justification and attest that all statements are true and correct and the fairness and reasonableness of the price was adequately confirmed. (All prior form fields will lock once this e-signature is completed)

E-mail Address brandon.purcell@illinois.gov

Phone Number 217-299-3562 Date Aug 19, 2026

Printed Name Brandon Purcell

Agency Bureau/Division Head or University Purchasing Director and Not a Designee

SPO Approval and Signature Required

I have reviewed and understand the contents of this Sole Source Justification and agree with the State Agency or University determination.

I have reviewed and understand the contents of this Sole Source Justification and do not agree with the State Agency or University determination. As a result, the State Agency or University must explore other sourcing methods to satisfy their need.

State Purchasing Officer Signature Phone Number 217-299-5856 Date Aug 19, 2026

Printed Name Jenny Shourd E-mail Address jennifer.shourd@illinois.gov

Version 7.01 Page 6 of 6

Bulletin Reference Number 27-440DFPR-SECRE-B-53771

Requesting Agency/University Department of Financial and Professional Regulation

Sole Source Justification Form - Part II Section I - General Information

Project Title

Vendor

Initial Date of Procurement Bulletin Posting

Was a Sole Source hearing held per 30 ILCS 500/20-25?

Yes - Complete Section II and III below (Section II will only be visible when this option is selected)

No - Section II not required, go to Section III below Section III - CPO Approval and Signature Required

Based on my review, I authorize the Agency/University to proceed in accordance with the published Notice referenced above.

Based upon my review, I authorize the Agency/University to proceed with the following Changes.

Based on my review, the Agency/University is not authorized to proceed with this sole source as presented and my recommendation is that it be cancelled.

Other

CPO Signature CPO Phone

Printed Name Date

CPO E-mail

Version 7.01 Page of Sole Source Justification Form - Part I Section I - General Information Will this Sole Source amend a Professional or Artistic Services contract?

If yes, what was the original contract value?

*Sole Source may not be used for amendments for Professional or Artistic Services if the amendment would increase the value by more than 5% of the initial award or extend the term by more than 60 days.

Section II - Proposed Term If a Term Contract, does the term, including renewals, exceed 12 months?

If yes, provide a detailed justification including any economic benefit received for agreeing to a multi-year term:

Section III - Funding Source Select the type of funding to be used (Check all that apply):

Section IV - Sole Source Justification Are there secondary justification(s) for this sole source?

Section V - Purchase History Has the Agency or University Purchased these supplies or services in the past?

Term Term From Term To Value Description Contract Number Type Section VI - Business Rationale

1. Provide a detailed explanation of the need for the supplies or services:

2. Provide a list and describe in detail the specifications required to satisfy the need:

3. Provide detail explaining the justification selected in Section IV to explain why the requested supplies or services are the only ones available that can satisfy the agency or university requirements?

4. What are the unique features of the supplies or services that are not available in any other product or by any other vendor? Provide specific quantifiable factors/qualifications:

5. Has the Agency or University considered alternative supplies or services to satisfy their need?

5a. If yes, name the alternative vendors whose supplies or services were evaluated:

5b. If yes, what were the alternatives for each vendor and why were they unacceptable? Be specific with regard to features, characteristics, requirements, capabilities and compatibility:

5c. Explain how the market evaluation was conducted?

*This evaluation is to determine available options within a market. If the evaluation is to determine quality or best suited option, this is not the appropriate source selection. Under no circumstances shall the evaluation consist of testing alternative options. These activities must be conducted in a competitive transparent environment (i.e. IFB or RFP).

5a. If no, why weren't alternatives evaluated?

6. Are there resellers or distributors?

7. What efforts were made to get the best possible price (i.e. did the agency/university negotiate) and how did you determine the price for this purchase is considered fair and reasonable?

8. Will this purchase obligate the State to this vendor for future purchases such as maintenance, licensing or continuing need?

8a. If yes, please provide details regarding future obligations and/or needs:

9. What will be the financial or other impact to the State if this sole source is not approved and a competitive bid is required?

