JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY
Overview
Buyer
Place of Performance
NAICS
PSC
Set Aside
Original Source
Timeline
Qualification Details
Fit reasons
- NAICS alignment with historical contract wins in similar service areas.
- Scope strongly matches core technical capabilities and delivery model.
Risks
- Past performance thresholds may require one additional teaming partner.
- Potential clarification needed on staffing minimums before bid/no-bid.
Next steps
Validate eligibility requirements, assign capture owner, and schedule partner outreach to confirm teaming strategy before submission planning.
Quick Summary
The Federal Housing Finance Agency (FHFA) has issued a Justification for an Exception to Fair Opportunity for Legal Services (R418). This document explains the rationale for awarding a time-and-materials task order to APKS for Litigation and Other Legal Advisory Services without full and open competition. The services are crucial for FHFA's role as Conservator and regulator of Fannie Mae and Freddie Mac. The period of performance for this task order is from May 1, 2026, to April 30, 2027. FHFA anticipates awarding follow-on IDIQ contracts competitively in fiscal year 2026 for similar services.
Scope of Work
The required legal services are highly specialized, encompassing litigation, regulatory advice, securities law, financial services regulation law, antitrust, and administrative law. These services are directly related to FHFA's unique responsibilities and ongoing legal matters.
Contract & Timeline
- Type: Justification for an Exception to Fair Opportunity (Time-and-Materials Task Order against APKS IDIQ)
- Agency: Federal Housing Finance Agency
- Office: FEDERAL HOUSING FINANCE AGENCY, OBFM
- Place of Performance: Washington, DC, United States
- Period of Performance: May 1, 2026 – April 30, 2027
- Published Date: April 16, 2026
Rationale for Exception
APKS was selected due to its significant and unique knowledge of specific legal issues, FHFA's governing statutes, regulations, policies, and organizational structure, gained through extensive prior work. Transitioning to a new firm would result in substantial duplication of cost and a loss of critical expertise, making an exception to fair opportunity necessary.
Set-Aside
None specified, as this is a justification for an exception to fair opportunity, not a competitive solicitation.
Additional Notes
This justification highlights the specialized nature of the legal support required. Interested parties should note that FHFA plans to competitively award follow-on IDIQ contracts for similar services in fiscal year 2026. For inquiries, contact Laura Baker at laura.baker@fhfa.gov.