Attachment_3_Redacted_Sole_Source_Justification.pdf

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

100 F STREET, NE

WASHINGTON, DC 20549

OFFICE OF

OFFICE OF

ACQUISITIONS

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

RQ 31000-15-0194

J&A Number: 2015-0174

Upon the basis of the following justification, I hereby approve the issuance of the contractual action discussed below using other than full and open competition, pursuant to the authority cited herein.

1. Contracting Activity.

U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549

2. Nature and Description of Action Being Approved:

The U.S. Securities and Exchange Commission (SEC) intends to award a sole source requirement for data in a structured format on investment managers and pension fund consultants to Broadridge Financial Solutions, Lake Success, NY. This is a new contract action.

3. Description of the supplies or services required to meet the needs of the SEC and the estimated value:

The U.S. Securities and Exchange Commission (SEC) requires data in structured format that provides detailed information on investment managers and pension fund consultants.

The database shall include data elements for investment managers, pension fund consultants, investment firms, mutual funds and separately managed accounts, including directory information, product type, strategy, peer groups, investment specialties, performance, portfolio information, assets by year, average account size, and asset allocation. These data shall be updated as least monthly.

The information shall be available for downloading in compressed zip files, in a format compatible with the PerTrac Analytical Platform SQL Version. The database shall reside on an SEC server where it will be used by 52 users for analysis and to produce reports. The vendor shall provide documentation including a list of data fields and their definitions.

The estimated contract value for the base period is $ which will use FY15 funds. The total estimated contract value for the base and 2 option years is $.

4. Statutory Authority for Other Than Full and Open Competition:

The U.S. Securities and Exchange Commission (SEC) requires data in structured format that provides detailed information on investment managers and pension fund consultants.

5. Demonstration that the proposed contractor's unique qualifications or nature of the acquisition requires use of the authority cited:

The requirement is for a database with broad coverage of investment managers and pension fund consultants, that provides detailed information about them. This detailed information includes directory information, product type, strategy, peer groups, investment specialties, performance, portfolio information, assets by year, average account size, and asset allocation. In addition, the data is required in a specific structured format so that it can be incorporated into the SEC's OIDS research platform. The breadth and depth of the information in a format that enables the aggregation of investment manager and pension fund consultant data with additional content through OIDS fulfills the requirement for comprehensive coverage and analytical tools needed to perform on-going fund industry surveillance.

6. Efforts to ensure that offers are solicited from as Many Potential Sources as Possible.

Efforts to solicit offers from sources other than Broadridge Financial Solutions for the current requirements have been unsuccessful. Broadridge Financial Solutions is the only vendor capable of delivering the information requirements. The requirement will be transmitted through the GPE and, if warranted by the response to such notice, this action will be reviewed.

7. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

Before awarding a contract, the Contracting Officer will perform a price analysis in accordance with FAR 13.106-3 (and a cost analysis, if required) to determine whether the price is fair and reasonable.

8. Description of market research conducted and results or statement of the reasons market research was not conducted:

Knowledgeable individuals in Division of Economics, Risk, and Analysis and business librarians were consulted, and research was conducted on the Internet. Based on this research and the recommendation of those consulted, we concluded that the contractor possesses unique capabilities unavailable elsewhere in the market.

9. Other Supporting Facts:

None.

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

A list of sources that express an interest in actions under this J&A (once it is posted on the GPE) will be maintained in the applicable contract files.

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:

The Commission’s information requirements are ongoing and we will continue to perform market research for future acquisitions for the purpose of verifying the sole source nature of this acquisition.

TECHNICAL & REQUIREMENTS CERTIFICATIONS

I certify that the facts and representations which form the basis for this justification are accurate and complete.

Name/Title Signature Date

CONTRACTING OFFICER CERTIFICATION

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Name/Title Signature Date