OMBP RFP Q_A (HQ0423-22-R-0008) 26 October 2022 FINAL.docx

QUESTIONS and ANSWERS (Q&A) Comment by King, Dana L CIV DFAS ZEC (USA):

DoD Overseas Military Banking Program (OMBP) Request for Proposal (RFP) October 18, 2022

Q1: Subfactor 4: Transition Approach listed in Section M-3.1 (page 241) states that the Offeror’s transition “shall not exceed six months (180 consecutive days)…” C-17.1 however, requires a Transition Plan for the first 30-120 days from contract award, which seems to contradict the 6-month period. What is the maximum acceptable transition period?

A: Thank you for bringing the contradiction to the Government’s attention. Paragraph C-17.1 of the RFP will be amended to read as follows:

C-17.1. TRANSITION IN PLAN: The Offeror shall provide a transition in plan according to paragraph M-3.1.d.4 of this RFP. A finalized transition in plan will be incorporated herein, by means of a Contract modification subsequent to award. It is anticipated the transition in will not exceed six months [180 consecutive days] to accomplish.)

The Contractor shall develop and submit, with their proposal, a Transition Plan for the first 30-120 days from contract award which presents a clear understanding of all efforts involved in the transition from the incumbent Contractor. The plan shall present economical, effective, and workable solutions to accomplish the transition. The plan shall include the following items:

1. Interface/coordination with the Government

1. Contractor supervision of the transition process

1. Employee recruitment

1. Transition of key personnel

1. Initial training, indoctrination, and orientation of all contractor employees

1. Transfer and control of government furnished property

1. Transfer, custody, control, safeguard process and turnover procedures for system operation

1. A risk management plan for the phase in process

1. A Work Break Down Structure (WBS) outlining detailed tasks and schedules for the phase in process

Paragraphs one and two of C-17-3. of the RFP will be amended to read as follows:

C-17-3. TRANSITION OUT ACTIVITIES: The Contractor shall exercise its best efforts to effect an orderly and efficient transition with the successor Contractor to ensure that the required services are performed without interruption. The Contractor shall implement their Transition Plan presented in their proposal immediately on award. However, the Government may require changes to the plan after award of the Contract. Compliance of all Government requested changes or revisions to the plan are due within 30 calendar days of the request or sooner.

The Offeror shall also affirm they will work with DoD and the successor Contractor to develop a transition out plan and implement necessary steps to effectively transition out at the end of the Contract term.

Q2: Will DoD specify the number of personnel that the Offeror can hire and staff by location?

A2: DoD does not specify the number of personnel the Offeror can hire and staff by location. Personnel numbers and the basis for those numbers are proposed by the Offeror. DoD may engage in discussions during the RFP process related to personnel numbers as well as year-to-year during the annual contractor-submitted operating budget process identified in the RFP.

Q3: What categories of costs are in the $500,000 equipment purchases (e.g. servers, desktops, hardware, software, etc.)?

A3: The majority of equipment purchases, outside of computer hardware and software, are currency counters, chairs, and uninterruptible power supply batteries. All equipment purchases are subject to review during semi-annual reviews.

Please see RFP Amendment 9 which includes the Government’s amended RFP Attachment J-24 Cost_Pricing Matrix which prescribes the use of Historical Cost Elements from FY21 and Budgeted Cost Elements for FY22 for cost estimating and proposal preparation purposes. RFP Amendment 10 amended Sections L and M to reflect the amended J-24. Specifically, Section L, paragraph L-2.3 was amended to read as follows:

L-2.3. VOLUME III – COST/PRICE

Proposals must address all requirements identified in M-5. FACTOR 3: COST/PRICE. The Offeror's cost proposal shall include, but not necessarily be limited to, the following:

1. ATTACHMENT J-24 OMBP Cost_Pricing Matrix - Amendment 9 (30 September 2022). Offerors must complete Attachment J-24 in its entirety utilizing the estimates provided. Offerors must propose an Annual Fixed Fee for FYs 23 - 32 (the base year and all nine one-year option periods) and Fee Percentage (%) proposed as well as a potential six-month contract extension at the end of the Contract’s period of performance. Offerors must calculate and provide a total proposed Annual Total Home Office Operations Cost, MBF Operations Cost, and Offeror’s Proposed Fixed Fee. Offerors must also propose Cumulative 10-Year Offeror’s Proposed Fixed Fee, and Total Cumulative 10-Year Home Office Operations Cost, MBF Operations Cost, and Offeror’s Proposed Fixed Fee. (Required areas for Offerors to input their Cost Proposal information are highlighted in green.) Offerors are not required to submit cost information for any Bad Debt CLINs.

