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United States Government Accountability Office: 
GAO: 

Report to the Committee on Small Business and Entrepreneurship, U.S. 
Senate: 

January 2013: 

Export Promotion: 

Small Business Administration Needs to Improve Collaboration to 
Implement Its Expanded Role: 

GAO-13-217: 

GAO Highlights: 

Highlights of GAO-13-217, a report to the Committee on Small Business 
and Entrepreneurship, U.S. Senate. 

Why GAO Did This Study: 

In January 2010, the President announced the goal of doubling U.S. 
exports over 5 years. The President’s plan in the National Export 
Initiative included prioritizing exports by small businesses and 
called for improved coordination among agencies involved in federal 
export promotion activities. Recently, Congress has also directed SBA 
to expand its export counseling and financing activities. This report 
(1) describes SBA’s role within federal export promotion efforts, (2) 
assesses the extent to which SBA collaborates with other agencies in 
its export promotion activities, and (3) assesses the extent to which 
SBA is meeting requirements under the Small Business Jobs Act of 2010 
to expand export promotion training and staffing. GAO analyzed agencies’
documents and interviewed agency officials, including those in six 
selected field office locations serving areas with high export 
potential and where staff from at least two agencies were colocated. 

What GAO Found: 

The Small Business Administration (SBA) and five other key agencies 
provide a variety of export promotion services to small businesses. In 
addition to outreach, which all six agencies conduct, SBA’s primary 
activities include counseling and training, provided mainly through 
nonfederal partner entities called Small Business Development Centers, 
and export financing, provided through SBA’s Office of International 
Trade (OIT). 

While SBA collaborates to some extent with other key agencies on its 
export promotion activities, additional collaboration could enhance 
agency efforts and reduce overlap. SBA, Department of Commerce 
(Commerce), and the U.S. Export-Import Bank (Ex-Im) coordinate some 
export promotion activities at headquarters and at field locations, 
but some services overlap. For example, Small Business Development 
Centers and Commerce both assist companies new to exporting as well as 
more experienced exporters, despite intentions to divide 
responsibilities for those types of firms. Additionally, OIT and Ex-Im 
offer similar financial products for small businesses, such as export 
working capital loan guarantees. Overlapping services may cause 
confusion for small businesses and result in inefficient use of 
government resources. SBA and other agencies developed a joint 
strategy to increase small business exports and, to varying degrees, 
the agencies have included collaborative efforts in the performance 
evaluations of staff with export promotion responsibilities. However, 
SBA and other agencies have not clearly defined roles and 
responsibilities, and efforts to leverage resources have not included 
regularly sharing client information where possible. Such sharing 
could help agencies improve client services and clarify each agency’s 
impact in promoting U.S. exports. Enhancing collaboration could help 
agencies ensure they are working toward the goal of increasing exports 
by small businesses in a way that maximizes limited resources and 
mitigates overlap. 

SBA has made some progress in increasing export training of Small 
Business Development Center counselors but has experienced challenges 
in meeting increased OIT staffing requirements under the Small 
Business Jobs Act of 2010. The law required a certain number or 
percentage of staff working for the 63 Small Business Development 
Center networks to obtain export counseling certification. As of the 
end of September 2012, 73 percent of the networks had met this 
requirement, for which SBA set a 2013 deadline. To meet another 
requirement under the law, SBA needed to increase its OIT field staff, 
who primarily provide export financing assistance, from 18 to 30 
staff, by the end of September 2012. However, SBA has only advertised 
for four temporary positions and filled two of them. SBA officials 
noted challenges in finding qualified candidates and lack of continued 
funding for additional OIT field positions. In a recent report to 
Congress, SBA stated its plans to hire the additional OIT staff but 
did not include funding plans or updated time frames to fill the 
positions. Furthermore, the plan did not discuss how SBA would 
overcome the hiring challenges or discuss the potential to leverage 
resources of other export promotion entities that also provide export 
assistance. 

What GAO Recommends: 

GAO recommends that SBA (1) consult with Commerce and Ex-Im and 
clearly define export entities’ roles and responsibilities; (2) 
consult with Commerce and Ex-Im and identify ways to increase, where 
possible, sharing of client information; and (3) update its plan for 
meeting mandated staffing requirements to include funding sources and 
time frames, as well as possible efficiencies from improved 
collaboration. SBA agreed with our recommendations and noted it is 
taking steps to address them. We also received technical comments from 
other key export promotion agencies, which we incorporated, as 
appropriate. 

View [hyperlink, http://www.gao.gov/products/GAO-13-217]. For more 
information, contact Loren Yager at (202) 512-4347 or yagerl@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

SBA Provides Export Promotion Assistance to Small Businesses within a 
Complex, Multiagency Environment: 

SBA Has Taken Steps to Collaborate with Other Agencies, but Further 
Collaboration Efforts Are Needed: 

SBA Has Made Some Progress in Increasing Export Training but 
Experienced Challenges in Meeting Staffing Requirements under the 
Small Business Jobs Act of 2010: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Small Business Administration: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Congressional Committees with Jurisdiction over Key Agencies' 
Export Promotion Activities: 

Table 2: Export Promotion Program Budget, Fiscal Year 2012 (Requested): 

Table 3: U.S. Agencies' Activities to Support Small Business Exports: 

Table 4: Export Financing Assistance Programs Available to Small 
Businesses, by Federal Agency: 

Table 5: Selected Features and Limitations of SBA and Ex-Im Working 
Capital Loan Guarantees: 

Table 6: Selected Features and Limitations of SBA and Ex-Im Express 
Loan Programs: 

Table 7: Best Practices in Collaboration: 

Figure: 

Figure 1: Locations and Number of SBA OIT Staff by SBA Region, as of 
September 30, 2012: 

Abbreviations: 

Commerce: Department of Commerce: 

Ex-Im: U.S. Export-Import Bank: 

NEI: National Export Initiative: 

OIT: Office of International Trade: 

SBA: Small Business Administration: 

SBDC: Small Business Development Centers: 

SBJA: Small Business Jobs Act of 2010: 

State: Department of State: 

Strategy: National Export Strategy: 

TPCC: Trade Promotion Coordinating Committee: 

USDA: U.S. Department of Agriculture: 

USEAC: U.S. Export Assistance Center: 

USTDA: U.S. Trade and Development Agency: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

January 30, 2013: 

The Honorable Mary Landrieu: 
Chair: 
The Honorable James Risch: 
Ranking Member: 
Committee on Small Business and Entrepreneurship: 
United States Senate: 

The Honorable Benjamin Cardin: 
Committee on Small Business and Entrepreneurship: 
United States Senate: 

The Honorable Jeanne Shaheen: 
Committee on Small Business and Entrepreneurship: 
United States Senate: 

In January 2010, the President launched the National Export Initiative 
(NEI) with the goal of doubling U.S. exports over 5 years and 
prioritizing exports by small businesses. The President stated that 
the NEI was a key component of his administration's plan to help the 
United States transition from economic crisis to sustained recovery, 
as the potential of exports could help accelerate job growth. While 
exporting is fundamentally a decision driven by firms in the private 
sector, the federal government provides various types of assistance to 
U.S. exporters, especially small businesses, to help them overcome the 
challenges to selling their goods and services abroad, including a 
lack of information about exporting and foreign markets and 
difficulties in obtaining export financing. 

Many federal agencies are involved in export promotion. While the 
Department of Commerce's (Commerce) Commercial Service has 
historically been the primary U.S. export promotion entity, Congress 
recently directed the Small Business Administration (SBA) to increase 
its export activities, including export counseling and financing. 
[Footnote 1] Through the Small Business Jobs Act of 2010 (SBJA), 
Congress directed SBA to enhance its field presence by increasing the 
number and improving the training of its field staff, including staff 
at its nationwide network of over 900 Small Business Development 
Centers (SBDC), SBA partner entities that also provide export 
assistance to small businesses.[Footnote 2] SBA's Office of 
International Trade (OIT) leads SBA's efforts in cooperating with 
other federal agencies and public-and private-sector groups to 
encourage small business exports and to assist small businesses 
seeking to export. Both SBA OIT staff and the staff at the U.S. Export-
Import Bank (Ex-Im) provide export financing assistance to small 
businesses. 

This report (1) describes SBA's role within federal export promotion 
efforts, (2) assesses the extent to which SBA collaborates with other 
agencies in its export promotion activities, and (3) assesses the 
extent to which SBA is meeting SBJA requirements to expand export 
promotion training and staffing. 

To address these objectives, we defined "export promotion activities" 
as programs and services conducted by federal agencies that involve 
direct contact with U.S. exporters and have export promotion as their 
stated goal. Such activities include providing small businesses with 
export counseling, training, and financial assistance; they do not 
include activities such as advocacy, commercial diplomacy, and policy 
development and negotiations. Our review, therefore, covers six key 
agencies--SBA, Commerce, Ex-Im, the U.S. Department of Agriculture 
(USDA), the U.S. Trade and Development Agency (USTDA), and the 
Department of State (State)--with a particular emphasis on SBA's 
activities.[Footnote 3] Our assessment of coordination focused on 
coordination between SBA entities and Commerce and Ex-Im, which are 
key agencies that provide export promotion activities similar to those 
provided by SBA entities. We analyzed government-wide initiatives, 
strategies, and laws, as well as agencies' documents and data. We also 
interviewed agency officials representing the key export promotion 
entities in headquarters and in six selected field locations--Chicago, 
Dallas, Irvine (California), Miami, New York, and Portland (Oregon). 
We selected these locations because SBA staff were colocated with at 
least Commerce staff and in some cases with Ex-Im staff, had the 
presence of SBDCs with staff providing export assistance, and ranked 
among locations with the highest export potential according to 
Commerce data. At some of these selected locations, we also met with 
representatives of small businesses that used federal government 
export assistance. The results of our interviews with officials at 
these six locations are not generalizable to agency officials' views 
at all U.S. locations. We assessed interagency coordination primarily 
against selected practices for enhancing and sustaining collaboration 
we previously identified.[Footnote 4] We selected four collaboration 
practices--establishing mutually reinforcing or joint strategies, 
reinforcing individual accountability for collaboration efforts, 
agreeing on roles and responsibilities, and leveraging resources to 
identify and address needs--because they allowed us to highlight the 
most critical and relevant elements of collaboration among export 
agencies at headquarters and the field level. Among many requirements 
under the SBJA, we focused on the training and staffing requirements 
applicable to SBDC staff and OIT in the field locations, respectively. 
See appendix I for more details on our scope and methodology. 

