The Federal Housing Finance Agency (FHFA) issued a Justification for an Exception to Fair Opportunity on April 16, 2026, to award a non-competitive time-and-materials task order against the APKS Indefinite Delivery/Indefinite Quantity (IDIQ) contract 95314321D0001 for specialized legal advisory services. The task order, effective May 1, 2026, through April 30, 2027, encompasses litigation representation and legal counsel to FHFA in its capacity as Conservator and regulator of Fannie Mae and Freddie Mac, covering areas including securities law, financial services regulation, antitrust law, administrative law, and ongoing litigation matters such as challenges to the Third Amendment of the Treasury Agreement and the Fairholme Funds case. FHFA justified the sole-source award to APKS under 41 U.S.C. § 4106(c)(2) and FAR 16.505(b)(2)(i)(B), asserting that APKS possesses irreplaceable institutional knowledge developed through continuous representation of FHFA since 2011 and that transitioning to another firm would result in substantial duplicative costs and loss of legal continuity critical to FHFA's complex conservatorship and litigation matters. The specific vendor and award amount were not disclosed in the published notice, though the underlying rates were established competitively in November 2020 and will be subject to discount negotiations in the Task Order Requirement Package. The justification received certifications from FHFA's Assistant General Counsel, Contracting Officer, Senior Counsel, Senior Procurement Executive, and Competition Advocate in March 2026.

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