1. Additionally, Offerors must also ensure additional worksheets are provided, if needed to present offeror proposed alternatives and/or deviations from current OMBP operations, for the following:

1. Identification of all costs related to any subcontracts; e.g., core application platforms/software/etc., network support, ATM channel, courier services, etc. Offerors shall identify all known first-tier subcontractors with anticipated subcontracts of $3 million or more.

1. Identification of charges for those products identified in accordance with the provisions of Sections C and J as specified in paragraph a. above.

Q4: If the intent is to carry over the existing subcontracts, under which circumstances can potential offerors contact the current subcontractors for quotes to demonstrate price reasonableness?

A4: The Government has no restrictions on when potential offerors can contact current subcontractors. Recommend potential offerors coordinate with the incumbent Contractor or the successor Contractor coordinating with the incumbent Contractor during transition planning subsequent to contract award.

Q5: To what extent is the contractor responsible for the loss, damage, or theft of government property?

A5: FAR 52.245-1(h) specifically covers Contractor Liability for Government Property in short. Generally, the Government assumes the risk of loss of or damage to government property unless the damage was the result of gross or willful negligence or malfeasance by the Contractor’s management.

Q6: Will the government provide a copy of the incumbent Contractor’s transition out plan to assist in providing the most responsive transition-in plan?

A6: The incumbent Contractor will work with DoD and the successor Contractor to develop a transition out plan and implement necessary steps to effectively transition out at the end of the Contract term.

Q7: To what degree is current Contractor responsible for replacing equipment that is at the end-of-life cycle during transition phase of up to 180 days?

A7: The incumbent Contractor will be responsible for replacing equipment that is at the end-of-life cycle during the period in which they are performing Banking Operations on the current Contract. The timing of the transfer of responsibility for equipment replacement will be established during the development of the transition plan.

Q8: Given the nature of the services being delivered under this contract, can the Government elaborate on the inclusion of the Warranty Tracking clauses?

A8: The provision at DFARS 252.246-7005, Notice of Warranty Tracking of Serialized Items and the clause at DFARS 252.246-7006, Warranty of Tracking of Serialized Items are both required if the clause at 252.211-7003, Item Unique Identification and Valuation, is included. DFARS 252.211-7003 is required in solicitations and contracts, including solicitations and contracts using FAR part 12 procedures for the acquisition of commercial items, for supplies, and for services involving the furnishing of supplies. ATMs for example are acquired as Contractor Acquired Property (CAP) for the OMBP and furnished to the Government.

Please note, for the purposes of RFP Proposal preparation and submission, the Government is not expecting potential Offerors to complete and submit the related RFP Section J Attachments (J-13 Instructions for Electronic Submission of Warranty Tracking and Administration of Information for Serialized Items, J-14 Warranty Tracking Information, or J-15 Warranty Repair Source Instructions) unless they are providing warranted items as part of their Offer.

Q9: Is the Government planning to renovate any of the MBF locations and, if so, to what extent?

A9: There are not currently any plans to renovate any of the current MBF locations. Generally renovation activity would be a contractor-proposed item.

Q10: Outside of the facilities, what do the Commanders provide at each MBF? (e.g., security, telephone, utilities)

A10: Logistical support is provided in accordance with the DoD Financial Management Regulation Volume 12, Chapter 33, subsection 5.3 which may be viewed here: https://comptroller.defense.gov/Portals/45/documents/fmr/current/12/12_33.pdf

Q11: Is the $3 million threshold for reporting known first-tier subcontractors intended to be based upon the total subcontract value or the anticipated annual subcontract cost?

A11: In accordance with DFARS 204.1703(a): The $3 million dollar threshold is based upon a total estimated value, including options, that exceeds $3 million.

QUESTIONS and ANSWERS (Q&A) DoD Overseas Military Banking Program (OMBP) Request for Proposal (RFP) October 14, 2022

Q1: Will the Government provide recent security/cyber assessments of the OMBP?

A1: The recent assessment that the incumbent conducted regarding security/cyber assessment of the OMBP was to assess the current state of the OMBP’s technology environment comparing it to current industry standards, and how those industry standards align with PMO guidance, and the incumbent Contractor’s key practices.

The assessment is an internal (Contractor) assessment similar to an operational audit. The incumbent will be able to share a redacted version with a successor Contractor and thereby allow the successor Contractor to evaluate the Program based on their best practices and per the terms of the future OMBP Contract.

QUESTIONS and ANSWERS (Q&A)

October 13, 2022

Q1: In addition to operation of Community Bank under 12 U.S.C. § 90, would DoD consider operating Community Bank under 12 U.S.C. §§ 265, 266, 1767, 1789a, or 2013?