We conducted this performance audit from February 2012 to January 2013 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

Federal Interagency Entities Involved in Export Promotion: 

Title II of the Export Enhancement Act of 1992 authorized the creation 
of an interagency body called the Trade Promotion Coordinating 
Committee (TPCC) to carry out various duties, including coordinating 
the export promotion and export financing activities of the U.S. 
government, ensuring better delivery of services to U.S. businesses, 
and preventing unnecessary duplication among federal export promotion 
and export financing programs.[Footnote 5] The Export Enhancement Act 
requires this committee to issue an annual report to Congress 
containing a government-wide strategic plan for federal trade 
promotion efforts and describing the plan's implementation.[Footnote 
6] As a result, the TPCC's National Export Strategy, which articulates 
U.S. plans to increase exports, is generally issued annually.[Footnote 
7] The President also created the Export Promotion Cabinet and 
directed it to develop and coordinate the implementation of the NEI, 
working with the existing TPCC.[Footnote 8] The Export Promotion 
Cabinet delivered a September 2010 report to the President with 
recommendations to implement the goals of the NEI. The report 
identified several recommendations that support the NEI's priority of 
increasing exports by small businesses, including a recommendation to 
coordinate, expand, and leverage federal outreach resources to 
identify potential exporters. 

Some of the approximately 20 TPCC member agencies directly assist 
small businesses to export overseas, including the SBA, Commerce, Ex-
Im, USDA, USTDA, and State. These six agencies are overseen by various 
congressional committees, including appropriation and authorizing 
committees (see table 1). In 1993, the TPCC recommended that three 
agencies--the SBA, Commerce, and Ex-Im--colocate their staff at a 
domestic network of selected U.S. Export Assistance Centers 
(USEAC).[Footnote 9] These "one-stop shops" were to provide 
coordinated export training, trade leads, export finance, and 
counseling to U.S. businesses interested in becoming exporters. 

Table 1: Congressional Committees with Jurisdiction over Key Agencies' 
Export Promotion Activities: 

Agency: SBA; 
Committee on Appropriations: 
House Subcommittee: Financial Services and General Government; 
Senate Subcommittee: Financial Services and General Government; 
Authorizing committees with jurisdiction: 
House: Small Business; 
Senate: Small Business and Entrepreneurship. 

Agency: Commerce (International Trade Administration); 
Committee on Appropriations: 
House Subcommittee: Commerce, Justice, Science and Related Agencies; 
Senate Subcommittee: Commerce, Justice, Science and Related Agencies; 
Authorizing committees with jurisdiction: 
House: Foreign Affairs; 
Senate: Banking, Housing and Urban Affairs; Commerce, Science and 
Transportation. 

Agency: Ex-Im; 
Committee on Appropriations: 
House Subcommittee: State, Foreign Operations, and Related Agencies; 
Senate Subcommittee: State, Foreign Operations, and Related Agencies; 
Authorizing committees with jurisdiction: 
House: Financial Services; 
Senate: Banking, Housing, and Urban Affairs. 

Agency: USDA (Foreign Agricultural Service); 
Committee on Appropriations: 
House Subcommittee: Agriculture, Rural Development, Food and Drug 
Administration, and Related Agencies; 
Senate Subcommittee: Agriculture, Rural Development, Food and Drug 
Administration, and Related Agencies; 
Authorizing committees with jurisdiction: 
House: Agriculture; 
Senate: Agriculture, Nutrition and Forestry. 

Agency: USTDA; 
Committee on Appropriations: 
House Subcommittee: State, Foreign Operations, and Related Agencies; 
Senate Subcommittee: State, Foreign Operations, and Related Agencies; 
Authorizing committees with jurisdiction: 
House: Foreign Affairs; 
Senate: Foreign Relations. 

Agency: State; 
Committee on Appropriations: 
House Subcommittee: State, Foreign Operations, and Related Agencies; 
Senate Subcommittee: State, Foreign Operations, and Related Agencies; 
Authorizing committees with jurisdiction: 
House: Foreign Affairs; 
Senate: Foreign Relations. 

Source: GAO. 

[End of table] 

Export Promotion Funding: 

According to TPCC data, SBA's funding for export promotion activities 
has increased substantially in recent years, although SBA's funding 
remains a relatively small share of overall federal export promotion 
funding. For example, TPCC data showed that SBA received about $4 
million for export promotion activities in fiscal year 2006 and $5.2 
million in fiscal year 2010 and requested $6 million and $6.4 million, 
respectively, for fiscal years 2011 and 2012. While the fiscal year 
2012 request represents an increase of 60 percent from its fiscal year 
2006 funding levels, SBA's funding represents less than 1 percent of 
the total export promotion funding for the six key agencies that 
support small business exporting. According to the TPCC, the six key 
U.S. agencies requested over $1 billion for trade promotion activities 
in fiscal year 2012, and SBA requested $6.4 million, as shown in table 
2. 

Table 2: Export Promotion Program Budget, Fiscal Year 2012 (Requested): 

Agency: SBA; 
Budget request: $6.4 million. 

Agency: Ex-Im[A]; 
Budget request: $3 million. 

Agency: TDA; 
Budget request: $51 million. 

Agency: State[B]; 
Budget request: $198 million. 

Agency: Commerce; 
Budget request: $350 million. 

Agency: USDA; 
Budget request: $515 million. 

Agency: Total; 
Budget request: $1.123 billion. 

Source: TPCC Secretariat. 

[A] Since fiscal year 2008, Ex-Im has been self-sustaining for 
appropriations purposes, financing its operations from receipts 
collected from its borrowers. The fees charged by Ex-Im have covered 
its program subsidy and administrative costs in recent years. The 
program subsidy refers to budgetary resources that Ex-Im must allocate 
annually as capital reserves. Congress retains oversight of Ex-Im's 
budget by setting annual limits on Ex-Im's use of its funds for program 
subsidy and administrative expenses. For fiscal year 2012, Ex-Im 
requested $124.6 million for administrative expenses. 

[B] The budget request amount for State is cumulative for all business 
and economic activities in the agency. 

[End of table] 

TPCC member agencies may define trade promotion differently. For 
example, State's budget includes funding for all State business and 
economic activities because, according to State, those activities 
could contribute to enhancing U.S. trade. Conversely, the budget 
amount for SBA only includes funding for OIT even though other SBA 
entities, such as the SBDCs, may devote substantial amounts of time to 
export promotion. Therefore, the reported budget amounts may not 
always reflect each agency's total level of activity relating to 
export promotion or each agency's actual contribution toward 
increasing U.S. exports. Furthermore, the export promotion amounts in 
table 2 do not differentiate activities directed toward small 
businesses from those directed to larger businesses. All of the 
agencies other than SBA work with businesses of all sizes, which 
creates difficulties when making comparisons with SBA about export 
promotion assistance specifically focused on small businesses. 

SBA Entities Involved in Export Promotion: 

Within SBA, OIT has primary responsibility for export promotion. OIT's 
field staff of Export Finance Specialists are colocated with Commerce 
in 19 USEACs throughout the United States, with one OIT staff per 
USEAC. OIT field staff engage in a variety of activities but are 
primarily responsible for providing technical assistance, outreach, 
and training on SBA's export finance programs. 

Separate from OIT, SBDCs are nonfederal partner entities partially 
funded by SBA that provide a wide range of business services, such as 
assisting small businesses with financial and marketing advice and 
tools, primarily through one-on-one counseling services. The over 900 
SBDCs are organized into networks under 63 lead centers that largely 
correspond with state boundaries except in California and Texas, which 
have multiple lead centers. In addition to providing general business 
services, SBDCs may also help businesses interested in exporting, 
particularly those that are new to exporting and need assistance with 
preparing their business to export. For example, SBDCs may assist a 
company in developing an international business plan. While most SBDCs 
provide export assistance as one of many services, SBA has designated 
some SBDCs as International Trade Centers that focus primarily on 
exporting. 

One person in each of SBA's 68 District Offices is designated as a 
District International Trade Officer and provides basic export 
assistance as a collateral duty, but these officers spend most of 
their time on nonexport-related activities.[Footnote 10] The District 
International Trade Officers are managed by a separate SBA office, 
SBA's Office of Field Operations, and they are not usually colocated 
at USEACS. SBA intended that District International Trade Officers 
only spend about 15 percent of their time on export promotion 
responsibilities. These responsibilities include organizing and 
attending outreach events and fielding export-related questions from 
small businesses directed to the District Office. 

SBA Provides Export Promotion Assistance to Small Businesses within a 
Complex, Multiagency Environment: 

SBA's increased activities in promoting small business exports take 
place within a complex, multiagency environment. The responsibility to 
provide export assistance to small businesses is shared by six key 
federal agencies, which engage in four major activities to promote 
small business exports. The NEI identifies these primary activities 
for U.S. agencies involved in small business promotion, which we 
classify under four general terms: 

* Outreach: Identify small businesses that can begin or expand 
exporting: 

* Counseling and Training: Prepare small businesses to export 
successfully: 

* Trade Leads: Connect small businesses to export opportunities: 

* Financing: Support small businesses once they have export 
opportunities: 

These activities are dispersed across the six key agencies, as shown 
in table 3 and explained in further detail below. All six of the key 
federal agencies and their partner entities that support small 
business exporting participate in outreach and education to help 
prepare small businesses to export successfully. Additionally, each 
agency and partner entity engages in at least one other primary 
activity to assist small businesses with exporting. In addition to 
conducting outreach, SBA provides counseling and training, primarily 
through SBDCs, and assists small businesses with export financing 
through OIT. 

