Subject: File No. 4-668
From: Anonymous

December 23, 2013

We are somewhat disappointed with the proposed selection process. Firstly, the eligibility of SROs to respond to a RFP that they have authored collaboratively. Secondly, the involvement of such SROs in the selection/evaluation of competing responses to the CAT RFP. These dual roles can be argued as having ‘conflict of interests’.

We appreciate the steps described in the revised selection process to have firewalls within the SROs to segregate the individuals who are involved in the CAT selection, CAT response formulation and CAT RFP formation. However, the genuineness of such a separation is questionable in ‘for profit’ organizations. We presume it is challenging to enforce and monitor such restrictions where individuals are inextricably linked within the SROs.

We appreciate the SROs’ eagerness for fairness and transparency in the selection process, but at the same time we are concerned about their ability to remain neutral in executing the above ‘conflicting’ responsibilities.

Therefore, to eliminate the conflict of interests, our preference is to see a further amendment to the selection process, such that either:

1. Limit the respondents to CAT to non-SROs - such that SROs are collectively able to find the most technologically advanced and functionally rich solution for the CAT. The SROs can partner with the winning non-SRO bidder to implement and manage the CAT system.


2. Limit the respondents to the CAT only to the SROs, such that the CAT solution is conceived, developed and delivered by the SROs.