IW_Financial_JA.pdf

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

100 F STREET, NE

WASHINGTON, DC 20549

O(fice of Acquisitions

JUSTIFICATION AND APPROVAL

Simplified Procedures for Certain Commercial Items

RQ 65000-16-0085

J&A Log: 2016-0022

Upon the basis of the following justification as required by FAR

13.501(a)(1)(ii), I hereby approve the issuance of the contractual action discussed below using simplified procedures for certain commercial items in accordance with 41 U.S.C. 1901.

1. Contracting Activity.

U.S. Securities and Exchange Commission

100 F Street NE

Washington, DC 20549

2. Nature and Description of Action Being Approved:

The U.S. Securities and Exchange Commission (SEC) intends to award a sole source requirement for access to IW Financial's Global Compliance Workstation. This is a renewal contract action.

3. Description of the supplies or services required to meet the needs of the SEC and the estimated value:

The SEC proposes to negotiate the purchase of continuing services for an online global security risk assessment product for the SEC Headquarters and regional offices that provides profiles of publicly traded companies with connections to any country that has been identified by the U.S. Department of State as being a state sponsor of terrorism and as having programs for the production or proliferation of weapons of mass destruction or ballistic missile systems.

The product includes an explanation of the connection between each company and the country in question, including company financial information, lawsuit details, shareholder activism, and negative publicity related to each company. The product provides analysis of the investment risk associated with companies with ties to those countries.

The estimated contract value is ~ for the base year.

The estimated contract value for the base year and four option years is ~.

4. Statutory Authority for Simplified Procedures for Certain

Commercial I terns

The statutory authority permitting the use of simplified acquisition procedures is ( 41 U. S . C . 1901) FAR 13.501(a)(1)(ii) -

Simplified Procedures for Certain Commercial Items applying sole source procedures.

5. Demonstration that the nature of the acquisition requires use of the authority cited:

After publication of a notice seeking other possible suppliers who could meet SEC needs, no responsive capable vendors responded. It was therefore determined that the required information in consolidated and useful format can currently only be obtained from IW Financial.

6. Efforts to ensure that offers are solicited from as Many

Potential Sources as Possible.

In accordance with FAR 5.203(a), a notice of intent to award a sole-source contract to IW Financial for the services specified herein was posted to FedBizOpps.gov.

7. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer has determined that the anticipated cost of this action will be fair and reasonable. Before awarding a contract, the contracting officer will perform additional price analysis in accordance with FAR 15.404-1(b).

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

SEC staff conducted an exhaustive search and could not find any other comparable product. While there is information available on companies that may have ties to a state sponsor of terrorism, no other database or service could be found that has compiled all the information into one capability/interface.

9. Other Supporting Facts:

In response to language in House Report 108-221 that was issued by the Commission's oversight committee, Chaired by Congressman Frank Wolfe, the Division of Corporation Finance this year created the Office of Global Security Risk. The mission of that office is to ensure that publicly traded companies provide adequate disclosure about any ties to countries that have been identified as supporting terrorism, the production or proliferation of weapons of mass destruction, or human rights abuses.

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 supplies or services required:

The SEC intends to post this signed J&A after award in accordance with 13.501(a)(1)(iii).