Table 3: U.S. Agencies' Activities to Support Small Business Exports: 

Agency or partner entity: SBA; 
Outreach: [Empty]; 
Counseling and training: [Empty]; 
Trade leads: [Empty]; 
Financing: [Empty]. 

Agency or partner entity: OIT[A]; 
Outreach: [Check]; 
Counseling and training: [Empty]; 
Trade leads: [Empty]; 
Financing: [Check]. 

Agency or partner entity: SBDC; 
Outreach: [Check]; 
Counseling and training: [Check]; 
Trade leads: [Empty]; 
Financing: [Empty]. 

Agency or partner entity: Commerce; 
Outreach: [Check]; 
Counseling and training: [Check]; 
Trade leads: [Check]; 
Financing: [Empty]. 

Agency or partner entity: Ex-Im[A]; 
Outreach: [Check]; 
Counseling and training: [Empty]; 
Trade leads: [Empty]; 
Financing: [Check]. 

Agency or partner entity: USDA; 
Outreach: [Check]; 
Counseling and training: [Check]; 
Trade leads: [Check]; 
Financing: [Check]. 

Agency or partner entity: USTDA; 
Outreach: [Check]; 
Counseling and training: [Empty]; 
Trade leads: [Check]; 
Financing: [Check]. 

Agency or partner entity: State Department; 
Outreach: [Check]; 
Counseling and training: [Empty]; 
Trade leads: [Check]; 
Financing: [Empty]. 

Source: GAO analysis of agency documents. 

[A] Both OIT and Ex-Im provide counseling and training to lenders and 
small businesses on federal export finance products. However, for the 
purposes of this report, we considered the counseling and training 
provided by OIT and Ex-Im to be a part of both agencies' provision of 
financing assistance to exporters, rather than an independent service 
like the counseling and training provided by Commerce, SBDCs, and USDA. 

[End of table] 

Outreach: 

All six of the federal agencies that support small business exports 
conduct outreach, which can include any activity in which agencies 
seek to inform small businesses or other partners, such as lenders, 
about the export promotion services offered by the federal government. 
For this reason, outreach can be difficult to separate from other 
activities that are part of the agencies' export promotion effort. For 
example, a Commerce trade specialist could attend a trade show to meet 
with and counsel a number of existing clients, but there she would 
also have the opportunity to meet with small businesses to identify 
potential clients interested in exporting. As another example, 
seminars and training sessions, which may be useful for existing 
exporters or other clients seeking to improve their operations, can 
also serve an outreach function because they often help introduce 
small businesses to exporting and help them identify whether they are 
ready to begin exporting. 

Another important outreach tool for export assistance agencies is the 
Export.gov portal. Designed as a "one-stop shop" for companies 
interested in exporting, Export.gov provides content from multiple 
TPCC agencies in a single website. In September 2010, Commerce, 
working with other agencies, revamped the portal to include two new 
service channels, named "Begin Exporting" and "Expand Your Exports," 
that are designed to provide tailored information based on whether or 
not a company currently exports. Companies can use Export.gov to find 
webinars or in-person training or to find local resources that can 
help with export counseling or financing. Commerce intends to roll out 
a new version of Export.gov that allows for more tailored targeting of 
information in January 2013. 

Counseling and Training: 

SBA (through SBDCs), Commerce, and USDA all provide one-on-one 
counseling services to small businesses. Counseling is specific to the 
needs of each business and can cover a variety of topics relating to 
international trade and exporting, such as helping a business identify 
a target export market or discussing logistics for shipping exported 
goods. USDA's services, many of which are delivered through nonfederal 
partner entities called State Regional Trade Groups, are targeted 
specifically at businesses that export agricultural products.[Footnote 
11] Both Commerce and SBDCs offer counseling to businesses of all 
types. 

As we have previously reported, export promotion counseling is often 
labor intensive and time consuming because agency staff must spend a 
significant amount of time working with a company before it is able to 
successfully export.[Footnote 12] In particular, it can take a long 
time to prepare a company for exporting if it has never exported 
before. According to Commerce estimates, it can take 2 years or more 
from the time a company new to exporting begins to receive assistance 
until that business can make a successful export sale. Even companies 
with experience exporting may require over a year of preparation 
before being able to expand into a new market. 

Commerce and SBDCs both also conduct training on a variety of issues 
relating to exporting, such as navigating international logistics. 
Commerce and SBDCs often coordinate with one another, and other 
agencies often participate in their training sessions. While the 
agencies' courses may cover similar content, officials in Portland, 
Oregon, noted that some features of the courses may appeal to 
different audiences with different needs. For example, Commerce 
officials noted that Portland's SBDC offers intensive export training 
through a 10-session course that takes place over 10 months. On the 
other hand, Commerce and the area's District Export Council offer an 
Export University course that is specifically designed as a 1-day 
course. 

Trade Leads: 

While SBA typically does not provide much assistance with trade leads--
connecting small businesses with overseas buyers--a few of the SBDC 
counselors we met with said they sometimes try to help clients 
identify specific opportunities with overseas partners. Additionally, 
about 3 years ago, OIT started a matchmaker program in which OIT hosts 
or co-sponsors events. The matchmaker events are designed to help 
small businesses interested in exporting meet with export management 
companies, which are intermediaries that represent a company's product 
overseas and reduce some of the risks associated with exporting by 
managing the logistics of the process. Unlike programs sponsored by 
other U.S. agencies, SBA does not directly connect companies with 
potential buyers through this matchmaking program. However, OIT's 
matchmaking events could potentially result in more trade leads for 
small businesses because export management companies may be able to 
help identify foreign buyers. 

Other agencies connect clients with trade leads in a variety of ways. 
For example, USDA's Market Access Program provides funding that helps 
businesses attend trade shows, where they have opportunities to meet 
directly with potential buyers. Commerce leverages its international 
network of Commercial Officers to help U.S. businesses set up 
appointments with potential buyers abroad and to notify businesses 
when foreign buyers are looking to import U.S. goods. State Foreign 
Service Officers sometimes serve a similar role at overseas posts 
where Commerce does not have a presence. USTDA helps businesses 
identify export opportunities by providing financial assistance 
through grant and contract opportunities for U.S. businesses to 
conduct feasibility studies, pilot projects, and technical assistance, 
as well as hosting reverse trade missions, in which USTDA brings 
foreign buyers to the U.S. to help connect them with U.S. companies, 
both large and small.[Footnote 13] 

Financing: 

SBA, Ex-Im, and USDA offer various forms of financing assistance to 
small businesses, as outlined in table 4. SBA and Ex-Im both offer 
loan guarantees, which help businesses secure financing from private 
lenders, for working capital loans. Working capital loans may be used 
by businesses to finance activities that will help complete export 
sales. For example, a business might use a working capital loan to buy 
raw materials that it will use in manufacturing goods for export. SBA 
also offers guarantees on facilities development loans, which can be 
used to acquire or upgrade facilities and equipment used to produce 
goods or services involved in international trade. USDA offers loan 
guarantees to facilitate international sales of U.S. agricultural 
products, and Ex-Im provides direct loans to international buyers of 
U.S. exports, both of which allow U.S. companies to secure export 
orders and may result in larger orders. Ex-Im also offers insurance on 
export sales. 

Table 4: Export Financing Assistance Programs Available to Small 
Businesses, by Federal Agency: 

Agency: SBA; 
Working capital financing: [Check]; 
Facilities development financing: [Check]; 
Financing for international buyers: [Empty]; 
Export insurance: [Empty]; 
Grant and contract opportunities: [Empty]. 

Agency: Ex-Im; 
Working capital financing: [Check]; 
Facilities development financing: [Empty]; 
Financing for international buyers: [Check]; 
Export insurance: [Check]; 
Grant and contract opportunities: [Empty]. 

Agency: USDA; 
Working capital financing: [Empty]; 
Facilities development financing: [Empty]; 
Financing for international buyers: [Check]; 
Export insurance: [Empty]; 
Grant and contract opportunities: [Empty]. 

Agency: USTDA; 
Working capital financing: [Empty]; 
Facilities development financing: [Empty]; 
Financing for international buyers: [Empty]; 
Export insurance: [Empty]; 
Grant and contract opportunities: [Check]. 

Source: GAO analysis of agency documents. 

Note: The Overseas Private Investment Corporation, which is outside of 
the scope of our review, provides financing assistance and insurance on 
direct foreign investments. 

[End of table] 

SBA and Ex-Im both have finance specialists in domestic field offices 
who provide one-on-one technical assistance on export financing to 
small businesses and lenders. For example, they may counsel small 
businesses about different options for financing export sales. 

Agencies that provide loan guarantees and export-credit insurance have 
a financial impact that can far exceed their budget. Total SBA and Ex-
Im financing for small businesses has increased in recent years, from 
just over $5 billion in fiscal year 2009 to nearly $7 billion in 
fiscal year 2011.[Footnote 14] In fiscal year 2011, Ex-Im approved 
3,247 small business transactions, while SBA approved 1,547 small 
business loan guarantees. The majority of Ex-Im transactions, or over 
2,600 transactions worth approximately $3.3 billion, were for export-
credit insurance, while all SBA financing is for loan guarantees. 

SBA Has Taken Steps to Collaborate with Other Agencies, but Further 
Collaboration Efforts Are Needed: 

SBA, Commerce, and Ex-Im collaborate on some export promotion 
activities in headquarters and at field locations, but some services 
overlap, which can be confusing for small businesses and may not be an 
optimal use of resources. Some SBDCs and Commerce staff offer similar 
counseling services, and SBA and Ex-Im offer similar financial 
products to small businesses. SBA has collaborated with other agencies 
to develop a joint strategy for increasing small business exports and 
to include collaborative efforts in performance evaluations. However, 
SBA and other agencies have not clearly defined agencies' roles and 
responsibilities for export promotion, nor have they fully leveraged 
resources such as by regularly sharing client information, where 
possible. 

