Notice of Contract Action. Sole Source under SAT

The Federal Housing Finance Agency (FHFA) is proceeding with a sole source procurement under the Simplified Acquisition Threshold using FAR 13.106-1(b)(1) to award legal services to Arnold & Porter, citing unique and compelling circumstances that preclude competitive bidding. The necessity arises from the requirement for a contractor with highly specialized expertise in federal financial enforcement actions, deep familiarity with FHFA’s regulatory framework, and the ability to immediately commence work on time-sensitive matters involving potential financial misconduct and significant confidentiality risks. The contract is for advisory legal services including the preparation of a comprehensive legal memorandum, assessment of enforcement options, and recommendations to FHFA leadership, with performance occurring in Washington, D.C. No set-aside designation is used, and the NAICS code 541110 classifies this as legal services. The contracting officer has determined that only Arnold & Porter possesses the unique combination of experience, independence, and institutional knowledge necessary to fulfill the scope without conflict or delay, making competition impractical. Price reasonableness will be established through standard analysis under FAR Part 13, though no contract value is specified in the documentation. The government retains full responsibility for acceptance of deliverables, with no formal inspection criteria or quality standards outlined beyond the expectation of legally sound, confidential, and timely analysis. Security requirements are implied by the sensitive nature of the work, including handling of confidential information and avoidance of public disclosure, though no explicit clearance level is mandated. The procurement was digitally signed on May 15, 2026, with a posting date of May 26, 2026; the sole source justification is the only attachment referenced, and no other contract clauses, representations from the offeror, packaging requirements, or invoicing details are provided. The primary point of contact is Laura Baker, and Taryn Jones serves as the technical representative, though formal COR/COTR designations and contact information are not included. No contract options, delivery schedules, or payment instructions are specified beyond the place of performance and agency location in Washington, DC 20219.