Justification__Approval_IDC_FBO.pdf

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION FOR OTHER THAN SIMPLIFIED ACQUISITIONS (FAR Part 6)

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Sole Source Justification”

a. Federal agency: Pension Benefit Guaranty Corporation (PBGC)

b. Contracting Activity: TAS Investment Securities Pricing Services

c. Project Officer Information:

• Project Officer Name: Tracy Soforenko

• Department: IT & Business Modernization

• Office No.: 5549

• Phone: 202 326-4000 x3943

d. Type of Document Justification and Approval

2. Nature and/or description of the action being approved.

a. Acquisition purpose and objectives.

The Trust Accounting System (TAS) is an investment portfolio and accounting solution managed by the Financial Operations Department (FOD) to support the accounting and financial reporting of investment assets, plan receivables, and liabilities related to terminated pension plans and the commingled investment portfolio through an application service provider model. One core component of this solution is the ability to automatically obtain market data including security master file updates, securities prices, and corporate actions for securities within the portfolios of terminated pension plans.

PBGC requires:

• End-of-day pricing data from markets and exchanges around the globe;

• Real-time market data from a broad range of global sources at a range of speeds;

• Historic pricing data of wide variety of assets across asset categories;

• Securities Master File data;

• Corporate Actions data

Upon receiving a system request through the Trust Accounting System (TAS) the pricing service provider Interactive Data Corporation (IDC) obtains applicable prices for securities requested and creates a normalized file which is delivered though a pull process. Data is pulled by the TAS application server from the IDC pricing service and processed using the Message Center in Eagle ADMS. In addition, PBGC users leverage IDC’s Remote Plus toolset to make ad hoc requests for securities prices directly within Microsoft Excel templates which are later uploaded into specialized message streams in Eagle ADMS.

b. Project background.

Alternatives Analysis: Between August 2009 and November 2009, PBGC conducted an alternatives analysis to determine the most appropriate approach for delivering the required Trust Accounting functionality. A Commercial Outsource model was selected from amongst available alternatives.

Full Service ASP Implementation Acquisition: In 2010, PBGC contracted with Booz Allen Hamilton (BAH) to perform an evaluation of available products/services and implement the selected products/services as a full service TAS solution.

COTS Product Selection Approach: The TAS team followed a structured and thorough approach in evaluating the available COTS products for implementation at

PBGC.

From September 2010 through May 2011, the Securities pricing services market was evaluated by conducting extensive market research using various research methods including reviews of Gartner studies, online profiles, trade publications, the team’s industry experience, and other industry sources. Five criteria were documented for the investment security pricing vendor evaluation and were prioritized during discussions with PBGC TAS user groups. Three leading investment security pricing vendors were identified to have enough fit for further analysis after the market research. The criteria were presented to the list of three vendors. Vendor service capability and cost model documents were requested from the three vendors. The vendors highlighted their products in responses to the requests. The vendors were evaluated from both functional and technical perspective. The TAS team also assessed risks to the PBGC for each of the three vendors. Based on the evaluation, PBGC selected IDC as the vendor to provide investment security pricing for integration with the Eagle Investment System COTS-based solution.

In May 2011, PBGC chose IDC’s Fund Run and Remote Plus products/Services from among the commercially available options based on their best fit to PBGC’s requirements.

Implementation: PBGC worked to configure the Eagle ADMS product to meet PBGC requirements and integrate the application with IDC’s Fund Run and Remote Plus products. In January 2012, BAH executed a sub-contract with Interactive Data Corporation for use of the Fund Run and Remote Plus products. Custom integration and reporting was implemented to meet PBGC’s requirements.

Production Operation: TAS began production operation in January 2013. TAS serves as PBGC’s system of record for the Trust Fund. PBGC is actively using IDC’s Fund Run and Remote Plus products in production.

c. Project Value and Timeframe.

Based on market research conducted before and during the TAS Investment Package Evaluation, the Investment Industry provides the most favorable pricing if agreements are five years in duration. Understanding the limitations of federal contracts, this contract is defined as a base year and 4 one year option periods beginning July 1, 2013.

Based on our draft Independent Government cost Estimate, we anticipate a contract across the five options valued at just under $1 Million.

d. Authority.

This contract action is being sought under the FAR 6.302-1, only one responsible source and no other supplies or services will satisfy agency requirements.

3. A description of the supplies or services required to meet the agency’s Needs (including the estimated value).

PBGC requires the following services from IDC:

A. Security Master File Information (new and updates)

B. Month End Prices for all current holdings in the TAS Security Master File

C. Ad Hoc End of Day Pricing for the holdings of terminated Plans on the Date of Plan Termination (DOPT) along with supplemental end of month prices

D. Corporate actions for securities

The table below outlines the anticipated dollar value of these services over the base and 4 option years.

Component of Service Base Year Option Year 1 Option Year 2 Option Year 3 Option Year 4 Contract total FundRun Monthly Pricing $72,800 $144,334 $144,334 $144,334 $144,334 $650,137 Corporate Action Update $630 $630 $630 $630 $630 $3,150 Securities Master File Update $20,844 $41,325 $41,325 $41,325 $41,325 $186,145 RemotePlus DOPT Pricing $16,856 $16,856 $16,856 $16,856 $16,856 $84,278

Total $111,130 $203,145 $203,145 $203,145 $203,145 $923,710

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

The specific authority allowing this action is 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 use of the authority cited.

The only company able to provide Interactive Data Corporations’ Fund Run and Remote Plus Products is Interactive Data Corporation. The IDC Fund Run and Remote Plus are commercial off the shelf service developed and supported exclusively by Interactive Data Corporation.

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

A notice will be posted on FedBizOpps advising of the intent to award this as a Sole Source procurement.

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

The contracting officer will perform a price analysis to ensure the price to the Government will be fair and reasonable.

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

Extensive market research was performed during FY 2010 and FY 2011 leading to the selection of IDC Fund Run and Remote Plus as the PBGC TAS Securities Pricing Service.

In March 2013, PBGC confirmed that Interactive Data Corporation remains as the only service provider of the IDC Fund Run and Remote Plus products.

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

(i) Explanation of why technical data packages, specifications, engineering descriptions, statements of work, or purchase descriptions suitable for full and open competition have not been developed or are not available.

(ii) When 6.302-1 is cited for follow-on acquisitions as described in 6.302-1(a)(2)(ii), an estimate of the cost to the Government that would be duplicated and how the estimate was derived.

(iii) When 6.302-2 is cited, data, estimated cost, or other rationale as to the extent and nature of the harm to the Government.

N/A

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

N/A

11. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made.

N/A

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

I, Mark Miller, hereby certify that this justification and all the data supporting this justification are accurate and complete to the best of my knowledge and belief.

Original Signed Mark Miller, Contracting Officer Date:

Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for limited sources) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

In terms of the rationale for limited sources, I, Theodore J. Winter, Jr., hereby certify that this justification is complete and accurate.

Original Signed Theodore J. Winter, Jr.

Financial Operations Department Director

Date:

13. Reviews and Approvals.

Original Signed Steven Kvalevog, Competition Advocate Date: