Fed Cetera to Provide Free HUBZone Services to Members

COLLINGSWOOD, N.J. — The Fed Cetera Network, a business development organization under 48 CFR 52.219-9, will now offer members complimentary consulting and filing assistance services to apply for the U.S. Small Business Administration’s Historically Underutilized Business Zone (HUBZone) program. Fed Cetera will answer questions, assemble pertinent information, and submit initial applications on behalf of members.  Here’s a link where small businesses can contact Fed Cetera to inquire about joining the network.

Federal agencies have a goal of spending 3% of all contracting dollars with HUBZone-certified small businesses.  For example, The U.S. Department of Treasury has met its HUBZone prime spending goals every year since Federal Fiscal Year 2011, while the U.S. Department of Education has never met any prime spending goals for the HUBZone category since this small business contracting data has been publicly available through Federal Fiscal Year 2017, the last year for which data is available.  Check out links to SBA scorecards on these Federal agencies on the Resources page of Fed Cetera’s website.

A HUBZone program applicant must:

  • Be a small business.
  • Be at least 51% owned and controlled by U.S. citizens, a Community Development Corporation, an agricultural cooperative, a Native Hawaiian organization, or an Indian tribe.
  • Have its principal office located in a HUBZone. (The Resources page of the Fed Cetera website includes a link to the look up tool.)
  • Have at least 35 percent of its employees live in any HUBZone.

“We have seen an increased interest in this program, so we are responding to our members’ needs in this important area,” states Leah Wilson Conger, the organization’s co-operator. “We look forward to adding to our already-impressive roster of the most qualified HUBZone-certified small businesses available to Federal agencies and prime contractors with default collection needs.”

The Fed Cetera Network is a one-stop shop for Federal contractors, including United States Department of Education (ED) PCA contractors, to easily find pre-qualified potential subcontractors, protégés, and joint venture partners who have the wherewithal to implement Federal subcontracts successfully.  The Fed Cetera Network has helped dozens of small businesses pursue and receive Federal subcontracts over the years, and has helped multiple small businesses find and gain approval for mentorships under the SBA All-Small Mentor-Protégé Program. Fed Cetera hopes to provide even more opportunities to its members by assisting them in the HUBZone certification process.

About Fed Cetera
Fed Cetera is a “business development organization” under 48 CFR 52.219-9 that PCAs contact when subcontracting opportunities are available in order to be fully compliant with Federal regulations requiring outreach to various sources of potential subcontractors.  The company maintains a source list of qualified small collection firms, regularly markets to the PCA community, and provides advisory services around business development and compliance to firms operating in the federal market place.

HS Financial Group Achieves Federal SDVOSB Certification

CLEVELAND, Ohio — HS Financial Group, LLC, today announced it has achieved Service Disabled Veteran-Owned Small Business (SDVOSB) certification through the U.S. Department of Veterans Affairs (VA), Center for Verification and Evaluation (CVE) and has been added to the VA’s Vendor Information Pages (VIP).

The VA’s Vets First Verification Program is a result of The Veterans Benefits, Health Care, and Information Technology Act of 2006 (Public Law 109-461). The CVE verifies SDVOSBs/VOSBs according to the tenets found in Title 38 Code of Federal Regulations (CFR) Part 74 that address Veteran eligibility, ownership, and control. In order to qualify for participation in the Veterans First Contracting Program, eligible SDVOSBs/VOSBs must first be verified.

Due to Federal programs encouraging small business utilization and SDVOSB participation in procurements, HS Financial has emerged over the last several years as a leading small business subcontractor on Federal contracts related to default collection and other student loan business processes.  With this certification, HS Financial is the SDVOSB with the most experience among a small but growing cohort of such firms. There are currently forty-six (46) small businesses listed at www.sam.gov as SDVOSBs under the NAICS code for debt collection (561440).

“We are pleased to offer our experience along with this certification to any firm(s) interested in subcontracting and other opportunities,” stated disabled veteran owner Tim Sullivan, Esq., continuing, “We have the capacity to expand greatly to assist any firm with small business and SDVSOB spending goals in a fully compliant manner that maximizes results.”

To be eligible to be a SDVOSB, the following criteria must be met:

  • The Service Disabled Veteran (SDV) must have a service-connected disability as determined by the VA or Department of Defense (DoD).
  • The business must be small under its primary NAICS code.
  • One or more SDVs must hold the highest officer position, must unconditionally own 51% of the business, and must control its management, long-term decision making, and daily operations.
  • SDV ownership must be direct ownership.

HS Financial is a member of the Fed Cetera Network, a business development organization under 48 CFR 52.219-9.  “The small business market in Federal contracting is changing generally as is the SDVOSB market specifically,” stated Nick Bernardo, co-operator of the organization.  “We are pleased to offer Federal buyers and contractors the best options for small business utilization and SDVSOBs specifically, particularly one as experienced and well respected as HS Financial.”

About HS Financial

HS Financial Group, LLC, is a Service Disabled Veteran-Owned Small Business founded in 2000 by Timothy M. Sullivan, Esq., and is located in Cleveland, Ohio. HS Financial Group focuses on consumer, government, education, and commercial collections and currently has over a billion dollars of receivables under management. The organization employs an extensive staff including collection professionals, attorneys, and support personnel united by a singular mission of partnering with clients in the management and liquidation of their delinquent receivables. With its knowledgeable and seasoned team of empowered professionals, utilizing state-of-the-art infrastructure and technology, HS Financial Group strives to develop custom-tailored, secure and efficient collection solutions for each client and deliver professional recovery results achieved through its core values of professionalism, ethics, and excellence. To learn more about HS Financial Group and its Accounts Receivable Management program and capabilities, please visit our website at www.hsfgroup.net.

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LoanWise Achieves Federal HUBZone Certification

NATIONAL CITY, Calif. — LoanWise announced today that it has achieved Historically Underutilized Business Zone (HUBZone) certification through the U.S. Small Business Administration (SBA). The HUBZone program helps small businesses in urban and rural communities gain preferential access to Federal procurement opportunities. The program was enacted into law as part of the Small Business Reauthorization Act of 1997.

Due to Federal programs encouraging small business utilization and HUBZone participation in procurements, LoanWise is just one of many HUBZone-certified small businesses with the capacity to collect Federal student loans.  There are currently thirty-two (32) small businesses listed at www.sam.gov as HUBZone-certified under the NAICS code for debt collection (561440).

The largest single Federal client for private collection agencies (PCAs) remains The U.S. Department of Education (ED). LoanWise has remained a subcontractor on the ED PCA contracts since 2008, performing for multiple PCAs in that time. LoanWise attributes its multiple successes as an ED subcontractor to continued top-of-the-line training, excellent employee benefits, and generous compliance and production bonuses.  The company is also certified as a woman-owned small business (WOSB). The San Diego labor market is an up-and-coming one for Federal subcontractors, and LoanWise has the capacity to add additional Federal subcontracts to its client roster.

“We are pleased that the SBA has seen fit to grant us this designation,” said Carol Patry, owner of the company, continuing, “We are anxious to provide additional employment opportunities to people in our area as we help PCAs absorb additional volumes from Federal agencies.”

LoanWise is a member of the Fed Cetera Network, a business development organization under 48 CFR 52.219-9.  As a small business, LoanWise qualifies for the SBA’s All Small Mentor Protégé Program (ASMPP).  Fed Cetera will hold a teleseminar at 11AM EST on October 4, 2018, on the ASMPP program.  Here is where you can sign up to attend.

Federal HUBZones are designated as such based on U.S. census data when an area has statistically proven economic needs, typically within depressed urban or rural communities. The U.S. Small Business Administration (SBA) certifies firms as HUBZone small businesses if they meet all of the eligibility requirements. For starters, the firm must be owned at least 51% by American citizens, with few exceptions.  The firm’s principal office must be located with a HUBzone, and more than 35% of the firm’s employees must live in a HUBZone. These requirements are just the beginning of establishing a business as a HUBZone-certified concern.

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ORH Counselors Achieves Federal SDVOSB Certification

NORRISTOWN, Pa. — ORH Counselors today announced it has achieved Service-Disabled Veteran-Owned Small Business (SDVOSB) certification through the U.S. Department of Veterans Affairs (VA), Center for Verification and Evaluation (CVE) and has been added to the VA’s Vendor Information Pages (VIP).

The VA’s Vets First Verification Program is a result of The Veterans Benefits, Health Care, and Information Technology Act of 2006 (Public Law 109-461). The CVE verifies SDVOSBs/VOSBs according to the tenets found in Title 38 Code of Federal Regulations (CFR) Part 74 that address Veteran eligibility, ownership, and control. In order to qualify for participation in the Veterans First Contracting Program, eligible SDVOSBs/VOSBs must first be verified.

Due to Federal programs encouraging small business utilization and SDVOSB participation in procurements, ORH is just one of many SDVOSB small businesses with the capacity to collect Federal student loans.  There are currently forty-five (45) small businesses listed at www.sam.gov as SDVOSBs under the NAICS code for debt collection (561440).

The largest single Federal client for private collection agencies (PCAs) remains The U.S. Department of Education (ED).  ORH is currently implementing its first subcontract in suburban Philadelphia, a metropolitan area long known for its abundance of agents with past experience on Federal task orders. ORH has the capacity to add additional Federal subcontracts to its client roster.