Overlapping Export Assistance from SBA and Other Agencies Can Be 
Confusing for Small Businesses and May Lead to Inefficient Use of 
Resources: 

SBA export assistance efforts overlap with those of other agencies, 
primarily with the export counseling offered by Commerce and export 
financing products offered by Ex-Im; this overlap can create confusion 
for small businesses seeking export assistance. Overlap occurs when 
federal agencies have similar goals, engage in similar activities to 
achieve them, and target similar beneficiaries. When agencies provide 
overlapping services to the same clients, there are potential resource 
inefficiencies, and agencies could potentially focus their resources 
and strengths to better target clients and address identified needs. 

SBA's SBDCs and Commerce both provide one-on-one export counseling to 
small businesses that are new to exporting or currently exporting. 
Export counseling is tailored to the needs of each company, so the 
issues covered vary by client, but SBDCs and Commerce may cover 
similar issues. For example, both offer strategic advice to help 
companies identify target markets for exporting, assist companies in 
understanding and ensuring they are compliant with exporting 
regulations, and develop seminars to teach small businesses about the 
fundamentals of exporting. Not all services provided by SBDCs and 
Commerce overlap. For example, SBDCs help companies develop business 
plans or conduct financial analysis, services that Commerce does not 
provide. Commerce also leverages its overseas offices to provide more 
in-depth fee-based services such as its Gold Key service, which 
incorporates market research, in-person counseling, and personalized 
appointments with potential partners overseas. 

SBA and Ex-Im offer similar export financing products to small 
businesses, which are delivered through some of the same lending 
institutions. SBA and Ex-Im export working capital loan programs have 
many similar features, as shown in table 5. SBA and Ex-Im officials 
noted, however, that each program has limitations for eligibility, so 
companies may be able to use only one agency's product. For example, 
Ex-Im generally requires that more than 50 percent of the content of 
an exportable good guaranteed through its Working Capital Guarantee 
Program originate in the United States. SBA's Export Working Capital 
Program has no similar content requirement, so companies using foreign 
materials may prefer SBA loan guarantees. On the other hand, SBA can 
only guarantee a maximum loan of $5 million, so companies seeking 
larger loan guarantees may prefer Ex-Im. Additionally, since both 
products are loan guarantees, customers must still receive the actual 
loan through a private lender. 

Table 5: Selected Features and Limitations of SBA and Ex-Im Working 
Capital Loan Guarantees: 

Program features and limitations: Product; 
SBA Export Working Capital Program: Loan guarantee; 
Ex-Im Working Capital Guarantee Program: Loan guarantee. 

Program features and limitations: Type; 
SBA Export Working Capital Program: Single order or revolving line of 
credit; allows for advances against purchase orders; 
Ex-Im Working Capital Guarantee Program: Single order or revolving 
line of credit. 

Program features and limitations: Eligibility; 
SBA Export Working Capital Program: Small business operating for at 
least 1 year (can be waived based on management experience); 
Ex-Im Working Capital Guarantee Program: Business of any size 
operating for at least 1 year (can be waived based on management 
experience); Must meet certain financial requirements, including 
having positive net worth and meeting minimum standards on certain key 
industry ratios. 

Program features and limitations: Collateral; 
SBA Export Working Capital Program: Export-related inventory and 
accounts receivable from export sales; Personal or corporate guarantee 
of the owner; 
Ex-Im Working Capital Guarantee Program: Export-related inventory and 
accounts receivable from export sales; Personal or corporate guarantee 
of the owner. 

Program features and limitations: Content requirements; 
SBA Export Working Capital Program: None; 
Ex-Im Working Capital Guarantee Program: Must contain more than 50% 
U.S. content; Cannot be used to finance military or defense articles 
or services, with limited exceptions. 

Program features and limitations: Loan percentage guaranteed; 
SBA Export Working Capital Program: Up to 90%; 
Ex-Im Working Capital Guarantee Program: Up to 90%. 

Program features and limitations: Loan amount guaranteed; 
SBA Export Working Capital Program: $5 million; 
Ex-Im Working Capital Guarantee Program: No limit. 

Source: GAO analysis of Department of Treasury, SBA, and Ex-Im 
documents. 

[End of table] 

SBA and Ex-Im officials in the field noted that the agencies' express 
loan programs also share some similarities. In 2012, Ex-Im introduced 
its Global Credit Express program as a pilot, which is designed to 
provide a relatively fast infusion of capital to small business 
exporters and is similar to SBA's Export Express program, as outlined 
in table 6. Ex-Im's Global Credit Express program is still smaller in 
terms of volume--according to an Ex-Im official, it had resulted in 
fewer than 10 loans as of November 2012--and some details of the 
program are evolving, such as the options for lending institutions to 
refer clients to Ex-Im. However, both products are available for a 
variety of business activities that will support a company's export 
development. In addition to Ex-Im's restrictions regarding U.S. 
content of exported goods, one major difference between the two 
products is that SBA's Export Express is a guarantee for a loan 
provided by a private lender, while Ex-Im's Global Credit Express is a 
direct loan from Ex-Im to a small business. Ex-Im officials also noted 
that Ex-Im charges significantly higher fees for Global Credit Express 
than SBA does for Export Express to ensure the programs do not 
compete. Additionally, SBA officials noted that there are substantial 
differences in the duration of each loan, with the Export Express 
program offering either a revolving line of credit with a maturity of 
up to 7 years or a term loan with a maturity of up to 25 years, while 
Global Credit Express has a maturity of up to 1 year. 

Table 6: Select Features and Limitations of SBA and Ex-Im Express Loan 
Programs: 

Program features and limitations: Product; 
SBA Export Express: Loan guarantee; 
Ex-Im Global Credit Express: Direct loan from Ex-Im. 

Program features and limitations: Content requirements; 
SBA Export Express: None; 
Ex-Im Global Credit Express: Must contain more than 50% 
U.S. content; Cannot be used to military or finance defense articles or 
services, with limited exceptions. 

Program features and limitations: Loan limit; 
SBA Export Express: $500,000; 
Ex-Im Global Credit Express: $500,000. 

Program features and limitations: Eligibility; 
SBA Export Express: Small business operating for at least 12 months; 
Ex-Im Global Credit Express: Small business operating for at least 3 
years and exporting for at least 1 year. 

Program features and limitations: Response time; 
SBA Export Express: Within 36 hours; 
Ex-Im Global Credit Express: About 5 days. 

Source: GAO analysis of SBA and Ex-Im documents. 

[End of table] 

Overlapping services can be confusing for small businesses and may 
result in an inefficient use of government resources. Both agency 
officials and private sector representatives said overlapping services 
can make navigating the federal export assistance system difficult. 
According to SBA, SBDC, Commerce, and Ex-Im officials, small 
businesses typically do not know which services each agency provides 
or where to go for assistance. Private sector representatives agreed 
it is challenging for small businesses seeking export assistance to 
determine which federal entity would best serve their needs. They 
noted, for example, that export financing assistance is very important 
for small businesses to be competitive in international markets, but 
it can be difficult to understand the differences between federal loan 
programs for financing exports. Additionally, as we have noted in the 
past, overlapping federal efforts can result in an inefficient use of 
government resources.[Footnote 15] By addressing such inefficiencies, 
agencies could more effectively target government resources toward 
accomplishing the NEI goal. 

SBA and Other Agencies Follow Some Best Practices in Collaboration but 
Could Take Further Actions to Reduce Overlap: 

In prior work, we identified practices that can help enhance and 
sustain collaboration among federal agencies and thereby maximize 
performance and results, and we have recommended that agencies follow 
them.[Footnote 16] These collaborative practices include among them 
establishing joint strategies, reinforcing individual accountability 
for collaborative efforts, determining roles and responsibilities, and 
leveraging resources, as described in table 7.[Footnote 17] 

Table 7: Best Practices in Collaboration: 

Establish mutually reinforcing or joint strategies: 
Design individual but mutually reinforcing strategies or a joint 
strategy to help align activities, core processes, and resources to 
achieve a common outcome. 

Reinforce individual accountability for collaborative efforts: 
Design performance management systems that emphasize and set 
performance expectations for collaboration. 

Establish mutually reinforcing or joint strategies: 
Design individual but mutually reinforcing strategies or a joint 
strategy to help align activities, core processes, and resources to 
achieve a common outcome. 

Agree on roles and responsibilities: 
Define and agree on respective roles and responsibilities, including 
how the collaborative efforts will be led. In doing so, agencies can 
clarify who will do what, organize their joint and individual efforts, 
and facilitate decision making. 

Establish mutually reinforcing or joint strategies: 
Design individual but mutually reinforcing strategies or a joint 
strategy to help align activities, core processes, and resources to 
achieve a common outcome. 

Leverage resources to identify and address needs: 
Leverage resources, such as human, information technology, physical, 
and financial resources, to support the common outcome. 

Source: GAO-06-15. 

[End of table] 

SBA and Other Agencies Have Developed a Joint Export Strategy for 
Achieving NEI's Goal: 

SBA and other agencies have developed a joint annual strategy at the 
headquarters level to work collaboratively toward the NEI goal of 
doubling U.S. exports by the end of 2014. The 2011 National Export 
Strategy (Strategy), drafted by SBA, Commerce, Ex-Im, and other TPCC 
agencies, was the first time that the agencies developed common 
metrics for measuring the federal government's export-promotion and 
trade-access impacts as a whole, rather than highlighting individual 
agencies' successes. Joint performance measures include the number of 
small business exporters assisted by U.S. government finance programs, 
the value of exports supported by counseling, and the value of exports 
supported by financing assistance.[Footnote 18] The Strategy also 
discusses progress with regard to NEI priorities, including exports by 
small businesses and other areas such as trade access. While the 
Strategy does not identify areas of overlap in export promotion 
services across agencies, it distinguishes the different types of 
expertise and assistance needed by small businesses that have never 
exported (new-to-export) compared with those that have exporting 
experience and are expanding into new markets (new-to-market). The 
Strategy also notes efforts by SBA to track data on new-to-export 
companies and a Commerce initiative to target new-to-market companies. 
SBA also has agency-wide and OIT-specific plans that address agency 
goals. Both plans are generally consistent with the NEI goal. 