A1: We will accept proposals from any entity that is authorized to accept deposits of public money and to act as a fiscal agent of the United States, as it is in the Government’s interest to have a broad field of potential offerors to operate Community Bank. While historically the operator has been a bank and authorized under 12 U.S.C. § 90, any of the statutes cited would likely provide the necessary authorization for a Credit Union to operate Community Bank instead.

Q2: In addition to FDIC insurance, would DoD consider as the operator of Community Bank, a depository insured privately, insured in connection with another Federal fund, or operated consistent with 31 C.F.R. § 202.6?

A2: DoD policy, DoD 7000.14-R Volume 12, Chapter 33, subsection 3.1.1 identifies “Except in limited situations overseas, only banking institutions insured by the Federal Deposit Insurance Corporation and credit unions insured by the National Credit Union Share Insurance Fund, or by another insurance organization specifically qualified by the Secretary of the Treasury, shall operate on DoD installations.” An Offeror’s proposal containing an alternate method of insurance should clearly identify specifics associated with the insurance and why it should qualify as like-insurance provided as required by DoD policy.

Q3: Please describe whether accounts, deposits, and loans through Community Bank would be on the balance sheet of the operator.

A3: As DoD is not a financial institution and is unable to host accounts, take deposits, and engage in loaning money, the reporting of these activities required for any purposes would be completed by the financial institution operating Community Bank. The extent and frequency of reporting required would be a matter between the financial institution operating Community Bank and entities for which reporting is being undertaken. As this is a Cost-Plus-Fixed-Fee contract, any reporting and compliance costs that are incurred within the scope of the Contract are borne by the DoD.

July 29, 2022

Q1: Does the OMBP Contractor operate the business solely under U.S. law/reg, or do they incorporate local law/reg as well? Status of Forces Agreements are not clear on whether the successor Contractor would be exempt from foreign banking and privacy laws, but may have a viable argument that the in-person on-base only operations are subject to U.S. law only.

A1: The OMBP Contractor is responsible for adhering to U.S. banking laws and regulations during contract performance. To the extent that local law or regulations apply to operations, it is the Government’s understanding current OMBP operations performed by the incumbent banking contractor are aligned with such. In some locations there are local labor laws, labor policies associated with U.S. Government and host country agreements, and privacy laws that apply.

Q2: The RFP indicates that the Bank Secrecy Act (BSA) does not apply outside the U.S. and is therefore, non-applicable to these MBFs. How do you ensure, and evidence, adequate BSA/AML oversight and compliance?

A2: While the Bank Secrecy Act does not apply to financial institutions operating outside the United States, the Request for Proposal section H-12 identifies the OMBP Contractor must comply with the Act and it is the Government’s understanding current OMBP operations performed by the incumbent banking contractor adhere to the BSA. The OMBP Contractor’s internal operations associated with executing contract requirements must provide for adequate BSA and Anti-Money Laundering oversight and compliance.

Q3: Can you confirm that all Community Bank ATMs are on DoD installations? Do ATMs dispense/accept USD only or USD/local currency?

A3: All of the ATMs are on DoD or installations where DoD has the host country authority to operate and locations are identified in attachment J-1 of the RFP. All ATMs dispense U.S. Dollars (USD) and ATMs dispense local currency where applicable. Approximately 30 ATMs accept envelope deposits however as those ATMs are replaced through lifecycle replacements, they are currently being replaced with ATMs that do not accept deposits.

Q4: Who provides required information technology (IT) support for the various systems (teller; online banking; core banking platform, etc.)? Is IT support a component of the Home Office Staff Support mentioned above?

A4: Most first-line IT support is currently supported by the Home Office and Overseas District Offices with vendors providing second-line support. Some IT support is performed by third-party vendors.

Q5: What is the approval process for the discontinuation or addition of products/services at MBFs?

A5: The DFAS Program Management Office (PMO) will issue the OMBP Contractor a Technical Direction Letter to request a proposal to effect a change in products or services. Proposals must contain information about cost and schedule to effect the change as well as other information as applicable. If a change is approved, an additional Technical Direction Letter and/or contract modification will be issued to effect the change. The OMBP Contractor may also propose unsolicited changes, which if approved, will be effected through the Technical Direction Letter and/or contract modification process noted above.

Q6: How does the OMBP Contractor maintain compliance with the “close acct within 90 days after PCS”? How do you know (systematically) that a service member has PCSed out of theater?

A6: The OMBP Contractor typically closes accounts when individuals go through a local base clearing process prior to leaving their current assignment, a process called a Permanent Change of Station (PCS). Additionally, a Date Estimated Return from Overseas (DEROS) is present on orders issued to individuals and when accounts are established that information is maintained in OMBP systems. The OMBP contractor must exercise good-faith efforts to ensure accounts are not maintained 90 days past PCS, except as permitted by contract.

Q7: How are subcontractor selection and contract renewals handled? Is there a vendor census available?

A7: Generally, the selection and management of subcontractors is the discretion of the vendor. However, the prime contractor or subcontractor on federal government contracts must ensure their subcontractors are evaluated in accordance with FAR 15.404-3, “Subcontract pricing considerations.”

Q8: Please provide information related to the following Human Resources aspects of the OMBP: How many people are eligible for the plans?; How many people are covered under the medical plan?; What plans are offered?; Who are the carriers?; Is medical self-funded?; Are covered employees that are overseas U.S. citizens?; Are there any supplemental policies by country?; Employee contracts (where applicable); Latest employee census including division & service line designation abroad and for U.S. corporate operations (if applicable), title, department / function, location, PTE vs. FTE, salary, benefits, bonus / commissions, review rating; HRIS and Payroll operating system; Employee Handbook- HR Policies; Unique employment laws for countries identified; Compensation Philosophy; Salary Structure/Grading; Job Descriptions; Bonus/Incentive Plans; Deferred Compensation Plans; Equity Plans; 401K Plan Document; Definitions of full and part time; exempt and non-exempt; workweek, payday, minimum wage; Recruitment strategies from the U.S. Talent Acquisition team; How are staff recruited and hired in each location? Does staff work for the Fed Gov’t or the banking entity? What has been turnover rate last few years?

A8: Staff are employees of the OMBP Contractor. Specifics on the topics above may be informed by OMBP Contractor corporate practices and may vary by location. While approved costs associated with employment of individuals by an OMBP Contractor are a government cost, and the Government may negotiate costs of such, specific information necessary to manage personnel is an OMBP Contractor responsibility to establish and maintain.

Q9: Please discuss banking rules and regulations as they apply to the OMBP. Particularly related to any of the following: Bank Secrecy Act (BSA) / AML / OFAC; BSA/AML/OFAC Risk Assessment; BSA/AML/OFAC Program; Customer Identification Program Policy; CDD/EDD and Beneficial Ownership Process and/or provide applicable procedures; Fraud Prevention Program; Other applicable procedures, controls, risk assessments, and policies; BSA/AML monitoring system; Most-recent Internal (if applicable) and External Audit to ensure independence; Please provide the latest Organizational Chart for the BSA team structure.

A9: Policy and procedures to meet requirements of items listed above are managed by the OMBP Contractor. The OMBP Contractor is the financial institution operating the OMBP and the OMBP Contractor must ensure day to day OMBP operations comply with applicable banking laws, rules, and regulations. The successor OMBP Contractor would be responsible for ensuring that policy and procedures continue to meet requirements of applicable banking law, rules, and regulations.

Q10: We are in the process of becoming a licensed National US Bank and are currently partnering with sponsoring banks to support our payments gateway in the U.S. and Internationally. We have identified an international banking partner who is willing to partner with us for this opportunity with the Government. Would the Government consider an 8(a) women-owned set-aside for this opportunity or a sole source if a small business could be sponsored by a licensed international bank based in Panama that has 3 correspondent banks in the U.S. and is American owned to accomplish the goals of the RFP?

A10: The OMBP Contractor must be a licensed and insured U.S. financial institution. With regard to small business set-aside, the Government intends to proceed with full and open competition as coordinated with the Small Business Administration.

Q11: Would the DoD support a mentor/protégé model JV with an 8(a) for this opportunity with a sponsoring bank relationship.

A11: The Government intends to proceed with full and open competition as coordinated with the Small Business Administration.

Q12: Does a bank have to be the prime for this contract? If deliverables can be met with the bank as the sponsoring bank for a Small Business awarded as Prime.

A12: Yes, the Prime for the OMBP Contract must be a U.S. Bank.

July 15, 2022 Q1: Are early termination costs for subcontracts on the current Contract (HQ0423-13-D-0001) allocable costs on to the current Contract or costs for the successor Contractor if the successor Contractor opts to change subcontractors?

A1: Costs associated with early termination of existing cost-reimbursement subcontracts for the current Contract (HQ0423-13-D-0001) should not be included as part of potential Offeror Proposals. Pursuant to FAR 52.249-6 and FAR 31.205-42, reasonable costs that are allowable and allocable costs incident to the transfer or close-out of operations at the end of contract performance are allocable to the current Contract and reimbursable expenses to the incumbent OMBP Contractor.

Q2: Would it be viewed as a conflict of interest for credit unions, who operate on-base overseas under a geographic franchise, to bid?

If it is not viewed as a conflict of interest, what other implications may there be for an overseas on-base credit union if they were to be granted the OMBP contract?

A2: Any entity (financial institution) chartered, properly insured, and capable of meeting criteria and requirements identified in Section C of the RFP and providing a proposal demonstrating the ability to perform requirements identified within the RFP may submit a proposal.

The Community Bank is a separate and distinct DoD entity, which is managed but not owned by the OMBP Contractor. OMBP operations are separate and distinct from an entity’s corporate operations and existing financial institution arrangements would have to remain in place as separate and distinct from OMBP operations.

Q3: Can you provide an overview of the regulatory oversight environment? Clarify the governing regulatory agencies/bodies. Do the regulators such as the Office of the Comptroller of the Currency (OCC) or the Office of the Secretary of Defense (OSD) examine “Community Bank operated by Bank of America,” completely independent of the OMBP Contractor?

A3: The Department of Defense Overseas Military Banking Program, which is also referred to as “Community Bank,” is operated under the authority of 12 United States Code (USC) 90 through the United States Treasury designation of a financial institution as a depositary and financial agent of the U.S. Government and under the authority of Department of Defense Directive (DoDD) 5118.03 for the operation of Military Banking Facilities (MBF) on military installations. Historically, the operations of MBFs have not been considered to be “banking branches” subject to regulation or oversight. See “Comptroller’s Licensing Manual, Branches and Relocations,” Office of the Comptroller of Currency (OCC), October 2019.

Although historically MBFs are not “banking branches” and are not generally subject to regulation on that basis it remains a possibility that a new statute, rule or regulation or reinterpretation of an existing statute, rule or regulation could alter that conclusion and the DoD does not have the authority to preclude such a future possibility although we do not have any reason to believe that any action or reinterpretation is forthcoming.

Q4: What are the licensing requirements and the processes/timelines for obtaining licensing requirements (or exemptions therefrom) from the foreign banking regulators?

A4: The OMBP Contractor has authority to operate in existing OMBP operating locations without foreign banking licensing, except for the United Kingdom which requires a banking license. This operating authority is a result of Status of Forces Agreements and other international agreements between the U.S. Government and the applicable host nation. To the extent that new foreign operating locations are identified during the OMBP Contract period of performance, the U.S. Government will ensure international agreements permit operations and if licensing or other notification of OMBP operations is required, work with the contractor as circumstances dictate to assist in facilitating operations.

Q5: What is composition of the U.S. based Home Office Staff Support team (e.g., Exec Mgt; Finance; Ops)?

A5: Functions in the Home Office currently encompass all core roles to support OMBP operations to include: Executive Management, Human Resources, Loan Servicing, Technology, Online Banking, Project Management, Business Controls, Reconciliation, Card Services, Training & Compliance, Procedure Management, Contract Administration, Wires, Finance and Accounts Payable.

Q6: Does the OMBP Contractor maintain/manage a dedicated call center for Community Bank?

A6: Yes the OMBP has call center operations with a live response option and a 24 hour Interactive Voice Response capability. The call centers are currently located in San Antonio and in Germany. Information about call center operations may be viewed online at: https://www.dodcommunitybank.com/home/newcomer/contact. Additionally, OMBP customers may submit questions or concerns to customer service personnel through secure email capability available on www.dodcommunitybank.com.

Q7: “...the servicing MBF shall provide transactional U.S. currency to defense credit unions… at no cost…” Can you provide context to this requirement?

A7: In performance under the Contract, the OMBP Contractor acquires U.S. currency for use by U.S. credit unions operating overseas on DoD installations. While there are costs incurred under the Contract to do so, currently there are no charges levied by the OMBP Contractor to the U.S. credit unions.

Q8: How do you control the ban on marketing the OMBP Contractor’s products to Community Bank account holders?

A8: The OMBP Contractor is responsible for establishing controls and procedures to ensure that corporate offerings are not introduced during contract performance. Additionally, use of any Personally Identifiable Information or names attained through OMBP contract performance for corporate marketing purposes is strictly prohibited. Information on this topic may be shared in training and covered as part of management routines. The current RFP identifies that upon approval of the DoD, certain corporate marketing to individuals returning to the United States may take place.

Q9: Any special considerations for Business Continuity Plans?

A9: The OMBP has established Business Continuity Plans that the OMBP Contractor will be responsible for maintaining and ensuring are appropriate to deliver intended results. Periodically, the OMBP Contractor may be required to participate in table-top exercise plans with the DFAS PMO or local commands.

Q10: Per C-16: The Contractor…shall provide banking services (including ATMs) to Department installations within the United States. Can you provide context to this requirement?

A10: This provision was in the Draft RFP but was not in the final RFP so proposals should not contain anything related to this requirement.

Q11: What are the key elements of a transition plan between the incumbent Contractor and a successor Contractor?

A11: The transition plan should identify tasks, resources, costs, and schedule for a new OMBP contractor to operate the OMBP as described within the RFP (See C-17).

