PWS - EFS- 7-12-21 - Audibility.pdf

DRAFT – For Reference Purposes Only

OFFICE OF INSPECTOR GENERAL HOUSING AND URBAN DEVELOPMENT

OFFICE OF LEGAL COUNSEL

GINNIE MAE RELATED EXPERT FINANCIAL SUPPORT SERVICES

INITIAL ORDER for AUDIBILITY SURVEY AND RELATED SUPPORT

The Office of the Inspector General (OIG) at the U.S. Department of Housing and Urban Development (HUD) is an independent government entity established by the Inspector General Act of 1978, to safeguard government funds provided to HUD to assist and support affordable housing and community development from fraud, waste, and abuse. Agency staffs are located in Washington, DC and in regional and field offices across the country.

1.0 PURPOSE and OBJECTIVE

The purpose of this requirement is to obtain subject matter expertise to conduct an Audibility Survey of GNMA under HUD OIG’s GNMA Related Expert Financial Support Services vehicle.

1.1 BACKGROUND

As per the GNMA Related Expert Financial Support Services Vehicle Performance Work Statement.

1.2 SCOPE

The scope of this order is to obtain expert support services to conduct an Audibility Survey of GNMA and provide expert advice in relation to actions undertaken, with specific focus on Assessment of Governance and Internal Controls and Risk Assessment.

1.3 CONTRACTOR PERSONNEL

1.3.1 PROJECT/PROGRAM MANAGER/TEAM LEAD(S). The Contractor shall provide a Project/Program Manager/Team Lead or equivalent (PME)) who shall be responsible for all Contractor work performed under this action. The role of PME status may be assigned to any individual supporting this action who is a Certified Public Accountant and designated by the Contractor as having the authority to obligate the Contractor.

1.3.2.1 The PME shall be a single point of contact for the Contracting Officer and the COR for the contract, and is designated as KEY. The PME shall be responsible for all deliverables, staffing, and actions under this requirement. The name of the PME, and the name(s) of any alternate(s) who shall act for the Contractor in the absence of the PME, shall be provided to the Government. During any absence of the PME, only one alternate shall have full authority to act for the Contractor on all matters relating to work performed under the contract. The PME and all designated alternates shall be able to read, write, speak and understand English.

1.3.2.2 The PME shall be available to the COR via telephone during normal business hours.

1.3.3 QUALIFIED PERSONNEL. The Contractor shall provide qualified personnel to perform all requirements specified in this PWS. Personnel proposed shall be in accordance with the labor mix and approach described by the contractor’s proposal. Resumes describing the qualifications of the Contractor’s key personnel will be submitted to the COR on an ongoing basis as new personnel are assigned to this audit.

1.4 KICK OFF MEETING

The contractor shall be available for a Contract Kick Off meeting within 10 Business Days of the date of award. This may be in person at HUD OIG HQ or via teleconference.

1.5 PERIOD OF PERFORMANCE

The primary place of work shall be the contractor’s facilities. HUD OIG will provide conference space/work space at secondary worksites, to include HUD OIG HQ in Washington DC and other offices located CONUS as necessary.

1.6 TRAVEL

The Contractor may be required to travel to conduct fieldwork at the contractor and/or subcontractor’s location, unless otherwise specified. Travel shall be approved in advance by the COR or Contracting Officer. Travel is subject to the Federal Travel Regulations.

1.7 SPECIAL SECURITY AND INFORMATION CONTROL REQUIREMENTS

In addition to any security requirements contained in the Terms and Conditions, the contractor shall adhere to the following:

1.7.1 CONFIDENTIALITY AGREEMENTS

The Contractor and its employee performing the work under this order must be required to submit a non-disclosure/confidentiality agreement.

2.0 GOVERNMENT TERMS AND DEFINITIONS

ARO After Receipt of Order CAPD Contracts and Procurement Division CD Communications Division CO Contracting Officer COR Contracting Officer Representative CPOC Central Point of Contact CS Contract Specialist DOA Date of Award GFE Government Furnished Equipment HUD Housing and Urban Development MFD Multi-Function Device OEM Original Equipment Manufacturer OIG Office of the Inspector General PO Program Office SAR Semi Annual Report to Congress

3.0 GOVERNMENT FURNISHED RESOURCES

The government shall furnish necessary access to employees, facilities, and information systems as necessary for the contractor to complete the required work. On a case by case basis, HUD OIG will furnish a laptop if necessary, to access specific government networks, subject to completion of appropriate background checks. For access to certain information the Contractor will be required to sign a Non-Disclosure Agreement or similar documentation.