While the Strategy was created at the headquarters level, much of its 
implementation takes place in the field. The NEI created an 
overarching goal for the different trade agencies and guides the 
Strategy, but agency officials at the headquarters and field levels 
differed in their views about the NEI's impact on collaboration. SBA 
and other agency officials at the headquarters level noted 
improvements in collaboration as result of the NEI, such as 
interagency communication and coordination of events, which are 
discussed in the Strategy. However, SBA staff and other agency staff 
we interviewed in some field locations noted that while the NEI has 
increased public awareness of federal export assistance activities, it 
has had limited effect on the extent to which the agencies 
collaborate. In its report that reviewed coordination among USEACs and 
federal and nonfederal partners with respect to NEI priorities, the 
Commerce Office of the Inspector General similarly noted that Commerce 
actions to implement the NEI have had a limited effect on the extent 
and quality of collaboration with such partners.[Footnote 19] 

SBA and Other Agencies Generally Include Collaboration Efforts in 
Staff's Performance Evaluations: 

SBA and other agencies have taken steps to implement the best practice 
of including collaborative efforts in performance evaluations of 
export assistance staff; however, the export promotion assistance 
entities vary in how they include collaboration efforts in their 
performance standards and measures. For example, OIT performance 
standards include staff's participation in activities and events in 
conjunction with other export agencies. OIT officials also noted that 
beginning in fiscal year 2013, they will track the number of export 
credit insurance referrals made by OIT staff to Ex-Im staff. SBDCs' 
performance measures focus on the clients and jobs for which SBDC 
staff provide assistance, but officials told us that SBA is beginning 
to track SBDCs' collaborative efforts with other agencies. While 
Commerce staff's performance evaluations note services provided by 
partner agencies, Commerce field staff told us that generally the key 
incentive for Commerce staff is to conduct services that help 
facilitate an export sale. Ex-Im's performance metrics encourage 
collaboration because they allow for staff to count financial 
referrals to other agencies toward their own performance goals. An Ex-
Im official noted that if an Ex-Im employee determines that an SBA 
financial product is more appropriate for a client and the referral 
results in a completed transaction, the Ex-Im staff may choose to 
count the sale of the SBA product toward individual performance goals. 
The NEI states that agencies should use such incentives to encourage 
employees to direct companies to the best option for financing even if 
the company is sent to another agency. 

Agencies Have Not Clarified Their Roles and Responsibilities for 
Export Promotion: 

SBA and other agencies have not developed guidance on roles and 
responsibilities to address overlapping counseling and financing 
functions. To implement this best practice in collaboration more 
effectively, SBA and other agencies providing similar export 
assistance to small businesses could clarify which export agency will 
serve certain export functions or types of clients. Officials of SBA 
and the other agencies have not formalized a process for determining 
how to direct clients with differing needs and levels of exporting 
experience to the most appropriate agency.[Footnote 20] 

First, SBA and Commerce have not clearly defined each agency's role in 
counseling small business exporters. SBDC and Commerce officials we 
spoke with indicated that they try to limit overlap by focusing on the 
areas where each entity has relatively more experience. Headquarters 
SBA and Commerce staff stated that SBDC counselors are expected to 
work with new-to-export companies while Commerce trade specialists 
should focus on new-to-market companies. According to Commerce 
officials, Commerce prefers to work with new-to-market businesses or 
businesses looking to export more in a market where they already 
export because those businesses can quickly take advantage of 
Commerce's extensive services and overseas resources. Commerce field 
staff are supposed to refer new-to-export businesses to SBDCs, where 
these businesses may benefit from an array of general business 
development services. According to Commerce officials, when Commerce 
staff focus on new-to-market businesses and send new-to-export 
businesses to SBDCs, the result is a more efficient use of Commerce 
resources than if Commerce staff were to focus on counseling new-to-
export businesses. 

While some SBA and Commerce officials explained the division of 
responsibilities for assisting new-to-export versus new-to-market 
businesses, we found that the division of responsibilities between the 
SBDCs and Commerce is not clearly defined in practice. Moreover, the 
agencies have not developed guidance that outlines a common 
understanding about where clients should be directed based on their 
export readiness.[Footnote 21] SBDC and Commerce field staff indicated 
that interagency roles and responsibilities for counseling new-to-
export and new-to-market companies are unclear. SBDC and Commerce 
staff at all six field locations we visited said that they counsel 
both new-to-export and new-to-market businesses, and that both 
agencies at their location may provide the same type of counseling. 
For example, sometimes both SBDCs and Commerce specialists at some 
locations provide market research for clients. 

SBDC and Commerce staff in some locations also noted that they may 
counsel the same client, but they do not regularly discuss with one 
another what services they provide to clients, nor do they regularly 
share client information. Some Commerce field staff also said that 
they had little interaction with their SBDC counterparts. 
Additionally, some Commerce field staff said that they continue to 
work with new-to-export clients that could help them meet their 
individual performance targets for export successes. SBA and Commerce 
officials informed us that they had not developed formal agency or 
interagency guidance that directed SBDC counselors and Commerce staff 
to primarily counsel one type of client. 

Second, SBA and Ex-Im have similar roles and responsibilities for 
similar financial products for small businesses. According to SBA and 
Ex-Im, the overlap in their financial products results from both 
agencies' efforts to respond to lender preferences. Ex-Im officials 
said that many lenders prefer to work with only one agency and very 
few lenders use both agencies' products, so clients may only be able 
to access one agency's products through their regular bank. SBA 
designates Preferred Lenders for its Export Working Capital loan 
guarantee with authority to process these loans without prior SBA 
review, and the SBJA has a provision that makes lenders participating 
in Ex-Im's similar Delegated Authority Program eligible to participate 
in SBA's Preferred Lenders program. However, both SBA and Ex-Im field 
staff noted that lenders primarily prefer to work with only SBA or Ex-
Im, due to the time and expertise needed to learn each agency's 
complex requirements and to process each agency's products. If a 
potential export financing client only meets the eligibility 
requirements for one agency's product and the client's lender does not 
work with that agency, the client would need to find a new lender to 
receive the agency's loan guarantee. SBA and Ex-Im may be able to 
explore options to better align export financing products and to 
assist lenders in more easily adapting to the rules for both SBA and 
Ex-Im products. 

Third, the roles and responsibilities of SBA's 68 District Offices and 
their relationship to other export promotion entities have also been 
unclear and are in transition. The Strategy envisioned that District 
International Trade Officers would lead Export Outreach Teams that 
would coordinate activities with Commerce at the local level. SBA 
officials noted that this had not happened because these district 
officers are still learning their responsibilities in assisting 
exporters, and their role is still evolving. Furthermore, some 
Commerce staff expressed uncertainty about the roles and 
responsibilities of the designated District International Trade 
Officers and had little or no interaction with them. We found the 
level of export promotion activities carried out by SBA district 
offices varied widely. For example, one District International Trade 
Officer with substantial personal experience with export-related 
issues was heavily involved in a wide variety of activities, including 
organizing events and providing one-on-one counseling to businesses 
interested in exporting. In contrast, other District International 
Trade Officers said that they had little or no experience with 
exporting and that their export-related activities are limited to 
serving as a point of contact within the district office and referring 
businesses to the appropriate federal entity. 

SBA and Other Agencies Leverage Some Resources but Do Not Regularly 
Share Client Information, Where Possible: 

While SBA and other agencies take some steps to leverage interagency 
resources both in headquarters and in the field, they do not regularly 
share client information, where possible, which may result in less 
effective client services. One best practice in collaboration 
emphasizes that agencies should leverage resources--such as human, 
information technology, physical, and financial resources--to support 
the common outcome established by the agencies' joint strategy. 

At the headquarters level, we found several instances showing that SBA 
and other agencies have taken steps to effectively leverage one 
another's export-promotion resources, as the following examples 
illustrate: 

* OIT chairs the TPCC's Small Business Working Group, which 
coordinates interagency cooperation on small business export promotion 
as part of the NEI. Agencies discuss coordination of small business 
exporting issues through this working group, including the issue of 
streamlining initial client intake across agencies to help agencies 
provide more targeted assistance to companies. 

* Agencies have also produced interagency outreach materials on 
federal export financing services through this working group. For 
example, the working group distributed a brochure on export financing 
and foreign investment finance programs available through SBA, Ex-Im, 
and USTDA. 

* SBA and Commerce staff in headquarters coordinate client intake 
through the Export.gov website and are working to enhance the site to 
help companies obtain more targeted assistance from agencies. 

Currently, registrants of Export.gov self-identify their export 
readiness; a Commerce staff downloads registrants' information from 
Export.gov and sends the information from new-to-export companies to 
OIT in SBA headquarters and directs new-to-market companies to 
Export.gov resources. Commerce and SBA officials told us they are 
working together to develop a new version of Export.gov, expected to 
be completed by January 2013, that is intended to improve upon the 
current design to better direct registrants to the appropriate export 
promotion entity and nearest geographical locations. These officials 
told us that the new version of Export.gov will ask the registrant a 
series of questions to determine the company's extent of business 
development and export readiness, and direct the company to the 
agencies or entities that could best assist it. 

At the field level, SBA and other agencies leverage resources by 
conducting joint outreach and training events. At all six locations we 
visited, SBA and other agencies invite one another to various events, 
including trade shows, road shows, and training events that inform 
small businesses about available federal services. For example, in one 
location, staff told us that at trade show events, SBA, SBDCs, 
Commerce, and Ex-Im may conduct joint seminars, where Commerce staff 
could discuss marketing and sales, while SBA and Ex-Im staff discuss 
financing. In another location, Ex-Im staff said they may include 
partners such as SBDCs in road shows they conduct. 

