PWS Mortgage Market Data.docx

PERFORMANCE WORK STATEMENT

DEPARTMENT OF VETERANS AFFAIRS

Mortgage Market Data Procurement, Normalization, and Modeling

Date: July 26, 2024 PWS Version 1.0

CONTENTS

5.5.2 ENVIRONMENTAL, SOCIAL AND GOVERNANCE (ESG) LGY DASHBOARD MAINTENANCE AND SUPPORT ……………………………………10

Contract XX Draft Task Order XX

BACKGROUND

In support of OPEN Government Act, Pub.L. 115-435, the Department of Veterans Affairs (VA) and ongoing efforts to support evidenced based decision making, the Veterans Benefit Administration, VBA Loan Guaranty Service (LGY) has a need for access to non-VA public and private economic, credit, and housing market data that will allow LGY staff to compare LGY portfolio data to broader markets, assess future loan and borrower performance, and provide the capacity to test and implement data-driven program policy decisions. This data will extend LGY’s ability to assess, manage, and deliver sophisticated, evidenced-based decision making. Additionally, public and private market data will provide comparative statistics and modeling to assess and accurately narrate the LGY loan portfolio to numerous internal and external stakeholders. This procurement will also provide LGY with enhanced ability to meet its established strategic objective of being a data-driven organization, adding more diverse data access to key decision makers and end users across the organization.

APPLICABLE DOCUMENTS

The documents in Section 2.0 in the Performance Work Statement (PWS) apply for the performance of this effort. The contractor shall be guided by the information contained in these documents in performance of this PWS, each can be found at the website indicated:

1. Privacy Act, 5 United States Code (U.S.C.) §552a, which is available at: https://www.gpo.gov/fdsys/granule/USCODE-2010-title5/USCODE-2010-title5-partI-chap5- subchapII-sec552a/content-detail.html

2. VA Pamphlet 26-7: Lender’s Handbook, which is available at: http://www.benefits.va.gov/warms/pam26_7.asp

3. Relevant circulars pertaining to VA Home Loan Program on VA’s Website: https://www.benefits.va.gov/HOMELOANS/resources_circulars.asp

4. VA Directive 6500, Information Security Program (VA Handbook 6500.6, Contract Security, which is available at: http://www.va.gov/vapubs

5. Veterans Affairs Acquisition Regulation (VAAR)-852.273-75: Security Requirements for Unclassified IT Resources (Interim-October 2008), which is available at: http://www.va.gov/oal/library/vaar/vaar852.asp

6. Rights in Data - General, Federal Acquisition Regulation (FAR) 52.227-14(d)(1), which is available at: https://www.acquisition.gov/far/52.227-14

7. VA Directive 6300, Records and Information Management (VA Handbook 6300.1 Records Management Procedure, and all applicable VA Records Control Schedules), which is available at: http://www.va.gov/vapubs/search_action.cfm?dType=2

8. Mortgage Industry Standards and Maintenance Organization (MISMO) which is available at: http://mismo.org/

9. Code of Federal Regulations Part 36-Loan Guaranty: eCFR: 38 CFR Part 36 -- Loan Guaranty

SCOPE OF WORK

The providing of data, modeling, analysis, and analytical support will be required for the duration of the contract. As LGY does not have access to active data sources of publicly and privately held economic, loan financials, and real estate data that would allow for the multi-leveled analysis or loan portfolio comparisons this contract must allow for actively updated data sources, as well as a staff of modelers and analysts that provide in-depth, robust support to LGY on the entire range of available housing, credit, securitization, and economic data. This data procurement and analytical support seeks to build a robust mortgage market data set gathered from public and private sources. The data will serve many purposes, including, LGY portfolio benchmarking, portfolio comparative analysis, accurate reporting of the LGY portfolio relative to peer institutions and loan products, capital markets assessment of LGY portfolio, and provide new mortgage/housing insights.

This contractor shall, exclusively leverage the existing, modernized, LGY data lake and tool sets, and make recommendations concerning additional tool sets to improve VA’s technical capabilities with respect to the deliverables.