“ORH Counselors is pleased to be able to offer Federal contractors the ability to count subcontracts given to us toward their Federal SDVOSB spending goals,” stated CEO Keith Baker, continuing, “We have confidence our resources and capital are sufficient to meet the needs of additional Federal clients.”

To be eligible as a SDVOSB, the following criteria must be met.

  • The Service Disabled Veteran (SDV) must have a service-connected disability as determined by the VA or Department of Defense (DoD).
  • The business must be small under its primary NAICS code.
  • One or more SDVs must hold the highest officer position, must unconditionally own 51% of the business, and must control its management, long-term decision making, and daily operations.
  • SDV ownership must be direct ownership.

ORH is a member of the Fed Cetera Network, a business development organization under 48 CFR 52.219-9.

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Federal SBA Mentoring Program Teleseminar to Feature SDVOSBs / HUBZone Protégé Options

COLLINGSWOOD, N.J. — The Fed Cetera Network, a business development organization under 48 CFR 52.219-9, will hold a teleseminar at 11AM EST on October 4, 2018, on the topic of the U.S. Small Business Administration (SBA) All Small Mentor Protégé Program (ASMPP).  The teleseminar will also feature brief overviews of Fed Cetera service disabled, veteran-owned (SDVOSB) and HUBzone-certified members who are seeking mentors. Here is where you can sign up to attend.

The SBA’s ASMPP launched in October of 2016 to provide a way for small businesses with any or no special socioeconomic designation(s) to form a mentoring relationship with another business in a manner previously available only to 8(a) firms.

The program benefits both mentors and protégés.  Mentors can form joint ventures with their protégé and compete for federal contracts and subcontracts on the basis of the protégé’s socioeconomic attributes, so, for example, a large business that becomes an approved mentor to an SDVOSB can compete as a joint venture partner to the SDVOSB for those opportunities, and the joint venture is considered an SDVOSB, regardless of the mentor’s status.  The mentor can own part of the protégé’s business, and can perform a sizeable portion of any resulting work. Protégés can receive various types of assistance, including financial assistance, from an approved mentor.

The Fed Cetera Network has a number of small businesses that have expressed interest in partnering with a mentor to pursue Federal opportunities, including SDVOSB and HUBzone firms.  Some of those firms will be profiled on the call.

The teleseminar costs $100 to attend, but is free to Fed Cetera Network members and to Private Collection Agencies (PCAs) now serving any U.S. Federal government agency, as well as to bidders to solicitation ED-FSA-16-R-0009.  Others will be invoiced upon sign up.

The Fed Cetera Network is a one-stop shop for Federal contractors, including United States Department of Education (ED) PCA contractors, to easily find pre-qualified potential subcontractors, protégés, and joint venture partners who have the wherewithal to implement Federal subcontracts successfully.  The Fed Cetera Network has helped dozens of small businesses pursue and receive Federal subcontracts over the years, and has helped multiple small businesses find and gain approval for mentorships under the SBA ASMPP. Member companies pay nothing to join the network, but pay only a nominal fee if successfully placed as a subcontractor with a Federal contractor.

Despite all that’s been written recently about the ED solicitation still in litigation, all federal agencies, including ED, have statutory requirements to spend significant dollars directly with small businesses.  According to the SBA’s small business dashboard, 71.2% of the $843.8M small business dollars spent by ED and 24% of the $2.5B eligible dollars for the Federal fiscal year ending later this month (dollars subject to small business percentage spending requirements), have been spent with small PCAs.  (You read that right. Nearly a quarter of every dollar ED spends on anything goes to a small business PCA.)

Many of the PCAs originally awarded as small businesses in 2014 are already large today and will be forced to reclassify as such in 2019.  ED’s stated intent to implement an enhanced servicer program is expected to come to fruition at some unknown, distant point in time in the future.  Meanwhile, news of Judge Wheeler’s permanent enjoinment against any cancellation of solicitation ED-FSA-16-R-0009 may result in additional contracts and placements to large PCAs.

None of these things has anything to do with ED’s statutory requirement to make direct awards for goods and services to small businesses, requirements that cannot be met through subcontracting, which ED will simply not meet without hiring small business collection agencies.

About Fed Cetera
Fed Cetera is a “business development organization” under 48 CFR 52.219-9 that PCAs contact when subcontracting opportunities are available in order to be fully compliant with Federal regulations requiring outreach to various sources of potential subcontractors.  The company maintains a source list of qualified small collection firms, regularly markets to the PCA community, and provides advisory services around business development and compliance to firms operating in the federal market place.

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ED’s Pending PCA Small Biz Set Aside: More Litigation?