Although we found that SBA and other agencies leverage interagency 
resources to some extent both in headquarters and in the field, we 
also found that SBA and other agencies could better leverage resources 
by sharing client information more consistently. In 2010, the Export 
Promotion Cabinet recommended strengthening interagency information 
sharing and coordination to implement the NEI. The extent to which SBA 
and other agencies share exporters' information on a regular basis 
varies. Commerce and Ex-Im have an informal agreement to share 
nonbusiness confidential client information on a quarterly basis. 
Commerce shares the name and contact information for clients that have 
purchased certain Commerce products, such as a Gold Key Service, and 
successfully exported.[Footnote 22] Ex-Im shares a list of new export 
credit insurance clients with Commerce but does not include client 
contact information. By contrast, SBDC counselors generally cannot 
share specific client information with other entities unless they 
receive permission from the client,[Footnote 23] and OIT does not 
regularly share its client list with SBDCs, Commerce, or Ex-Im, nor 
does it regularly receive client lists from other entities. OIT 
officials noted that currently, OIT field staff may share information 
about clients with other agencies informally, such as by engaging in 
joint client phone calls with other agencies' staff at the USEACs. 
Agency officials noted that information sharing is limited by certain 
privacy restrictions. SBA and other agencies' officials told us they 
are currently reviewing the types of information that they could share 
with each other. 

Some SBA, SBDC, Commerce, and Ex-Im staff in the locations we visited 
told us that obtaining access to agencies' client information would be 
beneficial. For example, such access could help increase their own 
clientele base and potentially provide small businesses with 
assistance in their area of expertise, as well as track the status of 
clients in the export life cycle. Commerce staff in headquarters and 
the field also noted that access to OIT client lists could improve 
Commerce's ability to report export successes, thereby helping 
Commerce track their impact in helping increase small business exports. 

SBA Has Made Some Progress in Increasing Export Training but 
Experienced Challenges in Meeting Staffing Requirements under the 
Small Business Jobs Act of 2010: 

The SBJA expanded SBA's presence in providing export assistance to 
small businesses, by requiring an increase in the export training of 
SBDC staff and an increase in the number of OIT field staff.[Footnote 
24] SBA has made progress in certifying SBDC staff by SBA's own 
established target date. However, SBA did not meet the OIT field staff 
levels within the deadline set by the SBJA, citing hiring and funding 
challenges. SBA's most recent plan to increase OIT field staff does 
not provide funding information for the new positions and updated time 
frames for filling them. 

Small Business Jobs Act of 2010 Expanded SBA Training and Staffing 
Requirements for Export Promotion Activities: 

According to SBA, the SBJA is the most significant piece of small 
business legislation in over a decade because it provides resources to 
help small businesses continue to drive economic recovery and create 
jobs. Among other changes, the SBJA increased the maximum size of 
SBA's export loan and loan guarantee amounts and elevated the 
importance of OIT within SBA by making it an independent office. 
[Footnote 25] In supporting NEI goals, the law also increased SBA's 
staff to provide additional export counseling resources to promote 
small business exporting.[Footnote 26] 

The SBJA included the following requirements for SBA with regard to 
export promotion staffing and training: 

Small Business Development Centers training/certification. At 63 lead 
SBDCs,[Footnote 27] SBJA required that five staff or 10 percent of 
staff, whichever is less, obtain certification in providing export 
assistance.[Footnote 28] SBA provides that certification can be 
obtained through an exam or a specific professional certification 
program: 

Office of International Trade field staff levels. SBJA required that 
by December 27, 2010, the number of OIT export financial specialists 
at USEACs would be at least the same as the number of these staff in 
2003, which was 22, according to SBA.[Footnote 29] The law required 
that there should be at least 3 of these OIT staff in each of the 10 
SBA regions by September 27, 2012, which would require a minimum of 30 
staff at USEACs nationwide.[Footnote 30] In addition, SBJA stipulated 
that SBA should place priority in certain locations and then 
strategically assign staff to the USEACs based upon the needs of 
exporters.[Footnote 31] 

SBA Has Made Progress in Certifying Small Business Development Center 
Staff to Increase Expertise in Export Counseling: 

The export and trade certification program for SBDC staff is intended 
to greatly expand the number of qualified small business counselors 
available to help small businesses to engage in international trade 
and to provide consistency in the quality of assistance across the 
SBDC networks. In interpreting the SBJA requirement for certifying 
staff at the 63 lead SBDCs, SBA determined that the certification 
standard would be based on the total number of staff in each of the 63 
SBDC networks and not merely on the number of staff at the lead SBDCs. 
The certification program would encompass staff at any of the over 900 
SBDCs that provide services to small businesses. According to SBA, 
this interpretation of the certification requirement helps ensure that 
all of the 63 SBDC networks have a minimum number of qualified 
counseling and training staff available to provide export and trade 
assistance to their small business clients. Although the SBJA did not 
specify a time frame to meet this requirement, SBA established its own 
agency policy to complete the certification requirement by December 
31, 2013.[Footnote 32] 

SBA provided two options for SBDC staff to obtain certification: (1) 
staff could take and pass an online competency test administered by 
SBA, or (2) staff could obtain certification in the National 
Association of Small Business International Trade Educators' Certified 
Global Business Professional program.[Footnote 33] SBA collaborated 
with the TPCC to develop an export education program that offers 
education in basic concepts, key international trade assistance 
resources, and key aspects of global trade to help small business 
counselors prepare for the SBA test. As of the end of September 2012, 
73 percent of the SBDC networks (46 of 63) had met the certification 
requirement.[Footnote 34] SBA noted that the certification requirement 
was intended to achieve one of the key goals of the SBJA--to improve 
the quality of international trade counseling and training received by 
businesses through the SBDC network. During our fieldwork, we found 
that SBDC staffs' knowledge and experience with international trade 
varied across some locations. Some SBDCs were focused primarily on 
international trade.[Footnote 35] Some SBDC staff had prior export 
experience that was helpful in providing export counseling to small 
businesses, according to these officials, while others had less 
experience and acknowledged the need for additional training. Field 
staff at the locations we visited informed us that they had either 
obtained or were in the process of obtaining certification. 

SBA's Efforts to Add OIT Field Staff Have Fallen Short of 
Requirements, and Its Staffing Plan Lacks Key Information: 

The SBJA directed OIT to increase field staff in two phases, and to 
distribute staff regionally. In an attempt to meet the SBJA 
requirement of increasing its OIT field staff levels from 18 to 22 at 
USEACs by the end of 2011, SBA advertised 4 temporary positions in 4 
specific locations but filled only 2 positions by June 2011 using SBJA 
funding that expired on September 30, 2012. The 4 locations were based 
on SBA's analysis of locations that lacked OIT staff since 2003 and 
had exporters with the greatest needs. With the expiration of the SBJA 
funding, SBA stopped advertising the remaining 2 positions left 
unfilled. Although SBA needed to increase its field presence to 30 OIT 
staff by September 27, 2012, SBA had not hired any more than the 2 
additional OIT staff and had a total of 19 OIT staff in USEACs. 
[Footnote 36] Furthermore, despite the SBJA's requirement for 3 OIT 
staff to be placed in each of SBA's regions, there are currently only 
2 out of 10 SBA regions with 3 or more OIT staff, while the other 8 
regions do not have the required staff levels. See figure 1 for a map 
of the current number of SBA OIT staff by SBA region. 

Figure 1: Locations and Number of SBA OIT Staff by SBA Region, as of 
September 30, 2012: 

[Refer to PDF for image: illustrated U.S. map] 

Number and location of Small Business Administration (SBA) Office of 
International Trade (OIT) staff at U.S. Export Assistance Center 
(USEAC): 

Region: New England; 
Number of staff: 1; 
Location: Boston; 
States in region: 
Connecticut; 
Maine; 
Massachusetts; 
New Hampshire; 
Rhode Island; 
Vermont. 

Region: Atlantic; 
Number of staff: 1; 
Location: New York; 
States in region: 
New Jersey; 
New York; 
Puerto Rico; 
U.S. Virgin Islands. 

Region: Mid-Atlantic; 
Number of staff: 2; 
Location: Arlington, VA; Philadelphia; 
States in region: 
Delaware; 
District of Columbia; 
Maryland; 
Pennsylvania; 
Virginia; 
West Virginia. 

Region: Southeast; 
Number of staff: 3; 
Location: Atlanta, Charlotte, NC; Miami; 
States in region: 
Alabama; 
Florida; 
Georgia; 
Kentucky; 
Mississippi; 
North Carolina; 
South Carolina; 
Tennessee. 

Region: Great Lakes; 
Number of staff: 4; 
Location: Chicago; Cleveland; Detroit; Minneapolis; 
States in region: 
Illinois; 
Indiana; 
Michigan; 
Minnesota; 
Ohio; 
Wisconsin. 

Region: Great Plans; 
Number of staff: 1; 
Location: St. Louis; 
States in region: 
Iowa; 
Kansas; 
Missouri; 
Nebraska. 

Region: South Central; 
Number of staff: 2; 
Location: Ft. Worth; New Orleans; 
States in region: 
Arkansas; 
Louisiana; 
New Mexico; 
Oklahoma; 
Texas. 

Region: Rocky Mountain; 
Number of staff: 1; 
Location: Denver; 
States in region: 
Colorado; 
Montana; 
North Dakota; 
South Dakota; 
Utah; 
Wyoming. 

Region: Pacific; 
Number of staff: 2; 
Location: Irvine; Sacramento; 
States in region: 
Arizona; 
California; 
Guam; 
Hawaii; 
Nevada. 

Region: Pacific Northwest; 
Number of staff: 2; 
Location: Portland; Seattle; 
States in region: 
Alaska; 
Idaho; 
Oregon; 
Washington. 

