Central Office Legislative Consultants
Title of Project: Regulatory Drafting and Impact Analysis Consulting Services
Scope of Work:
The contractor shall provide all resources necessary to accomplish the deliverables described in the statement of work (SOW), except as may otherwise be specified. Specific regulatory project needs are subject to change based on LGY, VBA, and VA leadership priorities. Currently, however, regulatory and economic analysis services are needed to support the following priority projects:
Regulatory Implementation of Public Law 115-174
Analyzing public comments received during interim final rule comment periods; assessing changes to final rule based on comments; preparing final rule and corresponding regulatory impact analysis based on updated data collected.
Drafting proposed rule addressing VA interest rate reduction refinance loans (IRRRLs), qualified mortgage (QM) status, and lender fees and charges; preparing regulatory impact analysis for rule; supporting the Office of Management and Budget (OMB) clearance process.
Enforcement Regulations Package
Assessing impact of policies related to implementing an enforcement suite that includes lender scorecards, lender lockout, limited denial participation, and penalties; drafting regulatory package and impact analysis to support OMB clearance process.
Assessing impact of policies related to implementing an appraisal panel renewal and removal process; drafting regulatory package and impact analysis to support OMB clearance process.
Administrative Law Judge (ALJ)
Servicer Tier Ranking with incentives for successful loss-mitigation
Regardless of the specific project, the following consulting services will be required:
Analyzing agency objectives and implications of alternative policies
Technical writing and editing in drafting regulations, information collection requests, and regulatory impact analyses
Supporting compliance with the Administrative Procedure Act (APA) and applicable statutory requirements and executive orders
Analyzing and summarizing public comments
Conducting regulatory impact analyses, to include research, collecting, and analyzing pertinent internal and external housing and economic data
Background: Loan Guaranty Service (LGY) is working on a number of high priority regulations designed to ensure VA home loans remain competitive with other mortgage products while providing appropriate protections for Veterans and military borrowers. Because the regulatory process can take upwards of 18-24 months under the best of circumstances, it is critical that LGY maintain momentum on these projects. While LGY currently has two full-time employees (FTEs) whose primary duties include regulation development and drafting, they are also responsible for other policy-related activities such as legislative views, proposals, and technical assists, Freedom of Information Act (FOIA) requests, and special projects, as appropriate. The contractor will provide experience in drafting economic analysis documents that conform with all applicable laws, regulations, directives, and Executive Orders. Recent interactions with the OMB, to include its latest review of LGY s interim final rule on VA cash-out refinance loans, revealed that future VA regulatory impact analyses will require more robust economic analyses that are on par with agencies that have teams solely devoted to economic forecasting and data analysis. Contractors will review non-sensitive information at a Low Risk nature for background information purposes. The C&A requirements do not apply, and that a Security Accreditation Package is not required.
Performance Period: The period of performance is one year, 8/1/19 7/31/20. Work at the government site shall not take place on Federal holidays or weekends unless directed by the Contracting Officer (CO).
Type of Contract: Firm-Fixed Price
Place of Performance: Work must be performed at the government s site. 1800 G Street NW Washington, DC 20006
Jeffrey A Reed
Contract Specialist
215-906-5468
Contracting Officer
