7 - Bloomberg JOFOC.pdf

FOR OFFICIAL USE ONLY

Source Selection Information -- See FAR 2.101 and 3.104

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

1. Identification of the agency and the contracting activity.

This justification for other than full and open competition has been prepared by the Commodity Futures Trading Commission (“CFTC” or “Commission”), Business Operations Branch (BOB), 1155 21st Street, NW, Washington, DC 20581.

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

The action being approved is the renewal of the CFTC subscriptions to the Bloomberg Professional Terminal Services including Bloomberg Shared Terminals, Disaster Recovery, and Bloomberg Valuation Service (BVAL) data. The contract will be for one (1) base year and four (4) one-year options.

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

The purpose of this contract is to renew the CFTC subscriptions for Bloomberg Professional Terminal Services. The Bloomberg shared terminals are currently located at three (3) CFTC office locations and provide the Commission with required financial news, market data, and other financial information required to perform oversight of the markets.

The total estimated value of this contract is $1,491,708.00 which includes the base year and all four (4) one-year options.

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

The statutory authority permitting other than full and open competition for this requirement is 41 U.S.C.3304(a)(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 CFTC Division of Market Oversight (DMO) utilizes a variety of information sources to maintain surveillance of commodity market activity. There is no single source that provides all the information the CFTC needs for market oversight. Bloomberg is one of those sources. Other sources include LexisNexis, Westlaw, and London Stock Exchange Group.

Bloomberg is a unique source for financial data. It provides interest rate related products and Credit Default Swaps and Credit Default Swap Indices (CDS/CDX) that are critical to the CFTC mission. Additionally, Bloomberg is the only vendor that offers a shared terminal service (as compared to individual licenses).

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

Pursuant to the requirements of RFO FAR 6.103(d) (2), RFO FAR 6.104, and FAR 5.201(b)

(1) (i), CFTC posted a presolicitation notice of its intent to procure Bloomberg professional terminal services on a sole source basis. The notice described CFTC’s requirements and stated that it would consider responses from all responsible sources received. The announcement was posted on June 5, 2025, with a response date of June 12th, 2025. No responses to the announcement were received. Therefore, negotiations were conducted with Bloomberg L.P. on a non- competitive basis.

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

Bloomberg provides its commercial subscription prices that are offered to all customers for these services. The CFTC has been using these services for many years and the prices have been reasonably stable with an average annual escalation of 3%. It has been an industry practice to apply a three percent 3% increase each year for these types of commercial licenses and subscriptions.

8. A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted.

CFTC conducted market research and could not identify another single provider that offered Bloomberg’s proprietary interest rate data, nor was there another provider that offered a shared terminal service. However, as described in section 6 of this justification, per the requirements of RFO FAR 6.103(d) (2), RFO FAR 6.104 and 5.201(b) (1) (i) CFTC posted a notice on SAM.gov of the Commission’s intent to negotiate a contract for the Bloomberg Professional Terminal Services on a sole source basis. The announcement stated that all responses would be considered, but none were received.

9. Any other facts supporting the use of other than full and open competition.

N/A

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

As stated in sections 6 and 8 of this justification, no sources expressed an interest in this requirement. No responses were received to the SAM.gov notice.

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.

Bloomberg Shared Terminals, Disaster Recovery, and BVAL data under the pending contract will be limited to Bloomberg L.P. because of its proprietary data and unique shared terminal service. However, the CFTC will continue to monitor the market when contemplating future acquisitions for this requirement and will compete future requirements for these services if possible.

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12. Certifications and Approvals

Technical Personnel Certification

I certify that the data supporting the recommendation to solicit and award on an other than full and open competitive basis is accurate and complete to the best of my knowledge and belief.

Norma Ruiz Date Technical/Requirements Certification

Contracting Officer’s Certification I certify that the data supporting the recommendation to solicit and award on an other than full and open competitive basis is accurate and complete to the best of my knowledge and belief.

Benjamin Van Wormer Date Contracting Officer

Approval in accordance with FAR 6.104-2(a)

William Roberson Date Senior Procurement Executive