The contractor will leverage existing and future LGY data, captured in routine transactions (e.g. Guaranty Loan Program, Direct Loan Program, REO Operations, Enterprise Risk functions, Claims, Acquisitions) to compare to external peer institutions, loan products, national/regional economics, geographic, and other publicly available data sources to provide LGY business lines with a diverse set of analytic views to the ever-expanding data repository.

The contractor will develop models that are owned and will be operated by LGY employees to develop, refine and improve predictive modeling based on variables established by VA to determine how a specific policy and procedural decision may impact future performance.

Also, the vendor will provide documentation of data gathering, data modeling refinement, modeling governance, and all related requirements. Additionally, the vendor will train LGY staff on this work, to ensure that LGY staff can independently operate and maintain this work. Any vendor selected in this contract will need to have extensive understanding of the VA Home Loan program (including subject laws, regulations, policies and procedures), proven capabilities to plus up the modernized LGY data lake, and significant mortgage market expertise.

PERFORMANCE DETAILS

The performance of the vendor shall be monitored by the COR, the CO, and must adhere to the standards outlined within this PWS.

PERFORMANCE PERIOD

The period of performance (POP) shall be 12-months from the date of award, four option years of 12 months. Firm-fixed price contract.

PLACE OF PERFORMANCE

The contractor shall perform efforts under this PWS primarily at their facilities and at Government site(s) as directed by Government.

Any work at a Government site shall not take place on Federal holidays or weekends unless directed by the Contracting Officer (CO) or the Contracting Officer’s Representative (COR).

There are eleven (11) Federal holidays set by law (USC Title 5 Section 6103) that VA follows: Under current definitions, five are set by date:

If any of the above falls on a Saturday, then Friday shall be observed as a holiday. Similarly, if one falls on a Sunday, then Monday shall be observed as a holiday.

The other six are set by a day of the week and month:

TRAVEL

The Government encourages the contractor to maximize its use of teleconferencing and video conferencing for meetings.

The Government anticipates no or limited travel under this effort to perform the tasks associated with the effort. If travel is needed, this will be at the contractor’s expense.

SPECIFIC TASKS AND DELIVERABLES

DATA ACCESS AND DELIVERY

a. The mortgage market data, analysis, and forecasts shall be accessed by Department of Veterans Affairs (VA) license holders through the vendor’s website. All data, analysis, models, and forecasting shall be always accessible by the VA during the performance of this contract. Historical data and forecasts shall be accessed for download/export from an easy-to-use, single web-page location where the user is able to select geography level (national, state, MSA), time, economic/financial variables, etc., of data to download/export. The download/export webpage should contain graphing/charting capabilities.

b. The vendor shall provide immediate access to all data and models developed within their environments via existing vendor delivery methods.

c. Where licensing is required, the vendor shall provide 15 separate licenses to allow 15 concurrent LGY staff to have access to data and analytical products.

d. Data must be formatted and available for import into the LGY data lake for use within existing LGY applications, models, and data warehouse.

DELIVERABLES:

5.1.1.a Mortgage market data webpage/web-portal to view and analyze data 5.1.1.b LGY formatted and structure mortgage market data 5.1.1.c Interfaces and system functionality necessary to enable and support the transmission of mortgage market data, analytical model, and associated data/modeling documentation to LGY software applications and data repositories pUBLIC AND pRIVATE mARKET DATA COMPILATION

a. The vendor shall identify public and private sources of data that consist of mortgage market data throughout the mortgage lifecycle (i.e., origination, servicing, and securitization).

a. Mortgage data examples or data types/topics include, but are not limited to the following:

i. Loan financial data:

1. Borrower profiles (aggregated and categorical)

2. Loan level financial

3. Loan servicing (with performance history)

4. Loan origination

5. Loss mitigation and default (i.e., loan modifications, default rates, foreclosures, bankruptcies, etc.)

6. Transfer history

7. Lifecycle history of accounts

8. Secondary mortgage market

ii. Real estate data:

1. Real estate listings

2. Real property records

3. Real property sales

4. Property taxes and insurance

5. Appraisals

6. Property images

7. Building Permits

iii. Publicly available mortgage data available from other mortgage market participants and data resources such as:

1. CFPB

2. HUD

3. GNMA

4. USDA

5. GSEs

6. FEMA

b. The vendor shall aggregate a large pool of relevant economic, borrower, and housing data sets with historic and predictive values. This data will be available for use via a web portal/web page and able to import data into the VA LGY data lake. Data imports into the VA LGY data lake must adhere to established data standards, formats, and table structures.

c. The data shall be formatted in a manner that supports enterprise data usage for comparative analysis amongst public, private and VA loan data.

d. The data will be refreshed as frequently as the data is refreshed by the entity producing the data and available for ingestion into the VA LGY data lake.

DELIVERABLES:

5.2.1.a Checklist of public and private data sources for mortgage market data with logical mapping to data elements derived from each.

5.2.1.b Procure aggregated, formatted, and structured mortgage market data in an LGY ingestible format.

5.2.1.c Mortgage market data webpage/web-portal to view and analyze data 5.2.1.d Comprehensive mortgage market data dictionary of all data elements with best available definitions, sources, and data structures aNALYTICAL MODELING

a. The vendor shall research and provide the best available data that consists of economic, financial, real estate data, environmental, social, governance at the national, state, MSA, CBSA, county, and zip code level.

b. This data shall be demonstrable using categorical variables to describe both borrower and property characteristics.

c. The modeling shall utilize mortgage/housing industry approved/known statistical methods and analytical logic. Additionally, the vendor will make efforts to implement logic and definitions developed by the VA LGY data team. When applicable the vendor will suggest new methods, techniques, processes, and procedures to improve the precision and accuracy of analytical models.

d. All modeling and statistical methods will be thoroughly documented and shared in a method prescribed by LGY via tools such as Confluence pages, SharePoint, JIRA, email, or other specified transmission methods.

e. Modeling documentation shall include the method of development, specific data used within the model, assumptions, risks, written methodology of development, and expected result or intent of the model.

DELIVERABLES:

5.3.1.a Ad-hoc development and implementation of analytical mortgage models (i.e. models that account for mortgage growth and risk related economic, capital markets analysis throughout the loan lifecycle, environmental, social, and governance variables) 5.3.1.b Written analysis interpreting analytical model results with multiple options or recommendations actionable by LGY senior leadership. Monthly advisory meetings.

5.3.1.c Comprehensive documentation of all requirements, techniques, modeling methods, and statistical methods used to derive analytical models.

5.3.1.d Logical mapping of data elements used to support analytical models with supporting transaction documentation for all data elements 5.3.1.e Delivery of all documentation contained within and formatted to LGY’s Confluence and Sharepoint instances Data ingestion and modeling training

a. The vendor shall develop a series of training modules that prepare and inform the VA data team on data sources identification, data ingestion, analytical models used to interpret the data, and report development.

b. The vendor shall provide transition and ownership of the sourcing and modeling of public and private mortgage market data. This transition will be supported with a vendor specified service level agreement.

c. These training modules and all supporting documentation shall be formatted in an easily transportable and consumable manner.

d. The vendor shall research and suggest best practice modeling techniques or new modeling techniques on an as needed basis.

e. The vendor shall provide recommended training, referential analytical modeling documentation, modeling forums, and research materials in support of a continuous training and learning environment.

DELIVERABLES:

5.4.1.a Comprehensive training documentation, with step-by-step instructions, for all modeling and data manipulation 5.4.1.b Training strategy, plan, and modules 5.4.1.c Modeling cases/canvases for new or emerging analytical techniques 5.4.1.d Transition plan for models, mortgage market data, and all supporting documentation

LGY-Tailored Portfolio Model and Reporting

a. In consultation with the VA LGY data team, the vendor will build and maintain a LGY-tailored portfolio model and report(s) that evaluates the state of the LGY loan portfolio relative to mortgage/housing industry.

b. The tailored portfolio and reports will contain key performance indicators (as specified by VA LGY), industry benchmarking, and summary statistics that describe the portfolios overall health, risks, and forecast.

c. Potential tailored portfolio categories include, consumer credit forecast, threshold analysis using historical trends, peer and product comparison, and core summary statistics with diagnostic indicators.

LGY MORTGAGE PORTFOLIO RISK MODEL

a. The vendor shall provide loan level portfolio risk modeling, in which LGY may determine aggregated and individual risk factors for different loan types, regions, and external economic factors.

b. This model shall include the ability to predict new loans entering the portfolio based on changes in economic conditions. At a minimum, these new loans will be evaluated for pre-payment rates, default, and foreclosure. These models should also be capable of performing multi-factor stress tests based on a variety of global, national or regional economic conditions.

c. The vendor shall feed model through multiple scenarios to determine how LGY portfolio will likely perform under different market conditions.

d. All model outputs must hold up to audit scrutiny, as such Vendor should have an extensive history with federal audit groups.

e. Outputs of LGY-tailored portfolio model shall be referenced at the loan level, and capable of being ingested into LGY analytic systems for compiling in different analytic products showing forward outlook of the current LGY portfolio as well as future loans predicted to enter the portfolio.

LGY MORTGAGE PORTFOLIO MODEL MAINTENANCE AND SUPPORT

a. The vendor shall provide technical guidance to LGY analysts on data formatting and organization to provide a seamless transfer of the LGY-tailored portfolio model at maturity and ensure data compatibility.

b. Vendor shall use this tailored model to provide whole-life cycle portfolio analysis, to identify trends, patterns, potential issues within the management of LGY portfolio. Vendor shall provide updated scenarios for the model, both on demand and as economic conditions change. Vendor shall allow for the addition of customized scenarios based on changing economic or social factors.

c. Vendor shall be tasked by COR for development and analysis.

d. Vender must offer significant transparency and customization that allows LGY insight and access to the economic factors that will allow LGY the ability to alter the model simulation to fit future analytical needs and additional program data.

e. Vendor shall provide a set amount of support hours for Model adjustments as prescribed by VA, or other support provided by staff economists, mathematicians, statisticians, or other subject matter experts.

f. All models, portfolio analysis, and data will be VA LGY owned and stored in approved VA LGY document storage applications or the data lake.

DELIVERABLES:

5.5.4.a LGY-tailored portfolio report and support models 5.5.4.b Data mapping of all data elements, and their tables, support the LGY-tailored portfolio report 5.5.4.c LGY portfolio risk model 5.5.4.d Comprehensive modeling and data documentation for all components of the LGY portfolio reporting 5.5.4.e Technical guidance and documentation for the LGY-tailored portfolio reporting and risk model

Optional task for data insights and analysis The contractor shall consider additional insight and analysis on a variety of mortgage related topics. These topics require specific data element combined with subject matter expertise to derive actionable solutions.

1. LOSS MITIGATION DATA AND ANALYSIS

a. As a proof-of-concept build a predictive model to determine the success or fail rate of current loss mitigation options within LGY and across the mortgage industry.

b. Determine the best available data to support this model, assess the predictive strength of the model, provide recommend practices or data that would render the strongest predictive capabilities.

c. With the comprehensive knowledge of modeling analysis and data identification, use data-driven analysis to provide actionable recommendations for strengthening loss mitigation prediction. Both modeling and data recommendations apply.

2. Environmental, Social, and Governance (ESG) data procurement for LGY ESG dashboard

a. The vendor shall provide climate data for the LGY ESG Dashboard in support of Executive Order on Climate-Related Financial Risk (EO 14030). LGY needs continued data procurement services to support the LGY ESG dashboard. The executive order requires the Secretary of Veterans Affairs to integrate climate-related financial risk into underwriting standards, loan terms and conditions, and asset management and servicing procedures for lending policies and programs.

b. Annually, the vendor shall procure and deliver data pertaining to climate change, peer comparison, mortgage-backed securities pricing, societal impact, overlays using FEMA, Corps of Engineers, Core Logic, American Enterprise Institute (AEI), and other data to support the on-going operation and maintenance of the LGY ESG dashboard. The data shall support geo coding, zip code analysis, and address comparison.

c. Annually, the vendor shall deliver ESG data that includes revised FEMA coastal maps (ten, twenty, and thirty-year projections), heat maps, prior 20-year major disaster maps, Corp of Engineers mapping, sales comparison data, and other applicable sources to support the LGY ESG dashboard and ESG analytics.

d. All data will be formatted for use in Excel, organized into one, three, and five-year time series, and be application programming interface (API) compatible.

e. The vendor will provide geo-coding services to review and update LGY address data for geo-coding compliance and use.

f. See Appendix for Table 1: Climate Related Dashboard Design Questions and Table 2: Non-Climate Related Environmental and Social Risk Dashboard Design Questions for a list of data measures, metrics and intended use.

Appendix:

Table1: Climate Related Dashboard Design Questions

Summaries

a. Earthquake

b. Wildfire

c. Inland Flood

d. Severe Convective Storm

e. Winter Storm

f. Hurricane Storm Surge

g. Hurricane Wind

Climate Risk & Lookup Page

dollars (financial risk) Individual perils include:

h. Earthquake

i. Wildfire

j. Inland Flood

k. Severe Convective Storm

l. Winter Storm

m. Hurricane Storm Surge

n. Hurricane Wind

Climate Risk & Lookup Page

o. Earthquake

p. Wildfire

q. Inland Flood

r. Severe Convective Storm

s. Winter Storm

t. Hurricane Storm Surge

u. Hurricane Wind

v. Composite Earthquake

PML’s are calculated for 50-year, 100 year, 250-year, 500-year events probability.

Climate Risk & Lookup Page

climate perils (e.g., Hurricane Storm Surge) change nationally and regionally between today, 2030, 2040 and 2050?

Climate Risk – Projected Climate Risk

the probability of rare events (50-year, 100-year, 250-year, 500-year)?

Climate Risk – Projected Climate Risk

associated with a particular address within the Guaranty Loan Portfolio?

Climate Risk – Lookup Page

Table 2: Non-Climate Related Environmental and Social Risk Dashboard Design Questions

exposed to air contaminant risks ranked by exposure deciles (1-10%, 11-20%...91-100%, low to high). Exposures risks include:

· Air Toxics Cancer Risk

· Respiratory Hazard Index

· Diesel PM (DPM) exposure

· Particulate Matter (PM2.5) exposure

· Ozone exposure

· Lead in paint

· Lead pipes

· Asbestos

· Radon What is the potential exposure of the dwellings in the loan guaranty portfolio to environmental hazards (lead, asbestos, and radon) within the dwelling units associated with the VA portfolio?

Environmental Risk – Household Contaminants

or release. Exposures risks include:

· Proximity to Risk Management Plan Sites

· Proximity to Hazardous Waste TSDF

· Proximity to National Priorities List (Superfund Sites)

· Wastewater Discharge Indicator (Stream Proximity and Toxic Concentration)

What is the potential exposure of the dwellings in the loan guaranty portfolio to nearby current operations and historic condition possibly at risk for environmental accidents or releases?

Environmental Risk – Household Contaminants

· Traffic Proximity and Volume

· Nearness to Wastewater Treatment Sites (proximity and number)

value?

Energy Efficiency Mortgage

GENERAL REQUIREMENTS

SECURITY: POSITION/TASK RISK DESIGNATION LEVEL(S) AND CONTRACTOR PERSONNEL SECURITY REQUIREMENTS All requirements in Section 6, Addendum A, and Addendum B of the PWS apply to this effort.

The position sensitivity and the level of Background Investigation (BI) commensurate with the required level of access for the following tasks within the PWS are:

Position Sensitivity and BI Requirements

Low

National Agency Check with Written Inquiries (NACI) A NACI is conducted by the Office of Personnel Management (OPM) and covers a 5-year period. It consists of a review of records contained in the OPM Security Investigations Index (SII) and the Department of Defense (DOD) Defense Central Investigations Index (DCII), Federal Bureau of Investigation (FBI) name check, FBI fingerprint check, and written inquiries to previous employers and references listed on the application for employment. In VA it is used for Non-sensitive or Low Risk positions.

The Tasks identified, and the resulting Position Sensitivity and BI requirements identify the BI requirements for Vendor identified contractors, based upon the tasks the vendor individual will be working. The submitted vendor Staffing Roster shall indicate the required BI level for each contractor, based upon the task(s) the contractor will be working.

The contractor, their personnel, and their subcontractors shall be subject to the Federal laws, regulations, standards, and VA Directives and Handbooks regarding information and information system security as delineated in this contract.

Information made available to the contractor or subcontractor by VA for the performance or administration of this contract or information developed by the contractor/ subcontractor in performance or administration of the contract shall be used only for those purposes and shall not be used in any other way without the prior written agreement of the VA. This clause expressly limits the contractor/subcontractor's rights to use data as described in Rights in Data- General, FAR 52.227-14(d) (1).

All Contractors and Contractor personnel shall be subject to the same Federal security and privacy laws, regulations, standards and VA policies as VA, including the Privacy Act, 5 U.S.C.§552a, and VA personnel, regarding information and information system security. Contractors must follow policies and procedures outlined in VA Directive 6500, Information Security Program; and VA Handbook 6500.6. See attached VA 6500.6 Appendix C, which is incorporated in the resulting purchase order to ensure appropriate security controls are in place.

Contractor Personnel Security

a. Any individual who requires access to the VA site(s), personally identifiable information (PII) and/or access to VA local area network (LAN) systems shall be the subject of a favorable fingerprint check (SAC) adjudicated by VBA Personnel Security Office (PERSEC). Individuals are required a background investigation and must receive a favorable adjudication from the VA Personnel Security and Adjudication Center (PSAC). These requirements are applicable to all sub-contractor personnel requiring any Background Investigation (BI) conducted by Defense Counterintelligence Security Agency (DCSA).

b. The level of BI will be in accordance with VA Directive 0710 dated June 4, 2010 and is available at http://www.va.gov/vapubs/viewPublication.asp?Pub_ID=487&FTyp.

Background Investigation: The Contractor employee level of BI required for this effort is:

Low Risk (T1) Security – Employees Moderate Risk (T2) – Managers and Directors Note: The position sensitivity should reflect the results from the completion of the PDAT versus the title of the individual.

Investigation Documents: Immediately after contract award, the COR will provide the Contractor with the following background investigation documents to be completed by the Contractor and returned thru the COR to VBA PERSEC to begin the background investigations process for all contract employees working on the contract who will have access to VA/VBA facilities, VA systems, or privacy data:

1. Background Investigation Request Worksheet

1. Optional Form 306 – Declaration of Federal Employment

1. VBA Contractor Fingerprint Request Form

1. VA Form 0710 – Authorization for Release of Information Fair Credit Report (if T2 or higher)

1. (SC) Self-Certification Form (if applicable)

1. VA Form 0711 – Request for Personal Identity Verification Card

1. SIC Contractor Background Request Form (unsigned)

Submitting Completed Package: Upon receipt of documents listed above from the COR, the COR will submit the background investigation package to VBA’s Personnel Security Specialist. Upon notification of favorable fingerprint results, the COR should request the official VA email account and will be notified of all background investigation requirements preventing the Contractor from an immediate onboard. Thereafter, the Contractor shall receive an email notification from DCSA including detailed instructions regarding completion of the background clearance application process in the Electronic Questionnaires for Investigations Processing (e-QIP) system. e-QIP is an online, internet accessible system, where the Contractor employee shall complete the security questionnaire required for OPM to process background investigation. Once the e-QIP is released by VBA PERSEC, scheduled by OPM, the Contractor may begin work while the background investigation is ongoing.