Q12: Does the OMBP Contractor or DoD maintain the subcontracts/licensing agreements with vendors and operating agreements with the installations? Are all subcontracts/agreements transferable?

A12: The OMBP Contractor contracts directly with vendors. A list of agreements above a set threshold ($100,000) is reported to DoD. DoD maintains the ability to review all agreements. All subcontracts/agreements are transferable. To the extent that a subcontract/agreement were not transferable, the program would absorb any increased costs, assuming the costs were otherwise reasonable, allowable, and allocable. The OMBP Contractor does not have operating agreements with local installations.

A list of current licensing agreements, subcontracts/agreements for the current Contract (HQ0423-13-D-0001, H-14 Report) for goods or services acquired in excess of $100,000 will be provided to FIs that request them and have completed and submitted the NDA to the Contracting Officer.

Q13: What risk does the OMBP Contractor bear related to increased third-party contract costs (e.g., cost to maintain ATMs; facilities maintenance expense)?

A13: There is no risk to an OMBP contractor for increased third-party contract costs insomuch as costs have been approved by the DFAS Contracting Officer prior to contract award and during the annual budget cycle review. The third-party costs are reimbursed on a cost basis. Although the risk of increased costs falls upon the DoD it is expected that the OMBP Contractor works to ensure all costs to operate the program, including escalation factors for future costs with third-party vendors, provide best value to the DoD and are in accordance with the Cost Accounting Standards and Contract Cost Principles in FAR Parts 30 and 31.

Q14: Please provide transaction-level or financial detail for 2019, 2020, and YTD 2022 for the OMPB.

A14: UNREDACTED version(s) of the OMBP Program Management Report (which provides the data from the OMBP Contract by year for OMBP Banking Operations will be provided to potential offerors upon request after completion of the non-disclosure agreement and submission to the Contracting Officer. Please keep in mind that the Government considers some of the content Non-public or Confidential information. Potential offerors are reminded that it is expected that all reasonable measures to protect the confidentiality and avoid the unauthorized use, disclosure, publication, or dissemination of the disclosing the contents are taken.

Q15: Please provide additional information pertaining to the Overseas Branch Network and ATMs, currencies in use, need for cash after hours, physical characteristics of the MBFs, and inventory of equipment.

A15: The following additional OMBP information is provided as follows:

1. Overseas Branch Network and ATMs

a. Specific location of each office - MBF Operating Locations are identified in Section J, Attachment J-1 of the RFP.

b. For each office

i. Hours – MBF Hours of Operation are identified in Section J, Attachment J-2 of the RFP.

ii. Staffing – Information related to FTEs is provided in Section J, Attachment J-17 of the RFP as well as the UNREDACTED version(s) of the OMBP Program Management Report, which will be provided to potential offerors upon request after completion of the non-disclosure agreement and submission to the Contracting Officer. Please keep in mind that the Government considers some of the content Non-public or Confidential information. Potential offerors are reminded that it is expected that all reasonable measures to protect the confidentiality and avoid the unauthorized use, disclosure, publication, or dissemination of the disclosing the contents are taken.

iii. Accounts domiciled – As of March 2022:

1. Loans 2,973

2. Checking 53,947

3. Savings 12,184

4. # customers: Estimated at 50K

2. Currencies in use:

a. Local: Euro, Pound Sterling, Yen, and Won at locations where these currencies are used in surrounding areas

b. USD: At all locations

c. Other: None on a recurring basis although there may be local requests to acquire other currency for use by local commands

3. Need for cash after/off hours: For local command use, on an extremely limited basis there could be the need to provide cash outside of normal operating hours. This request would be worked at the local level. For individuals, ATMs are typically placed in locations permitting 24/7 access.

4. Physical characteristics of banking centers:

a. Square footage: Varies by location. DoD policy requires that space provided is adequate to conduct retail banking operations. See RFP H-16.b.(8).

b. Description of location (# offices/teller stations, etc.): There are global standard fixtures and furniture which can be seen in photos which will be posted with the contract opportunity documents in conjunction with July 15, 2022 Q&A responses and incorporated into Section J, Attachment J-1a of the RFP in Amendment 5.

c. Vaults/safes: Each location has a vault and/or safe based on design or build.

d. Space for additional equipment such as ITM’s: Space for additional equipment would vary by location.

5. Inventory of equipment:

a. ATM’s: There are currently 276 current ATMs. Specific locations and lifecycle information pertaining to the ATMs is provided in Section J, Attachments J-1, J-19, and J-20 of the RFP.

b. Security equipment: Security equipment is furnished and maintained by the base and varies by location

Q16: Please provide a description and diagram of the OMBP IT network structure.

