HUD Justification SP Subscription.pdf

Justification for Other than Full and Open Competition

1. Requiring Activity: Department of Housing and Urban Development (HUD) Contracting Activity: Government National Mortgage Association Requisition Number: RCS-T-2026-00055

2. Nature and Description of the Action Being Approved:

Ginnie Mae’s Office of Enterprise Risk has a requirement for a Firm Fixed Price Sole Source Award to S&P Global Market Intelligence, LLC, (“SPGMI”) for an online, electronic financial services subscription with in-depth financial analysis and data services. This service is to be provided in a suite of comprehensive financial content covering: financial news and analysis; reviews of domestic and global banks; financial industry data; annual and quarterly regulatory filings; bank performance and peer analytics; earnings reports; and announcements and investor presentations. Electronic financial delivery products are unique because they support the integration of financial information directly into Ginnie Mae's proprietary software models and applications, without any additional requirements to the contractor to facilitate financial analysis and better management of Ginnie Mae’s Risk Profile. The data will be used for various purposes, including the creation of derivative works for Ginnie Mae’s internal use, such as the development of risk models, financial histories, credit profiles and other analytical tools relating to its role in the mortgage industry. The content will be delivered online and will be available 24/7.

3. Description of supplies or services required to meet Ginnie Mae’s needs (including the estimated value):

Ginnie Mae's Office of Enterprise Risk ("OER") requires an electronic subscription service of financial data from SPGMI to support the continued surveillance of its issuers and financial counterparties. These issuers include commercial banks, thrifts, savings and loans, mortgage banks, credit unions and other financial institutions that perform a variety of mission-critical functions, such as collecting monthly mortgage payments from borrowers and forwarding those payments to investor bondholders. SPGMI’s data also is crucial to Ginnie Mae’s ability to produce GAAP compliant financial statements. The anticipated award date is September 15, 2026.

Ratings Delivery Service:

SPGMI will provide the following unique on-line electronic financial services:

RatingsDirect® which provides access to S&P Global credit ratings, research, and credit-adjusted financial statements. It allows users to monitor credit trends, rating upgrades and downgrades, credit performance, and industry outlooks. Ratings coverage includes 9,500 global issuers and 81,000 securities; 720 U.S. Public Finance entities and 700,000 securities; and 16,500 Structured Finance transactions, including asset-backed, commercial mortgage-backed, residential mortgage-backed securities, and collateralized debt obligations and 43,000 securities.

RatingsXpress® provides access to S&P Global Ratings data for issuers and fixed income securities in a structured feed format that can been delivered directly into internal systems, databases, models and analytical workflows. This data is available by asset class, global issuers, international public finance and government entities. RatingsXpress is well suited for use cases such as counterparty risk monitoring, internal scorecards, benchmark analysis, model development, policy testing and other analytical processes that rely on timely and historical ratings data.

SNL FIG via Capital IQ Pro Desktop provides access to specialized financial institutions data that supports the analysis of banks, credit unions, insurance companies, and related financial entities. The content includes: global banking data, financial institutions regulatory data, bank branch data, depository rates, and insurance data.

SNL Banking Data API is a comprehensive banking suite that offers reliable and timely financial data that includes banking-specific benchmarks, such as asset quality details, loan and deposit composition, and regulatory capital breakdown including the latest Basel III disclosures.

SPGMI’s electronic ratings delivery products are unique because they support the integration of their ratings and related financial information directly into Ginnie Mae’s proprietary software models and applications to facilitate financial analysis and better manage its Risk profile.

Estimated Dollar Value of Base Year and Four (4) Option Years:

Base Year $565,060

Option Year One $593,290 Option Year Two $622,980

Option Year Three $654,130 Option Year Four $686,835 Total for Base Year and Four Option Periods $3,122,295

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

This action is taken under the authority 41 USC 3304 (a)(1) (see FAR 6.103-1). Only one responsible source, and no other supplies or services will satisfy agency requirements.

