Sole Source Justification_50310223P0025 (Redacted).pdf

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

CCH Incorporated’s Accounting Research Manager (ARM) is the only subscription product identified capable of fully meeting the SEC’s requirement. The SEC requires interpretive guidance by experts in the field of accounting and auditing. Other accounting subscriptions have not been found to provide the level of expertise needed by the SEC. Specifically, the SEC requires publications authored by technical experts in accounting defined as follows:

Accountants who have worked as an Associate Chief Accountant, Deputy Chief Accountant or Chief Accountant in the Division of Corporation Finance’s Office of Chief

Accountant or the SEC’s Office of the Chief Accountant.

Existing and former members or accounting staff of the IASB, IFRIC, FASB, or EITF or any technical accounting body or committee thereof.

Partners or former partners of the National Offices (or its equivalent) of the: Big 4 accounting firms (i.e. Deloitte, Ernst & Young, KPMG, PricewaterhouseCoopers), including former and current firms such as, Arthur Andersen, BDO and Grant Thornton.

Accountants with a minimum of fifteen years of relevant experience related to the application of the requirements of the IASB, IFRIC, FASB, EITF, or SEC to public companies.

For auditing matters: the experts above as well as existing and former members or staff of the PCAOB.

Additionally, several of the required publications provided within the subscription are under copyright and only available from CCH Incorporated. Therefore, it is not possible for any other source to meet this requirement.

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

The SEC Office of Acquisitions (OA) posted a Synopsis on January 31, 2023 in accordance with FAR 5.201 that provided notification of the SEC’s intent to award a sole source procurement to CCH, Incorporated for this requirement.

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

The Contracting Officer determines that the anticipated price will be fair and reasonable based on review of market research price estimates.

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.

CCH’s Accounting Research Manager (ARM) is the only subscription product identified that provides the content and interpretive guidance required by the SEC. The SEC has reviewed offerings from other companies including but found that they do not provide authors/contributors with the breadth of technical expertise needed.

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

None.

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

A listing of any sources that express interest in this acquisition will be maintained in the contract file.

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 SEC will perform market research for future acquisitions for the purpose of verifying the sole source nature of this requirement.

12. Required Signatures:

TECHNICAL & REQUIREMENTS CERTIFICATIONS: I certify that the facts and representati

(Signature)

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

(Signature)