Justification and Approval - 50310226P0001_Redacted.pdf

a) Electronic access to Board IQ, which provides news and analysis of the most pressing issues driving mutual fund board compliance and governance. The coverage includes information on how boards are handling topics such as fund governance, SEC updates, director compensation structure, boardroom diversity, 15(c) disclosure, and best practices.

b) Electronic access to FundFire, which provides original articles, summaries of money management industry news, and relevant asset management news.

c) Electronic access to Ignites, which provides original current and historical news, analysis, and video clips of the mutual fund industry dating back to 1999. The articles focus on issues including fund operations, exchange-traded funds, brokers, and annuities with links to related articles. Ignites Research provides proprietary surveys, interviews and analysis of third-party data, reports on insights into important strategic issues facing asset management firms.

This procurement is for a base period of twelve (12) months and four (4) twelve (12) month option years. The total estimated value of the contract is $687,960.00.

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

This acquisition is conducted pursuant to:

FAR 6.302-1 – 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 using the authority cited.

F.T. Specialist Inc. is the only known source of the required publications, and comparable data is not otherwise available. F.T. Specialist Inc. does not license its content to other vendors, and thus, the proprietary content is only available on the F.T. Specialist Inc. websites. F.T. Specialist Inc.’s publications contain analysis and reporting created by their editors and authors in the specialty industry of mutual funds, mutual compliance and governance, and money management.

The uniqueness of the information, combined with copyright protection, makes F.T. Specialist Inc. the only known source. SEC staff require access to these publications to meet the SEC’s mission to maintain fair, orderly, and efficient markets and to protect investors. Meeting this mission requires effective monitoring of markets and markets development in areas of finance, economics, and accounting; therefore, access to the content is critical for achieving this objective.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as possible, including whether a notice was or will be publicized as required by part 5 and, if not, which exception under part 5 applies.

The requirement was synopsized in accordance with FAR requirements. Following the addition of option CLINs, an amended synopsis was issued to provide notice of the revised scope and total potential value. No responsible sources were identified.

7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will determine the price to be fair and reasonable based on negotiations, comparison to historical pricing, and other appropriate price analysis techniques.

8. The market research conducted (see part 10) and the results or a statement of the reason market research was not conducted.

Market research was conducted in accordance with FAR Part 10 and included review of historical contract files, review of recent market research results for similar or identical supplies/services, publication of a formal request for information or sources sought, review of Government and/or commercial databases for relevant information, review of source lists for identical or similar items obtained from Government, professional, and/or industry sources, a review of catalogs and/or other generally available product literature and a review of existing multiple award contract vehicles and other Government-wide Acquisition Contracts (GWACS).

The market research, synopsis, and amended synopsis confirmed that no other responsible sources are capable of meeting the Government’s requirements.

9. Any other facts supporting using other than full and open competition.

Issuing a sole-source award with option CLINs allows the Government to maintain continuity of operations and avoid unnecessary duplication of costs and delays.

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

A listing of any sources that express interest in this acquisition will be maintained in the contract file.

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 Government will continue to conduct market research and assess the marketplace to determine whether the requirement in the future may be competed.