RegTech LSJ FINAL.pdf

CONSUMER FINANCIAL PROTECTION BUREAU

Office of Finance and Procurement

LIMITED-SOURCES JUSTIFICATION FAR 8.405-6 — Federal Supply Schedule Order

(i) Agency and Activity Identification Agency: Consumer Financial Protection Bureau (CFPB)

Contracting Activity: Office of Finance and Procurement (OFP)

Contracting Officer: Patrick Sisk

Document Type: Limited-Sources Justification

(ii) Nature and Description of the Action CFPB proposes to issue a standalone, unrestricted order under the GSA Multiple Award Schedule (MAS) contract 47QTCA18D003V held by Raft LLC ("Raft"), SIN 54151S, restricting consideration to Raft as the sole source under the authority of FAR 8.405-6. This order is separate and distinct from the existing 8(a) set-aside Blanket Purchase Agreement 9531CB23A0007 currently held by Raft, and is not a call or option issued against that BPA. The order is intended to bridge continuity of two current task orders under that BPA, developer support (9531CB23F0042) and program management/business analyst support (9531CB24F0003, modified to align its period of performance end date with 9531CB23F0042), during the period between Raft's loss of small business/8(a) set-aside eligibility and the anticipated award of a follow-on 8(a) set-aside BPA, which CFPB intends to competitively award in the near term.

(iii) Description of Supplies/Services and Estimated Value Services: RegTech Platform Support Services in direct support of Home Mortgage Disclosure Act (HMDA) Operations, continuing the scope, functions, and technical support currently performed under the existing 8(a) set-aside BPA task orders identified below.

Current task orders and existing period of performance end dates:

• 9531CB23F0042 — Developer support — current PoP ends 9/15/2026

• 9531CB24F0003 — Program management/business analyst support — current PoP ends 9/15/2026 (modified to align with 9531CB23F0042)

Proposed Bridge Period of Performance: 9/16/2026 through 4/16/2027 (7 months).

Estimated Value: $2,178,601.60 for the 7-month bridge period across both task orders.

(iv) Authority and Supporting Rationale Authority: FAR 8.405-6(a)(1)(i)(A) — Unusual and Compelling Urgency.

On July 28, 2026, Leonardo DRS, Inc. (NASDAQ: DRS) announced execution of a definitive agreement to acquire Raft LLC in an all-cash transaction valued at $450 million, with closing anticipated in the fourth quarter of calendar year 2026. Raft has notified CFPB of the transaction in writing. Leonardo DRS is not a small business under any applicable NAICS size standard. Under 13 CFR § 125.12(a), Raft is required to recertify its small business size and 8(a) program status within 30 calendar days of the transaction becoming final, or upon an earlier agreement in principle. Because the acquiring entity is other than small, Raft's recertification was disqualifying. As of 8/20/2026, Raft LLC is no longer listed as an 8(a) Business Development Program participant on SAM.gov or Small Business Administration's (SBA) Dynamic Small Business Search (DSBS), confirming loss of 8(a) eligibility, and Raft is also no longer classified as a small business under any applicable NAICS size standard as of that same confirmation date.

Under 13 CFR § 125.12(g), which eliminated the prior Federal Supply Schedule exception effective January 16, 2025, a disqualifying recertification renders a Schedule holder immediately ineligible for further set-aside orders, BPA calls, and option periods issued under its FSS contract. Separately, under 13 CFR § 124.515, the change of ownership and control resulting from the acquisition requires advance SBA approval, and Raft's removal from SAM.gov and SBA DSBS as an 8(a) participant confirms Raft has exited the 8(a) Business Development Program, consistent with the requirement that continued 8(a) eligibility requires 51 percent unconditional ownership and control by a socially and economically disadvantaged individual, a condition the Leonardo DRS transaction does not satisfy.