10. Is there any additional information you would like to add to justify this sole source?

Section VII Requesting Department Signature Required I know and understand the contents of this Sole Source Justification and attest that all statements are true and correct and the fairness and reasonableness of the price was adequately confirmed.

State Agency Bureau/Division Head or University Purchasing Director Approval and Signature Required I know and understand the contents of this Sole Source Justification and attest that all statements are true and correct and the fairness and reasonableness of the price was adequately confirmed. (All prior form fields will lock once this e-signature is completed) SPO Approval and Signature Required Sole Source Justification Form - Part II Section I - General Information Was a Sole Source hearing held per 30 ILCS 500/20-25?

Section II - Sole Source Hearing Details The State posted to the Illinois Procurement Bulletin a description of the State's need, the justification for the sole source decision, and information regarding the opportunity to submit comments and testify at a public hearing. Notice of the hearing was also posted outside of the hearing room 48 hours prior to the hearing.

The public hearing was conducted for the purpose of receiving testimony regarding the sole source determination. The Hearing Officer recommends the following:

The following relevant documents are attached:

Section III - CPO Approval and Signature Required 9.0.0.2.20101008.1.734229

statutorily mandated to create, maintain, and administer a database herein referred to as the Anti-Predatory Lending Database (APLD). Services include providing the technology, business processes, and support for the APLD in order to track residential mortgage loan transactions that are initiated by licensed loan originators or mortgage brokers in Cook, Kane, Peoria, and Will counties. IDFPR has established standards that trigger required credit counseling based on entered information that is deemed high-risk by the APLD. Other services include management, administration, maintenance of the APLD, providing program management services, customer service functions, technical support, regulatory compliance support, data entry services and program review as required by IDFPR.

ILCS 77) (Act) and originally established the Predatory Lending Database Pilot Program for designated areas of Cook County. The Act required the Department of Financial and Professional Regulation (Department) to create, maintain, and administer a database created under this program herein referred to as the Anti-Predatory Lending Database (APLD). The APLD must allow brokers, originators, credit counselors, title insurance companies and closing agents to enter borrower application and closing information online as specified by the Act and the Department's administrative rules. The Act requires the Department to determine whether credit counseling is recommended for the applicant-borrower based upon Department standards.

Q2Answer: Services to be Provided: Vendor agrees to manage, administer and maintain the APLD which includes providing program management services, customer service functions, technical support, regulatory compliance support, data entry services and program review (collectively referred to as the "System") as required by the Department pursuant to the Act.

Vendor agrees to provide a technical and business solution to enable IDFPR to: Track mortgage application information entered by brokers, originators, credit counselors, title insurance companies and closing agents; Identify and notify applicants for credit counseling based upon IDFPR standards, Vendor shall work with assigned IDFPR DOB staff to document and implement the preferred method of notification to borrowers to meet this requirement; Track mortgage loan closings for compliance; Facilitate the issuing of certifications of compliance as generated by the database; Vendor shall provide quarterly and semi-annual reports as required by IDFPR which will assist IDFPR DOB in the preparation of required reports to the Illinois General Assembly.

Vendor agrees to provide notification and limited training of IDFPR staff, loan originators, title insurance companies, closing agents and credit counselors regarding the requirements of the system.

Vendor agrees to provide a security system to protect confidential information to comply with state and federal law.

Vendor agrees to provide the management reporting system for the APLD.

Vendor shall meet requirements as documented in the contract for Information Access, Process and Issue Private Lender Exempt Certificates as needed, Process and Send Self-Registration Letters to Mortgage Brokers, Process and File Lis Pendens Notices as required by Statute, Data Retention, Optional Services, and System Availability.

The pricing provided is an annual cost broken into equal monthly invoices. No additional costs or line items will be incurred during the terms of this agreement. Considering systems of this magnitude can cost public and private sectors tens of millions of dollars to solicit, develop, implement, and maintain, the current price is deemed fair and reasonable and this procurement is the best value for IDFPR and the State.