Reciprocation: Contractors who have current favorable background investigation previously conducted by OPM or DCSA may be accepted through reciprocation. When a previous personnel security clearance is currently held, it does not preclude the Contractor form submitting a complete Background Investigation Package as stated above to the COR immediately after contract award for all Contractor employees who will be working on the contract.

Pre-Screen: The Contractor shall prescreen all personnel who require access to VA site(s) and/or access to VA LAN systems to ensure they maintain a U.S. citizenship or Alien Registration that authorizes them to work in the U.S., and are able to read, write, speak, and understand the English language.

Contractor Performance: Contract performance shall not commence before

1. The VBA has confirmed favorable fingerprint results, or

1. PSAC confirms that it has received the Contractor’s investigative documents, The documents are complete, and that the background investigation information has been released to OPM for scheduling of the background investigation, or

1. VBA or the PSAC has confirmed that the verified investigation will be reciprocated.

Copy of Certificate of Investigation (COI): The COR will notify and forward the Contractor a copy of the Certificate of Investigation when the background investigation has been favorably completed or a Certificate of Eligibility (Form 4236) if the investigation has been reciprocated. The Contractor, if notified, of an unfavorable adjudication by the Government, shall withdraw the employee from consideration from working under the contract. Failure to comply, the Contractor personnel security requirements may result in termination of the contract for default.

Responsibility: The Contractor shall be responsible for the actions of those contract and subcontract employees it provides to perform work for the VBA. In the event damage arises from work performed by Contractor employees the Contractor will be responsible for resources necessary to remedy the incident.

Vendor Selection: Should the Contractor use a vendor other than OPM or DCSA to conduct background investigations, the investigative company must be certified by OPM/DCSA to conduct Contractor background investigations. The Vendor Cage Code number must be provided to the VA PSAC, which will verify the information and conclude whether access to the Government’s site(s) and/or VA LAN systems can be granted.

Investigative History: The investigative history for Contractor personnel working under this contract must be maintained in the databases of either OPM or DCSA.

Government Responsibilities:

· After the VBA PERSEC has quality controlled the BI package from the Contractor, the VBA PERSEC will send a courtesy e-mail notification to the Contractor and the COR identifying the e-QIP email from DCSA including detailed instructions regarding completion of the BI application process and the level of background that was requested.

· Upon receipt of required background investigative documents, VBA PERSEC will review the background investigative documents for completion and initiate the background investigation by forwarding the background investigative documents to OPM to conduct the BI. If the background documents are not complete, VBA PERSEC will notify the Contractor and COR of deficiencies and include corrective instructions.

· VBA PERSEC will pay for background investigations and reciprocals processed through the VA PSAC and conducted by OPM in advance.

· The COR will notify and forward the Contractor a copy of the Certificate of Investigation when the BI has been favorably adjudicated or a Certificate of Eligibility (Form 4236) if the investigation has been reciprocated. The COR will also notify the Contractor of an unfavorable adjudication by the Government.

Training

a. All Contractor and sub-contractor personnel requiring access to VA information and VA information systems shall complete the following before being granted access to VA information and networks:

1) Sign and acknowledge understanding of and responsibilities for compliance with the National Rules of Behavior related to access to VA information and information systems.

2) Successfully complete any cyber security or privacy training as required for VA personnel with equivalent information and/or system access.

b. The Contractor shall provide to the Contracting Officer a copy of the training certificates and signed Rules of Behavior for each applicable employee within 30 days from the date TMS access is granted and annually thereafter, as required. These online courses are located at https://www.tms.va.gov/learning/user/login.jsp

Data Security

VA will supply the vendor with (non PII) program information, to include Loan data and addresses. This data will come in the form of multiple secure file transfers from VA data infrastructure to the vendors secure data infrastructure, which may require a Memorandum of Understanding between the vendor and VA IT, or LGY program data will be sent to the vendor on a secured hard drive. It will be the responsibility of the vendor to follow all Federal information security policies for Federal/VA data once the transfer has taken place.

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