As a result, CFPB cannot issue further set-aside orders or exercise further options under Raft's existing CFPB 8(a) BPA 9531CB23A0007, as had been the Bureau’s intent until the recent and unanticipated change in circumstances. This directly affects continuity of Home Mortgage Disclosure Act (HMDA) Operations, a statutorily-required function of the Bureau. HMDA filing season runs January 1 through March 1, and the Bureau's first statutorily-required publication of collected HMDA data is due March 31. Both current task orders now lapse September 15, 2026, before the March 31, 2027 statutory publication deadline and before a compliant competitive follow-on 8(a) source selection, which CFPB is preparing to initiate and which will include evaluation of Key Personnel and Technical Approach factors with oral interviews, can reasonably be completed.

CFPB's market research for the follow-on competitive 8(a) BPA identified four responding 8(a) firms under SIN 54151S; none can realistically transition and begin performance in time to avoid a coverage gap beginning September 16, 2026. The proposed 7-month bridge period (9/16/2026-4/16/2027) provides continuity through the statutory publication deadline plus administrative margin for transition to the follow-on 8(a) award with another vendor, as this requirement has not been released from the 8(a) Program by the SBA. Absent this bridge action, CFPB will be unable to maintain the contractor support necessary to fulfill its statutory HMDA publication obligation, resulting in significant financial and operational injury to the Government within the meaning of the urgent-and-compelling standard. HMDA data are relied upon by federal, state, and local policymakers, fair lending analysts and examiners, community interest groups, academic researchers, compliance and analytics vendors, and the mortgage industry. Disruption to the publication of HMDA data would be highly visible and would result in CFPB being out of compliance with applicable statutory law, and, therefore, also carries significant reputational risk to the Bureau.

(v) Efforts to Ensure a Fair and Reasonable Price

Pricing will be evaluated against Raft's current GSA MAS SIN 54151S rates, which were established through GSA's price negotiation and are subject to the Price Reduction Clause. CFPB has further compared proposed labor categories, rates, and level of effort against rough-order-of-magnitude pricing obtained through market research conducted for the planned follow-on 8(a) competition, in which four capable 8(a) firms under SIN 54151S provided pricing for comparable scope. See the accompanying Price Reasonableness Determination, which documents the Contracting Officer's finding.

(vi) Market Research Market research was not separately conducted for this bridge action because the requirement is a continuation of an existing, previously competed 8(a) set-aside scope currently performed by Raft, and the purpose of the action is continuity of an incumbent effort pending completion of a full and open 8(a) competition, which CFPB is preparing to initiate. Market research supporting that follow-on competition, including identification of four capable 8(a) firms via SBA's Dynamic Small Business Search, is documented separately in the acquisition file.

(vii) Other Facts Supporting Limited-Sources Consideration

• Raft is the incumbent performer with institutional and technical knowledge of CFPB's RegTech platform and HMDA Operations environment, minimizing transition risk during the bridge period.

• The acquisition and resulting eligibility change is outside CFPB's and Raft's control, and Raft self-reported the transaction promptly.

• HMDA is a statutorily-required Bureau function with fixed, externally-driven deadlines (filing season close March 1; publication deadline March 31) that do not move to accommodate a source selection timeline.

• CFPB has already taken affirmative steps toward a competed follow-on 8(a) award, evidencing that the limited-sources action is a narrow, time-bound bridge rather than a substitute for a competitive action.

(viii) Actions to Remove Barriers to Future Competition CFPB will complete the competitive follow-on 8(a) set-aside BPA as expeditiously as practicable, targeting award and complete transition on or before April 16, 2027. The bridge order will include a defined not-to-exceed base period with a single capped option under FAR 52.217-8, Option to Extend Services (not to exceed six additional months), to preserve continuity only in the event the follow-on competition or award is delayed, without extending the limited-sources arrangement beyond the minimum period reasonably necessary.

(ix) Contracting Officer Certification I certify that the foregoing justification is accurate and complete to the best of my knowledge and belief.

Patrick Sisk, Contracting Officer, CFPB Office of Finance and Procurement

Date: _______________

(x) Approval

Estimated value ($2,178,601.60) exceeds the threshold requiring approval above Contracting Officer certification alone; approval by the CFPB Competition Advocate (or other official designated under FAR 8.405-6(d)(3)/(4)) is required prior to award.

Laurent E. Pichet, Competition Advocate, CFPB

Date: _______________

9/4/2026

09/04/2026