JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

The Pension Benefit Guaranty Corporation, an agency of the Department of Labor, awarded contract 16PBGC27C0002 to Bolton Partners DC, Inc. on October 16, 2026. This firm-fixed-price agreement provides essential actuarial support services for the management of three Complexity Level IV pension plans, specifically the Sears Holdings Pension Plan 1, Sears Holdings Pension Plan 2, and The McClatchy Company Retirement Plan. The period of performance for these services extends from October 16, 2026, through October 15, 2027, with work performed in Washington, DC. This procurement was conducted as a non-competitive award under the justification for other than full and open competition, citing 41 U.S.C. 3304(a)(1) and FAR 6.103-1(b). The agency determined that Bolton Partners DC, Inc. was the only responsible source capable of satisfying the requirement. This decision was based on the critical need for continuity in actuarial methods and the determination that transitioning to a different contractor would introduce unacceptable technical risk to the management of these complex pension plans.