4.0 CONTRACTOR FURNISHED RESOURCES

The contractor shall furnish all resources necessary to complete the requirements, excluding those items specified in 3.0.

5.0 REQUIREMENTS

The contractor shall conduct an Audibility Survey of GNMA, to include the below taskings:

5.1 PROGRAM PLANNING

The Contractor shall develop a detailed Program Plan addressing Section 5.2 and 5.3, to include, at a minimum, an outline and schedule identifying major milestones, areas of responsibility, identify necessary resources or expertise issues/bottlenecks and/or information needs, and similar. This shall be provided to HUD OIG as a draft plan within 30 days of Kick Off for review and comment. Upon return of comments, the contractor shall return an updated version within five (5) business days for final review. Upon approval, the contractor shall proceed with execution.

5.2 ASSESSMENT OF GOVERNANCE AND INTERNAL CONTROLS

The contractor shall conduct an assessment of Governance and Internal Controls of GNMA, focusing on the following areas and to result in an interim, draft final, and final reports, with dates to be agreed upon in the Program Plan:

a. GM Structure, to establish a Map/Flow Chart of Business Processes to address, but not be limited to identifying roles and responsibilities within GNMA GM structure, description and charting of GNMA Systems to include Ownership and Operations, GNMA Data Collection, GNMA business processes, and outlines GNMA systems and sources of information to help prioritize HUD OIG engagements and oversight efforts.

b. Assessment of Key Products, to include but not limited to Single Family Housing (SF), Multifamily Housing (MF), Multifamily Mortgage Backed Securities (MF MBS), HECM MBS, Stripped MBS, and REMICS.

c. Assessment of Key Processes, to include but not be limited to Issuer approvals, securitization, issuer monitoring, transfer of MSR, default and termination, investor payments, and investor reporting.

d. Assessment of Key Participants in GM Programs, to include but not be limited to:

1. Process Participants: ex. FBNY, document custodians, issuers, sponsors, MERS, etc. ad their relationship with GNMA.

2. Other regulators: ex. OCC, Treasury, State Banking Regulators and their relationship with GNMA.

3. Investors and Other Market Participants

e. Assessment of GNMA Sources of Financing/Sources of collateral

f. Assessment of Legal authority and requirements on GNMA

5.3 RISK ASSESSMENT

The contractor shall conduct a risk assessment of GNMA, focusing on the following areas and to result in interim, draft final, and final reports, with dates to be agreed upon in the Program Plan:

a. External Risks, such as Macro Economic and Market Risks

b. Internals Risks, such as Risk in the Governance and Delegation of Authority, Business Processes, Use contractors, Technology Issues, Internal Controls and Data Information Systems

c. Counterparty risks, to include Bank vs. Non-Bank issuers

d. Crisis Readiness

5.4 TRAINING SUPPORT IN RELATION TO SURVEY TOPICS

The contractor shall provide three (3) training sessions subject to Section 5.3 of the Vehicle PWS, as they relate to sections 5.1 and 5.2 of this order. Training will be based and requested on the ongoing and/or completed results of the Survey effort, with the first Training Action Request anticipated three months after contract award. One (1) session will be requested every three (3) months thereafter, or as agreed to by the COR and CTR PME.

5.5 REGULAR REPORTING and REGULAR MEETINGS

The Contractor shall provide a biweekly written report to the COR, to include at a minimum work performed during the preceding time period (including labor categories/hours) and broken down by task, and a record of tasks performed in sufficient detail as to allow the COR to verify invoiced work. The report shall also include status updates for assigned tasks and projects, issues identified, and general projections/tasks for the next reporting period, in addition to any other fields as requested by the COR.

A regular meeting will be held monthly, to include the COR, the Contractor PM or Team Lead, on a date jointly agreed to by both parties. Meetings may be held more frequently by request of the COR if needed to address emergent issues.

6.0 REFERENCE DOCUMENTS AND LINKS

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7.0 DELIVERABLES AND SUCCESS CRITERIA

ITEM SOW DELIVERABLE DUE BY

1 1.4 Kick Off Meeting With 10 Business Days of Award

2 5.1 Program Plan Draft within 30 days of Kick Off, Final within 5 Business days of Government Comments

3 5.2 Assessment of Governance and Internal Controls Reports, due dates to be agreed upon

4 5.3 Risk Assessment Reports, due dates to be agreed upon

5 5.4 Training provided via Vehicle

PWS 5.3

Initial Request to be made three (3) months after kick off and every 60- 90 days thereafter or as agreed to.

6 5.5 Reporting and Regular Meetings Biweekly and Monthly