JOFOC-signed.pdf

JUSTIFICATION

Bureau Enhanced Acquisition Management System

Procurement ID: ePRO-2019-11577 BEAMS User Guide

BEAMS Feedback

SUMMARY

Procurement Title:

Inside Mortgage Finance Subscription (New Contract)

CFPB Division & Office:

RMR: Mortgage MarketsRMR: Mortgage Markets

Contracting Officer:

Del Toro, Vanessa (CFPB)

Contract Specialist:

Acquisition Strategy:

Sole Source - SAT or over

Anticipated Award Date:

Base and All Options Value (Total Contract Value):

$563,386.89

BR Total Amount:

$38,625.00

Program Office:

RMR: Mortgage MarketsRMR: Mortgage Markets

Bureau:

BCFP

Contract Type:

Firm Fixed Price b

Contract Number:

Type Of Action:

New Contract/Agreement

Is it Sole Source?

Yes No

FAR Reference:

6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements

PERIOD OF PERFORMANCE

Base Period (Months):

Number of Option Periods:

Option Period 1 (Months):

Option Period 2 (Months):

Option Period 3 (Months):

Option Period 4 (Months):

COSTS Note: the Base Amount(s) do not update from the Buy Request after the first time they are copied.

If the Base Amount in the BR changes, you may need to manually update it here.

Life-Cycle Estimated Total:

$563,386.89 Base (From Buy Request 1):

$85,526.25 Note: You may over-ride the base amount (s).

Base (From Buy Request 2):

If the background color is yellow, the amount does not match the Buy Request.

Option Year 1 Cost:

$115,940.34

Option Year 2 Cost:

$118,259.15

Option Year 3 Cost:

$120,624.33

Option Year 4 Cost:

$123,036.82

FAR 6.3

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

(FAR) 6.302

Date Needed:

4/23/2019

Nature/Description of Action, Supplies, and Services [FAR 6.303-2(b)(2] and (3):

Display Acq Plan Statement of Need The Consumer Financial Protection Bureau (CFPB), Research, Markets, and Regulations (RMR) is seeking to acquire Inside Mortgage Finance (IMF) data and newsletters that will facilitate its efforts to track trends in the mortgage market. The services include comprehensive market-level statistics and qualitative information about industry trends, concerns, and movement. IMF also provides information about the movements of specific companies and industry players, and is often the first to know about these trends. RMR requires a multi-user subscription to IMF's “Mortgage Market Statistical Annual" for 5 users and also requires (9) nine newsletter subscriptions from IMF. It is necessary for the users to have the “Web-access data subscription – Spreadsheet Format because it allows the user to download the data in Excel spreadsheet format, which is more convenient and advantageous when performing mortgage market research. Currently, RMR has access to the newsletter subscriptions from IMF through a separate Bureau-wide contract (administered through the Library) which will last through September 7, 2019. RMR will work with the Library for a strategy going forward but to ensure that RMR continues to have uninterrupted access to the newsletters, RMR requires options for purchasing the newsletters for the base year and subsequent option years.

Statutory Authority Permitting Other than Full and Open Competition [FAR 6.303-2(b)(4)]:

6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements

Description of Market Research and Results [FAR 6.303-2(b)(6), (8) and (10)]:

Display Acq Plan Market Research The COR searched online for vendors that would meet the CFPB's requirements. Below are a number of vendors found to provide mortgage data, and reasons they don't meet Bureau requirements. SNL Financial: provides some mortgage market share data, but does not appear to cover industry information on independent mortgage companies, which make up a sizeable portion of the mortgage market Black Knight: provides mortgage, property, and MLS data. While useful for understanding the general market trends, their data cannot be aggregated by institution and will not offer insights into the movements of specific companies and industry players. Mortgage Bankers Association Originations data:

provides annual data on top lenders broken out by loan types, loan size, and states. However, this data is only made available on an annual basis, after HMDA data (which the CFPB collects) is published. In contrast, IMF provides quarterly estimates of originations data which allow the Mortgage Markets team to better monitor developments in overall trends and of specific companies. Servicing data: provides quarterly and annual performance reports on the revenues and expenses associated with servicing residential mortgage loans.