Source: SBA data; Map Resources (map). 

Notes: Though OIT field staff serve in the USEACs shown, USEAC regions 
do not match up with the SBA District Office regions shown in the map. 
For example, SBA OIT staff in the Portland, Oregon, USEAC cover 
Montana. Montana is covered, however, by a different SBA District 
Office than the one serving Oregon. 

[End of figure] 

According to SBA officials, SBA encountered hiring challenges that 
hindered it from filling the four temporary, 13-month term positions 
it advertised. The main difficulties were that the positions offered 
were not permanent positions and required specialized trade finance 
expertise, which contributed to a shortage of qualified candidates. 
SBA officials said that there were no qualified applicants for the OIT 
position in one location and few interested and qualified candidates 
in the other locations. Applicants for the temporary OIT positions 
that SBA advertised were required to have 1 year of specialized 
experience to minimally qualify for the position. SBA also considered 
qualifications such as knowledge of SBA's trade finance programs; 
knowledge of advanced concepts, principles, and practices of 
international trade; and the ability to underwrite export trade 
finance transactions. 

Citing difficulties with finding qualified staff for the four 
advertised OIT positions, and not having continued funding to hire 
more staff, SBA never advertised for the additional eight OIT 
positions it would have had to fill, in addition to the original four, 
to meet the SBJA field staffing requirement. SBA officials noted that 
they still have the goal to hire additional OIT staff, and said they 
intend to implement the requirement to hire up to 30 OIT staff after 
fiscal year 2012, if SBA has sufficient funds available for that 
purpose. With the expiration of SBJA funding at the end of September 
2012, SBA officials told us that they no longer have the funding to 
hire additional OIT staff. SBA received $26.5 million in SBJA funds to 
implement SBJA requirements, according to SBA officials. Since OIT 
positions required by the SBJA were not filled, SBA used the funds to 
meet other SBJA requirements, such as hiring staff in offices other 
than OIT and, within OIT, hiring an Assistant Administrator and 
preparing export-related reports, both as required by the SBJA. 

SBA developed a plan to increase its OIT staff levels to 30 staff and 
proposed--in a report submitted to Congress in September 2012--to 
place the staff in specific USEACs. This proposed allocation of staff 
does not match the one specified in the SBJA requirement. While the 
SBJA required 3 OIT field staff in each of SBA's 10 regions, SBA's 
proposal for staff allocation was a minimum of 2 staff in some SBA 
regions and 5 staff in 1 region. SBA explained that its staffing 
allocation proposal reflected optimal distribution to support 
exporters' needs based on available full-year trade data from U.S. 
Census and Commerce. The SBA OIT field staffing plan noted that the 
underlying logic of its proposed allocation was that the more 
exporters there were within a state, the more opportunities SBA staff 
would have to directly interact with and assist them. 

SBA's plan lacks some critical updated information. The plan listed 
the proposed USEAC locations and the SBA regions where OIT staff would 
be located, as well as the number of SBA exporters and percentage of 
small business exporters in each of SBA's 10 regions. It also noted 
that the SBJA funding for the OIT positions would expire on September 
30, 2012, but did not discuss how SBA intended to fund the future new 
positions to meet the required staffing levels. Although the report 
was submitted to Congress only weeks before the SBJA deadline to meet 
OIT's staffing requirement, the plan also did not discuss revised 
targets for time frames, providing no information on when SBA expects 
to reach the level of OIT field presence required under the SBJA. 

Moreover, the plan explained SBA's difficulties in attracting 
qualified candidates, but the plan did not discuss how SBA would 
overcome the hiring challenges or discuss the potential for leveraging 
the resources of other export promotion entities that could provide 
similar export assistance as that provided by OIT staff. Some OIT 
staff told us that they are currently covering OIT work for a large 
geographic area. With the current OIT staff levels and locations, 
these staff have been meeting the needs of small businesses within 
their office's jurisdiction but outside the metropolitan areas where 
they are based. They said they can do this by traveling to attend 
outreach events and by relying on referrals from staff of other export 
promotion entities with offices in various locations outside the OIT-
served metropolitan areas. These other entities include Commerce, 
SBDC, or financial institutions that serve as lenders of SBA export 
loans. In light of the array of services provided by existing export 
assistance entities, SBA may be able to leverage other entities' 
resources in fine-tuning its plan for hiring additional OIT field 
staff to meet the SBJA requirements, provided that SBA and other 
agencies clarify their roles and responsibilities and begin to 
exchange information on a regular basis. 

Conclusions: 

SBA's increased responsibilities in the realm of export promotion have 
thrust it into an already crowded field of federal agencies providing 
small businesses with assistance. The challenges SBA now faces in 
limiting the extent to which its export promotion efforts overlap with 
those of other agencies highlight the need for SBA and other key 
export promotion agencies to further their collaboration efforts. SBA 
and the other agencies have collaborated on export promotion 
activities to some extent by developing strategies, conducting joint 
outreach events, and sharing some client information among agencies, 
but many challenges to effective collaboration remain. In particular, 
some of SBA's OIT and SBDC activities overlap with those of Ex-Im and 
Commerce, respectively. Without clear definition of each entity's 
roles and responsibilities, the overlapping export financing products 
offered by SBA and Ex-Im and the labor-intensive export counseling 
sessions provided by SBDCs and Commerce may cause confusion for small 
businesses and could result in duplication of efforts and inefficient 
use of government resources. Additionally, SBA and other federal 
agencies do not regularly or comprehensively share client information, 
which is a significant impediment to achieving effective interagency 
collaboration in providing export promotion assistance to small 
businesses. While some entities' staff told us that they are limited 
in their ability to share client information, additional information 
sharing, where possible, would help improve client services and help 
agencies better track their impact in promoting U.S. exports. 

SBA has had mixed results in meeting SBJA requirements expanding its 
export promotion presence. On the positive side, SBA is well on its 
way to ensuring that a sufficient number of SBDC staff are better 
trained and prepared to assist small business exporters. On the 
negative side, however, SBA has fallen short of meeting the law's 
specific requirements for increasing and placing OIT field staff, 
citing funding and hiring challenges. The most recent SBA report to 
Congress reiterates the agency's intention to hire all the additional 
OIT staff required by the SBJA. However, SBA's plan does not clearly 
identify the funding sources or time frames for hiring the additional 
staff, nor does it explain how it will address the hiring challenges 
it experienced previously. SBA needs to fill in those gaps in its OIT 
staffing plan, which presents an opportunity for the agency to step 
back and strategically reassess its plan and related resource 
allocation decisions in light of actions that could address the 
collaboration and information-sharing challenges identified in this 
report. 

Recommendations for Executive Action: 

We are recommending that the Administrator of the Small Business 
Administration take the following three actions: 

1. To help small businesses understand and get the most benefit from 
the various export assistance products and services provided by 
different federal entities, and to efficiently use government 
resources, consult with Commerce and Ex-Im and more clearly define 
roles and responsibilities of export promotion entities' export 
counseling and financing staff agencywide and at the local levels. 

2. To improve collaboration and leverage available resources, consult 
with Commerce and Ex-Im and identify ways to increase, where possible, 
sharing of client information deemed useful for SBA, Commerce, and Ex-
Im. 

2. To more effectively implement SBA's expansion of OIT field staff as 
required by the SBJA, update SBA's plan for additional OIT staff to 
include funding sources and time frames, as well as possible 
efficiencies from clearly defining roles and responsibilities and 
leveraging other entities' export assistance resources. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to SBA, Commerce, Ex-Im, USDA, 
USTDA, and State. In its written comments on the draft, which are 
reprinted in appendix II, SBA concurred with our recommendations and 
noted that SBA would work to implement the recommendations. We also 
received comments from Commerce stating that Commerce generally agreed 
with our findings and noting developments that had occurred since we 
provided them our draft--including the subsequent issuance of the 2012 
National Export Strategy. 

More specifically, in response to our recommendation on the need to 
clarify agency roles and responsibilities, SBA and Commerce provided 
us with a copy of the December 2012 Interagency Communiqué developed 
by TPCC agencies. The communiqué, which we included in appendix II, 
was intended to clarify roles and responsibilities and provide 
guidance on referring U.S. businesses seeking export assistance to 
federal, state, and nonfederal resources according to each firm's 
export readiness and business needs. We mentioned the communiqué in 
our report and noted that it did not include referral protocols for 
clients requiring trade financing products, which the communiqué said 
would be issued by the end of January 2013. The communiqué also notes 
that agencies intend to develop local Export Outreach Teams, to 
increase awareness of local international trade expertise and enhance 
communication and collaboration at the local level. Among other 
things, the Export Outreach Teams would develop referral protocols and 
initiate ongoing discussions of shared clients. Thus, the communiqué's 
plans, when fully implemented, would begin to address two findings in 
this report: the need to clarify roles and responsibilities among SBA, 
Commerce, and Ex-Im and the need to identify ways to increase sharing 
of client information deemed useful for SBA, Commerce, and Ex-Im. 
Regarding our recommendation to increase sharing of client information 
where possible, SBA acknowledged its continued work with other 
agencies to integrate knowledge management within current legislative 
restrictions on information sharing, and noted its optimism about the 
potential for information technology to facilitate greater information 
sharing. SBA also noted that the SBDC program's authorizing 
legislation prevents SBDCs from sharing specific client information 
outside of their network without prior written consent from the 
client, except under limited purposes. Furthermore, SBA agreed that it 
intends to respond to staffing requirements of the SBJA while 
acknowledging resource constraints in its next annual report to 
Congress. 

We also received comments from Ex-Im, USDA, and USTDA, clarifying 
information about their activities. We incorporated agencies' 
technical comments throughout our report, as appropriate. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to appropriate 
congressional committees; the Administrator of the SBA; the 
Secretaries of Commerce, Agriculture, and State; the Chairman and 
President of Ex-Im; and the Director of USTDA. In addition, the report 
will be available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-4347 or yagerl@gao.gov. Contact points for our 
Office of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff who made major contributions 
to this report are listed in appendix III. 