A16: Please refer to RFP Section J, Attachment J-18 for the OMBP Information Systems Architecture Overview. The Technical Architecture Diagram identifies all major core applications in use, as well as application to application interfaces. Detailed descriptions of the core banking applications, functionality within those applications, and specific software used within the environment will be included as part of the incumbent Contractor’s work performed during a transition to a new OMBP contractor.

Q17: Where are the locations of operations and related operations centers Stateside vs. OCONUS?

A17: There are currently four operating locations (Home Office in San Antonio TX, a District Office in Mainz-Kastel Germany, a District office at Camp Humphries Korea, and a Main Cash Vault at Miseau Army Depot).

Q18: Which services not offered today does the DoD hope to offer within next few years?

A18: As stated in B-3. of the RFP “…the Program Management Office may require the Contractor to implement relevant new technological advancements, upgrade the current system platforms and telecommunication capabilities and other innovations throughout the life of the Contract. Such changes will be implemented by a contract modification.

Technology and Products/Services Refresher – The Contractor shall conduct and provide the Government with a technology and products/services review annually, in accordance with Section C, paragraph 6-5(c).”

Q19: With regard to Fraud Detection/Prevention/Mitigation:

a. Please advise of Fraud incidents and how they are expected to be managed by Bank and on-base (base personnel as victim and as perpetrator)

b. Note expectations of Bank communication with Base MP regarding fraud incidents

c. Please advise of Fraud prevention and mitigation procedures

A19: Dependent on dollar amount, if internal fraud is detected, it is turned over to the base. The local forces guide next actions. In some cases, local labor law requirements will need to be followed. The Program deploys audits, cash counts, card fraud detection, and other standard actions to prevent financial fraud.

Q20: Please provide information pertaining to Cybersecurity Maturity Model Certification (CMMC) 2.0 certification level, NIST SP 800-171 compliance, and Information Security and Incident Response policies, procedures, and other relevant documentation.

A20:

a. CMMC: DFARS clause 252.204-7021 CYBERSECURITY MATURITY MODEL CERTIFICATION (NOV 2020) and the requirements contained therein are not applicable to the OMBP at this time (i.e., specific CMMC level is not a requirement).

b. NIST SP 800-171: The requirements in DFARS 252.204-7019 NOTICE OF NIST SP 800-171 DOD ASSESSMENT REQUIREMENTS (NOV 2020) are applicable to the OMBP. Please note, the links have been updated in the DFARS clause252.7019 published MAR 2022 and can be found at: https://www.acquisition.gov/dfars/part-252-solicitation-provisions-and-contract-clauses#DFARS_252.204-7019 DFARS 252.204-7019 and 252.204-7020 (both dated MAR 2022) will be updated in RFP Amendment 5 accordingly.

c. Information Security and Incident Response: Community Bank has robust information security and internal control processes and testing. For security reasons, these cannot be publically revealed. These will be revealed as part of the transition.

Q21: Would the Government consider a cost incentive type contract, rather than a predominantly CPFF type contract?

A21: Offerors are required to submit Cost Proposals with predominantly CPFF type CLIN structures pursuant to Section B of the RFP.

Q22: Monthly payments to the Contractor include: 1.) fixed fee; 2.) operating loss payment (if applicable); and bad debt expense (if applicable). Can you provide insight on any financial risks to the Contractor (e.g., failure to get DoD approval for allowable expenses; gov’t shutdown)?

A22: There are no financial risks provided that all reimbursable costs are reasonable, allocable, legally permissible, and government approved. In the event of a government shut down or failure to raise the debt ceiling, payments will be made, with applicable interest, as soon as the shut down ends or the debt ceiling is raised.

June 28, 2022

Q1: Is there a Community Bank Charter?

A1: Community Bank does not have a separate Charter from the incumbent Contractor/financial institution (FI). The Community Bank is not a “Bank” in the usual sense of the word. It is a government program that is implemented through a contract with a charted financial institution. The incumbent Contractor (Bank of America) is a chartered bank/FI.

Q2: Is the Contractor a Federal Deposit Insurance Corporation (FDIC) insured FI?

A2: Yes, the FI must participate in the FDIC program. The depositors are protected by the insurance as provided by law and regulation. The costs of insurance for Community Bank depositors are a program expense, assuming that the costs are otherwise allowable under DCAA rules.

Q3: Is there a FDIC number for the Legal Entity?

A3: Community Bank is not a legal entity. Community Bank customers receive protection under the FDIC. The insurance premium is paid by the Contractor and is reimbursed under the Contract if the costs are otherwise allowable under DCAA rules.

Q4: Is Community Bank a Legal Entity?

A4: No. Community Bank is a government program operated by a contractor/FI on behalf of the Department of Defense.

Q5: Can the successful Offeror talk to the Community Bank customers about insurance or other FI product offerings on the way out of the Country?