However, this data is only made available at an aggregated level and again does not give insight into the actions of specific companies. Furthermore, these data are provided in PDF form (instead of excel, which is more convenient to analyze) and only cover independent mortgage companies, not banks that also service mortgages. Does not have data on top servicing participants (by number of loans or volume services) or top residential subservicersCoreLogic: provides data on MLS, liens, property owners, valuations, property characteristics, and home prices. However, their data do not provide information aggregated at the lender or servicer level. Furthermore, the COR consulted with other members of the Mortgage Market team, who are considered by the Bureau to be experts in the field. Team members and the assistant director noted that Inside Mortgage Finance is the vendor of choice by financial institutions for the tracking industry trends. Furthermore, they were not aware of any other vendor that could provide the same depth of data and information about specific companies and industry players. Inside Mortgage Finance is the only vendor who provides the comprehensive market-level statistics and qualitative information about industry trends, concerns, and movement. The vendor is a small business.

Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

Determination of Fair and Reasonable Cost/Price [FAR 6.303-2(b)(7)]: The Contracting Officer determines that the anticipated price(s) will be fair and reasonable based on the following information:

Any Other Facts Supporting the Use of Other than Full and Open Competition [FAR 6.303-2(b)(9)]:

Actions Taken to Remove or Overcome Barriers to Competition [FAR 6.303-2(b)(11)]:

CERTIFICATION

Inside Mortgage Finance is an industry distinct data provider and the Mortgage Market Statistical Annual is the only comprehensive compilation of mortgage market statistics available from any source. Many of the indicators are developed from proprietary surveys of market participants conducted by IMF. There are no known competitors for this product.

The publisher is a first source of information for many mortgage lenders and servicers; in order for our policymaking to be well-informed, we will need to have the same information that the industry does. The newsletters focus on various topics such as industry developments, FHA and GSE lending practices, securitization trends, and more. One newsletter focuses on the CFPB and is an important source of information about the industry’s view of our work.

Inside Mortgage Finance is an industry distinct data provider and the Mortgage Market Statistical Annual is the only comprehensive compilation of mortgage market statistics available from any source. Many of the indicators are developed from proprietary surveys of market participants conducted by IMF. There are no known competitors for this product. The contractor’s online database and newsletters offers the following set of unique characteristics that are required by RMR:

• Comprehensive statistics on many trends, including:

o Mortgage originators o Mortgage servicers o Wholesale/retail lenders o Broker/correspondent lenders o Mortgage insurers o Fannie Mae and Freddie Mac activity o Originations by loan type o Mortgage delinquency rates o Mortgage activity by state o Weekly issuance, trading volume, key investors, MBS performance, and more

• Investor profiles

• Complete lists of MBS Issurance and Issuers

• Information on securitization rates

• Information on non-agency data and players

• Litigation brought by or against Fannie, Freddie, and the FHFA

• Internal watchdog reports

• Information on lenders’ operational strategies

• Regulatory analysis

• CFPB priorities

The commercial prices from IMF are on file and substantially higher than those used in the estimate. A quote will be requested from the vendor to confirm discounts and a new determination will be made at time of award.

NA

The Program office will continue to monitor the marketplace for emerging products and services that can meet or be modified to meet CFPB requirements.

Technical/Requirements Official [FAR 6.303-2(c):

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.

Contracting Officer [FAR 6.303-2(b)(12):By signing below, I certify that this justification is accurate and complete to the best of my knowledge and belief.

SIGNATURES

Person Decision Approved Date and Time

Senior Program Official (Only applicable under FAR 8.4)

Sign

Technical/Requirements Official

SignChang, Alice (CFPB)

Contracting Officer

SignDel Toro, Vanessa (CFPB)

Competition Advocate

SignGalicki, Joshua (CFPB)

Head of Contracting Activity

SignGragan, David (CFPB)

Senior Procurement Executive

Sign

STATUS

Pending

NOTES

Notes captured here are to facilitate communication between the CO and Program Office.

Please specify which tab your note is about Created By Date and Time

Acq PlanAcq Plan

Acq PlanAcq Plan Jeanette Villa

HISTORY

Created By:

Chang, Alice (CFPB)

Creation Date:

12/20/2018

Creation Time:

4:29:38 PM

Last Modified By:

Galicki, Joshua (CFPB)

Last Modified Date:

2/14/2019

Last Modified Time:

2:18:20 PM

2/14/2019 8:47:13 AM

1/28/2019 10:00:03 AM

2/14/2019 2:16:18 PM

Updated Justification Tab 1/25/2019

2:29:06 PM

Office of the Chief Procurement Officer Operations Division

Consumer Financial Protection Bureau