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

SPGMI is one of the “Big 3” in the financial subscription service. Each of their competitors provides uniquely proprietary ratings to Ginnie Mae under other sole source contracts. SPGMI provides financial subscriptions and credit ratings databases that are unique and are proprietary to their firm. Market Research with this company has revealed that they act as the sole distributors of the data they have curated and offer via a web-based financial subscription service. They have no distributors or dealers that sell these subscription services. This service must be purchased directly from the company.

As such, they deliver the market standard for financial analysis, risk assessments, economic forecasting, and stock market research to corporations, government agencies, investment banks, brokerage firms, and academic institutions. No other type of supplies or services will satisfy Ginnie Mae’s requirements.

6. A description of the efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a SAM.gov notice was or will be published as required by FAR 5.2, and, if not, which exception under 5.202 applies:.

Market research was conducted to identify potential sources, from both large and small businesses, for the same or similar type of services. Several techniques were employed in conducting market research for this acquisition including:

Researching www.SAM.gov to identify possible small business concerns with the capacity to fulfill this requirement. None were found able to perform these services.

Researching other Nationally Recognized Statistical Ratings Organizations (NRSROs), including AM Best and Demotech, Inc. Although these two are approved NRSROs, neither of these companies meet our requirements because both companies operate primarily within the insurance ratings industry.

Issuance of a Sources Sought Notice which was published on www.SAM.gov from April 14-20, 2026. No responses were received.

Direct contact with SPGMI’s Relationship Manager who serves as liaison to Ginnie Mae on the current contract.

To the extent that market research was conducted to identify potential sources, it revealed that SPGMI is the only vendor that provides its proprietary electronic ratings and institutional credit analysis.

7. The Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable:

As part of market research for this procurement, the independent government cost estimate was derived by adding a 4.75% escalation fee to the Base Year and all Option Years. The estimated total for the entire contract is $3,122,295.

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

Market research was conducted to identify potential sources (large and small business) for the same or similar services. However, market research revealed that SPGMI is the only company that provides the Ratings Delivery Services as outlined above because it is proprietary to them.

http://www.sam.gov/

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

The services and products provided by SPGMI continue to be critical to Ginnie Mae’s counterparty risk and financial reporting operations and requirements, all of which are essential for the continued viability of federal government housing programs. If these services are not acquired, it compromises Ginnie Mae’s ability to conduct due diligence inquiries into the participants of the secondary mortgage market, which help to fund various Federal Housing Authority (FHA) programs.

This Contract was awarded under the authority 41 USC 3302 (a) (1) (see FAR 6.103-1). Only one rational source, and no other, will satisfy agency requirements.

The contractor is not listed in the System for Award Management Exclusions (www.sam.gov) (FAR 9.405-1). However, the contractor’s performance on the current contract has been satisfactory as outlined in CPARs.

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

None.

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

A Notice of Intent will be posted on SAM.gov stating Ginnie Mae’s intent to make an award to SPGMI on a sole source basis, under the authority of FAR 6.103-1. Market research has revealed that these services can only be acquired from SPGMI because these services are of a proprietary nature.

This Notice of Intent is not a request for competitive quotations. No solicitation package will be issued.

http://www.sam.gov/

12. The contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief:

CERTIFICATIONS:

I certify that the facts and representations under my cognizance which are included in this justification and which form a basis for this justification are complete and accurate.

TECHNICAL COGNIZANCE: (If applicable)

(Signature) Phone Date _______

(Printed) Name and Title ________________________________________________

CONTRACTING OFFICER CERTIFICATION REQUIRED BY FAR 6.104-1 (a) (12)

I certify that this justification is accurate and complete to the best of my knowledge and belief.

(Signature) Phone Date ________

(Printed) Name and Title _________________________________________________

202-475-7914 07/27/26

This action is taken under the authority 41 USC 3304 (a)(1) (see FAR 6.103-1). Only one responsible source, and no other supplies or services will satisfy agency requirements.