A5: The marketing of financial services broadly speaking to include insurance to Community Bank customers, including permissibility, timing, and materials will be subject to the approval of the DoD.

Q6: Who works with the host country to have the ability to operate?

A6: The OMBP Contractor and the DoD work together to obtain the needed authority to operate. The cost, if any, of obtaining the necessary authorizations, is a cost of the Contract, assuming the costs are otherwise allowable under DCAA rules.

Q7: Who signs the agreement? (Community Bank, OMBP Contractor, PMO/DOD Banking?)

A7: This will be determined by the specifics of the Status of Forces Agreement (SOFA) or implementing agreement. To the extent that new agreements are necessary, costs associated with obtaining those agreements would be a cost of the Contact, assuming the costs are otherwise allowable under DCAA rules.

Q8: Is there a Mobile Banking APP?

A8: Yes, there is a Mobile Banking APP available for OMBP customers.

Q9: Is there any added value in connecting with the PMO?

A9: The PMO and the incumbent Contractor interact on a daily basis. The Contractor and the PMO are not directly systemically connected.

Q10: Is there system integration between Community Band and the OMBP Contractor?

A10: No, the Community Bank has separate systems from corporate Bank of America (incumbent). To the extent that some unknown integration exists, the costs of disintegration would be a cost of the Contract, assuming the costs are otherwise allowable under DCAA rules.

Q11: Who tracks the dollar value of funds held in account?

A11: The OMBP Contractor initially tracks the dollar value of the amounts in the accounts. The OMBP Contractor reports the dollar value of the accounts to the PMO.

April 7, 2022

Q1: The DFARS Proposal Adequacy Checklist (i.e., DFARS 252.215-7009) was included in the updated solicitation materials. Per DFARS 215.408 (4), this checklist is to be included in proposals that require the submission of certified cost or pricing data. Section M-1 of the solicitation states that this is a competitive source selection, which may create an exception to submit certified cost or pricing data under FAR 15.403-1(b)(1). Please explain why this checklist was included in the solicitation and whether or not it is required to be completed as part of an offeror’s proposal.

A1: DFARS 252.215-7009, entitled “Proposal Adequacy Checklist” was erroneously included in the Draft RFP and was removed from the Final RFP prior to issuing the Solicitation. The Proposal Adequacy Checklist will not be required for proposal submissions.

Q2: We request additional guidance from the government as to the level of detail required on projecting costs for the replacement of existing government furnished property over the period of performance in the RFP. There are over 10,000 items in the current inventory and it seems unrealistic that an offeror could reasonably project the timing and cost for such a magnitude of items. Further, the government exercises considerable control over replacement of existing equipment in the current contract. The annual budget submittal includes a request for replacement of property with updated pricing for each item. The request is not based on a planned lifecycle but on the expectation the items will no longer be serviceable in the coming fiscal year. The government evaluates the requests each year and often provides guidance to defer or cancel items. The expected costs for replacement of existing property would not be subject to fee and, consequently, not viewed as a differentiator between proposals. Actual costs for replacement of equipment in the current contract have ranged from $269,000 to $963,000 in any given year. We have no basis for developing a reasonable approach to estimating this cost for the RFP.

We do agree a reasonable estimate for the replacement of ATMs can be provided. Future pricing on each ATM will be subject to changes in makes and models of ATMs. We would be willing to provide an estimate for replacement of ATMs based on pricing available to us at this time.

A2: The Government established an estimate of the costs for replacement of existing government property (which includes government furnished property and contractor acquired property) as well as any non-replacement property (i.e., additional property that’s not replacing existing property). The Government estimates that $500,000 will be the cost for the OMBP “Equipment Purchases” for each year in the base year and nine one-year options periods ($250,000 for the six-month extension) during the period of performance in the RFP. An Amendment will be issued to the Final RFP (issued March 30, 2022) to reflect the $500,000 baseline. The Government is not requiring offerors to propose an item-by-item methodology for Equipment Purchases and recognizes the difficulties inherent in predicting future costs, especially over a range of equipment and supplies. Although the baseline has established an estimate for OMBP “Equipment Purchases” Offerors should describe their proposed methodology for MBF “Equipment Purchases” in sufficient detail so the methodology can be analyzed to determine if the proposed approach will result in fair and reasonable costs. Offerors should note that “Equipment Purchases” is exclusive of ATM Purchases and Installation on the Cost_Pricing Matrix.

Q3: Would DFAS be open to amend the current RFP to include the submission of the GPATs post the contract award?

A3: The Government’s expectation is that offerors submit the GPATs (RFP Attachments J-10, J-11, and J-12) to the best of their ability as Appendix C in their Technical Proposal.

Q&A October 26, 2022

OMBP RFP