Saturday, May 8, 2021
Home #BlackLivesMatter New Rule Finalizes Small-Business Subcontracting Changes

New Rule Finalizes Small-Business Subcontracting Changes

The Business as Usual approach which National Association of Mortgage Field Services (NAMFS) Offender Members have ran the Mortgage Field Services Industry from may be coming to an end. Since the inception of the US Department of Housing and Urban Development‘s (HUD) Management and Marketing (M&M) Field Service Manager (FSM) Contract offering, the same names have always been awarded billions of dollars in contracts since the inception its now infamous system. HUD began outsourcing the handling of their foreclosed FHA inventory in 1999 by and through the Management and Marketing Award Process.

On 14 June 2010, HUD had this to say,

The U.S. Department of Housing and Urban Development (HUD) today announced it is awarding contracts to 23 companies to serve as Asset Managers (AM) and 32 other firms to serve as Field Service Managers (FSM) under the third generation of its Management and Marketing (M) program, known as M III. The new contracts announced today are intended to reduce risk, increase sale prices and accelerate the pace of reselling HUD’s inventory of foreclosed FHA homes.

Matter of fact, then HUD Secretary Shaun Donovan had this to say when he rolled out the new and improved HUD M&M FSM 3.0,

These new contracts epitomize FHA’s continuing effort to reduce risk, increase net returns, decrease holding times, and improve efficiency in the resale of its inventory of foreclosed properties. It is critically important that FHA successfully and efficiently sell its inventory of these properties, and these contractors will help us do that.

The problem is that small businesses whom actually perform the work HAVE NEVER BENEFITED from HUD and in fact both Labor and US Taxpayers have been defrauded to the tune of tens of millions of dollars over the past several years alone.

Over the years, the NAMFS Regime has matured from a gangly child; awkward in its approach to the Industry, into a menacing juggernaut hell bent upon fraud, deceit and corruption. Fitting the classic definition of a Cartel, its Leadership began to realize that its once novel approach to assisting its Offender Members in the navigation of federal bureaucracies now required a more hands on approach to conceal its financial insolvency and profit losses. The NAMFS Regime initiated an active network replete with typewritten manuals ordered by Joseph Badalamenti, Founder of Five Brothers, creating entire frameworks for fraudulent charging back of Labor for millions of dollars in False Claims which had been submitted to financial institutions and the US Government. You see, the NAMFS Regime protected its hierarchy while it looted Main Street. The NAMFS Regime became identical to a rapist and daily victimized Minority Females like a pedophile out on bail.

Under amended FAR subpart 19.704(a)(2), contracting officers will have discretionary authority to require a contractor to establish subcontracting goals both in terms of total subcontract dollars and in terms of total contract dollars. The Federal Acquisition Regulatory Council clarified that use of total contract dollars is in no way an attempt to influence a contractor’s make or buy decision and clarified that a contracting officer will make such decisions on a case-by-case basis. In addition, under the amended FAR subpart 19.705-1, the contracting officer may establish small-business subcontracting goals at the order level for indefinite-delivery, indefinite-quantity contracts.

It gets better, though,

The rule provides a contracting officer with the authority to require a subcontracting plan from a prime contractor during contract performance in two situations:

  1. Under the amended FAR 19.301-2, contracting officers will be able to require a subcontracting plan in the event that a prime contractor’s size changes from small to other-than-small as a result of a size rerepresentation on a contract that contains FAR clause 52.219-9.

  2. In addition, the amended FAR 19.702 will allow a contracting officer to require a subcontracting plan when a contract modification of any value causes a contract’s value without a subcontracting plan to exceed the subcontracting plan threshold and subcontracting opportunities exist.

Just saying, Eric Miller. By the way,

Eric Miller, NAMFS, #BlackLivesMatter

Paul Williams
Linux addict buried deep in the mountains of East Tennessee.



Most Popular