As the industry waits for news this Friday from the Department of Education (ED) regarding next steps in the unrestricted private debt collection contract litigation, another story has emerged.

A source familiar with what’s happening in this space reports to insideARM that ED recently signaled its intent to hold another procurement for Private Collection Agency (PCA) services in the months ahead – one set aside for small businesses – that could lead to even more litigation.

The recently-disclosed procurement plans are cited within a spreadsheet available for download on a page of ED’s websiteabout forecasted contract opportunities.  The file is dated January 23, 2018, and indicates a procurement for default collection services is planned to begin during the Federal third quarter.  For those unfamiliar with Federal accounting practices, that’s this quarter.

Before anyone assumes the news will usher in a new round of restraining orders filed by jilted contractors, it’s no surprise why a set aside procurement would be in the works at ED, since there are reasons why one would be necessary.  Work has been partially set aside for small businesses since 1997, and contracts let to small businesses by ED are historically not as protest-prone as those let on an unrestricted basis.  Today, PCAs hired as small businesses are doing the lion’s share of all default collection work for ED.

“People should keep in mind, the Federal government has no large business spending requirements,” stated Nick Bernardo, a principal at Fed Cetera, a business development organization serving collection agencies that seek Federal work, continuing, “The Federal government only has small business spending requirements.”

This of course alludes not only to the government-wide mandate for Federal agencies to spend 23% of all contracting dollars with small businesses, but also to ED’s agency-level goal, which stood at 25.5% in Federal fiscal year 2016, the last year for which final performance data is available.  That year, ED missed its mark, achieving 23.35% of spending with small businesses to go with a “C” rating, according to data within a reportavailable on the Small Business Administration (SBA) website.

The same report’s comment section indicates ED, “remains dedicated and committed to small businesses and is actively engaged in outreach, training, advocacy, and strategic partnering. The Department has strong support and collaboration of our senior leadership, and will continue to strengthen our program, even in the face of programmatic challenges.”

One can infer these comments relate at least partially to the PCA program, since, according to the Federal Small Business Dashboard, unofficial tallies for Federal fiscal year 2017 show small business PCAs accounted for more than 55% of $657 million in direct small business spending at ED last year, and more than 15% of $2.4B in total ED spending during the same period.  And this in a year when the U.S. Court of Federal Claims cut off new work for eight months, beginning with the last five months of that fiscal year.

In that sense, small business PCA utilization is part of ED’s strategy to meet dual needs: to properly service defaulted student loan borrowers on one hand, and to meet its small business utilization goals on the other, which ED would simply not meet without setting some PCA work aside for small business.

Because more than a handful of large businesses now in litigation with ED over the unrestricted procurement were originally awarded contracts set aside for small businesses when they themselves were small, it could be argued ED could not meet its overall defaulted student loan needs without using set aside contracts as a proving ground for small businesses that ultimately “grow up” and take on much larger volumes of work that needs to be done.

The law of unintended consequences being what it is, the centralization of Federal student loan lending since 2010, plus mandates for ED to use small businesses as prime PCAs and as subcontractors to prime PCAs, has created a large pool of small businesses now qualified to do the work.

But why wouldn’t the current field of eleven small businesses simply keep shouldering the load of servicing borrowers and helping ED meet small business goals, you might ask? Small business contracts awarded in 2014 were awarded as “long term contracts” in Federal parlance, which subjects them to regulations requiring Federal contracting officers to request “that a business concern recertify its small business size status no more than 120 days prior to the end of the fifth year of the contract, and no more than 120 days prior to exercising any option thereafter.” (78 Fed. Reg. 61114 [Oct. 2, 2013])

Industry insiders are speculating that very few, if any, of the current eleven small PCAs may be able to recertify as small businesses when the time comes.  This means ED can’t take credit for small business spending after that unless they do something, like hire more small businesses.

Companies able to compete for new small business awards are just as numerous as those still competing for the unrestricted awards now held up in litigation. The field includes up to a few of the current eleven small PCAs, numerous current small business subcontractors, many former small business subcontractors to unrestricted PCAs that stopped receiving new work since 2015, newly-formed companies with owners who have decades of ED experience, and possibly a few formerly-large PCAs that may have fallen under the size standard for collection agencies because they stopped receiving new work from what had been their largest client in 2015. That’s to say nothing of many other firms that have not done this work in the past yet have lots of higher education experience, and any number of other would-be competitors.

Since ED’s the only game in town, this sets up a potential for a repeat of what has transpired with unrestricted contracts over the past few years.  The sheer number of qualified bidders, plus the fact that the very existence of so many potential bidders rides on doing this work, portends a high likelihood of more protests, and more litigation, unless ED can devise a strategy to avoid it.

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