Signed by: 

Loren Yager: 
Managing Director: 
International Affairs and Trade: 

[End of section] 

Appendix I: Scope and Methodology: 

The objectives of this report were to (1) describe Small Business 
Administration's (SBA) role within federal export promotion efforts; 
(2) assess the extent to which SBA collaborates with other agencies in 
its export promotion activities; and (3) assess the extent to which 
SBA is meeting Small Business Jobs Act (SBJA) requirements to expand 
export promotion training and staffing. 

In our review, we defined "export promotion activities" as programs 
and services conducted by federal agencies that involve direct contact 
with U.S. exporters and have export promotion as their stated goal. 
Such activities include providing small businesses with export 
counseling, training, and financial assistance; they do not include 
activities such as advocacy, commercial diplomacy, and policy 
development and negotiations. Our review, therefore, covers six key 
agencies--SBA,[Footnote 37] Department of Commerce (Commerce), the 
U.S. Export-Import Bank (Ex-Im), the Department of Agriculture (USDA), 
the U.S. Trade and Development Agency (USTDA), and the Department of 
State (State)--with a particular emphasis on SBA's 
activities.[Footnote 38] We reported data from the Trade Promotion 
Coordinating Committee (TPCC) Secretariat on agencies' requested 
budget authority for export promotion activities for fiscal year 2012, 
which was the most recent data available. We also analyzed TPCC data 
on SBA's budget authority for export promotion activities for fiscal 
years 2006 through 2012. We determined that the data were sufficiently 
reliable for our purpose of illustrating SBA's relative share of the 
overall federal export promotion budget. 

To address all of our objectives, we interviewed agency officials 
representing the key export promotion entities in headquarters and in 
six selected field locations--Chicago, Dallas, Irvine (California), 
Miami, New York, and Portland (Oregon). We selected these locations 
because they had at least two export promotion entities' staff 
colocated, had the presence of Small Business Development Centers 
(SBDC) with staff providing export assistance, and ranked among 
locations with the highest export potential according to Commerce 
data. At some of these selected locations, we also met with 
representatives of small businesses that utilized federal government 
export assistance. The results of our interviews with officials at 
these six locations are not generalizable to agency officials' views 
at all U.S. locations. 

To describe SBA's export promotion activities within federal export 
promotion efforts, we analyzed government-wide initiatives, 
strategies, and TPCC's and agencies' documents and data. Our 
description of SBA and other agency activities is intended to be 
illustrative of the types of activities agencies engage in to support 
small business exports and is not exhaustive of all activities 
undertaken by each of the agencies. 

To assess the extent to which SBA collaborates with other agencies in 
its export promotion activities, we focused our assessment on 
coordination between SBA entities with Commerce and Ex-Im, the key 
agencies that provide similar export promotion activities to similar 
clients and that work together at the headquarters and field level, 
including at five of the selected field locations that feature all 
three agencies colocated in the same city. We analyzed government-wide 
initiatives, strategies, as well as TPCC's and agencies' documents, 
including the National Export Initiative and National Export Strategy. 
Additionally, we compared export promotion activities of Commerce and 
Ex-Im that are similar to SBA's activities, based on our analysis of 
information provided agency officials. We also used the results of our 
discussions with agencies' headquarters and field staff in six 
selected locations to assess the level of interagency collaboration. 
We assessed interagency coordination primarily against selected 
practices for enhancing and sustaining collaboration we previously 
identified.[Footnote 39] We selected four elements of collaboration 
best practices--establishing mutually reinforcing or joint strategies, 
reinforcing individual accountability for collaboration efforts, 
agreeing on roles and responsibilities, and leveraging resources to 
identify and address needs--because they allowed us to highlight the 
most critical and relevant elements of collaboration among export 
agencies at both the headquarters and field level. These elements also 
relate to issues identified in the 2011 National Export Strategy--for 
example the need for each SBA, Commerce, and Ex-Im to target clients 
and focus their strengths to achieve the common NEI goal to double 
U.S. exports. 

To assess the extent to which SBA is meeting SBJA requirements to 
expand export promotion training and staffing, we analyzed the SBJA 
and identified the specific export promotion requirements applicable 
to increasing the level of training of SBDC staff and increasing OIT 
staff numbers. We did not examine the other requirements under the 
SBJA. We analyzed SBA and SBDC documents and interviewed agency 
officials in headquarters and field locations to determine the 
implementation status of the SBJA requirements. We determined the 
extent to which SBDCs have met the certification requirement through 
an exam with the assistance of available training, but we did not 
assess the content or effectiveness of the certification, exam, or 
training. Furthermore, we reviewed SBA OIT's September 2012 report to 
Congress which, according to SBA, contained the most current 
implementation status and plans for the SBJA requirements. 

We conducted this performance audit from February 2012 to January 2013 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the Small Business Administration: 

U.S. Small Business Administration: 
Washington, D.C. 20416: 

January 16, 2013: 

Mr. Loren Yager: 
Managing Director: 
International Affairs and Trade: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Yager: 

The Small Business Administration (SBA) appreciates GAO's detailed and 
thorough analysis of SBA's export promotion programs. Thank you for 
recognizing the joint efforts of SBA and our Trade Promotion 
Coordinating Committee partner agencies in the coordinated delivery of 
services to small business exporters. 

We appreciate the recognition of SBA's leadership role in the Small 
Business Working Group of the National Export Initiative and our 
twenty year history of colocation and collaboration in the network of 
U.S. Export Assistance Centers (USEAC). We are particularly proud of 
SBA's contribution to the USEAC network, which is a collaborative 
colocation initiative unique in the Federal Government. We also 
appreciate GAO's recognition of the rapid embrace by the Small 
Business Development Centers of the increased role in export 
counseling they were given in the Small Business Jobs and Credit Act 
of 2010. SBA is a team player in the export space and continues to 
make an important contribution to the national mission to expand 
exports for small businesses, along with our partners at the 
Department of Commerce and Ex-Im Bank. 

We submit the following comments: 

On page l2, the draft report states "... and OIT and Ex-Im offer 
similar financial products to small businesses:" From our point of 
view, there is only one "similar" financial product, the Export 
Working Capital loan program, about which you have pointed out several 
important differences between our respective agency products. The 
SBA's Export Express Program can be either a revolving line of credit 
with a maturity of up to 7 years or a term loan with a maturity of up 
to 25 years depending on the use of proceeds. Ex-Im Bank's Global 
Credit Express (see typo on page 14 which refers to ExIm's "Export 
Express") has either a 6 month maturity or a 1 year maturity—hardly 
the loan to support ongoing working capital needs or long-term fixed 
asset financing. Nor was this direct loan program developed for that 
purpose. It basically was designed for promising exporters who could 
not obtain a government guaranteed loan through the banking system 
(whether a standard SBA loan, SBA Export Express or Ex-Im/SBA Working 
Capital loan). While some proceeds can be used for "export 
development," we understand that Global Credit Express provides 
support for export transactions and helps graduate these borrowers to 
a government guaranteed product, such as the SBA's Export Express or 
Export Working Capital Loan. In addition, the SBA offers the 
International Trade Loan, a term loan up to $5 million, to help 
companies expand their facilities and equipment as they grow their 
export business. This is not something Ex-Im Bank provides. On the 
other hand, Ex-Im Bank provides credit insurance and the SBA does not. 

The draft report on page 18-19 states that "agencies have not 
developed guidance that outlines a common understanding about where 
clients should be directed based on their export readiness" or that 
"directed Small Business Development Center counselors and Commerce 
staff to primarily counsel one type of client". A recent development 
is important to note: on December 12, 2012 SBA, through the Office of 
Small Business Development Centers, issued to all SBDCs the Inter-
Agency Communique developed in collaboration with our TPCC partners 
(attached hereto and provided to GAO with permission from the TPCC) 
(hereinafter referred to as the "Inter-Agency Communique"). The 
Communique provides guidance on referring US businesses seeking export 
assistance to the best federal, state or non-federal resource — 
including SBDC counselors - according to each firm's export readiness 
and business needs. The communique further recognizes that there 
should be "no wrong door" for businesses seeking help in exporting, 
and offers a referral matrix that can accommodate the myriad client 
types and circumstances of potential exporters based on its industry 
sector, structure, preparedness, size, location and other factors. 

The draft report also states on page 22 "Agency official noted that 
information sharing is limited by certain privacy restrictions" The 
draft report does not consistently separate its recommendation for SBA 
to increase its client information sharing with other federal 
agencies, from a recommendation for SBDCs (as nonfederal entities) to 
share their client information with SBA or other federal agencies. The 
distinction is relevant because the SBDC program's authorizing 
legislation specifically prevents SBDCs from sharing client 
information outside their network — even to SBA - without prior 
written consent of the client, except under limited purposes related 
to compliance. You may consider noting that Section 21(a)(7)(A) of the 
Small Business Act (15 USC 648 (a )(7)(A)) prohibits an SBDC from 
disclosing the name, address, or telephone number of any individual or 
small business concern receiving assistance under this section without 
the consent of such individual or small business concern, unless" 
required by a court order or the disclosure is "necessary for the 
purpose of conducting a financial audit of a small business 
development center." 

Finally, we have identified a few minor issues pertaining to the draft 
report's reading of the SBA's regulations and standard operating 
procedures (SOP), as well as the Small Business Jobs Act of 2010 
("SBJA"). First, on page 11 the draft report states that "SBA also 
offers guarantees on facilities development loans, which can be used 
to acquire or upgrade facilities and equipment used to produce goods 
or services for export" (emphasis added). Section 120.347 of SBA 
regulations, however, states that such guarantees can be used to 
acquire or upgrade facilities and equipment used to produce goods or 
services involved in international trade (emphasis added). Second, 
Table 6 on page 15 of the draft report states that the response time 
for the SBA Export Express program is 36 hours, but the SBA SOP states 
that the response time is one business day, See SBA SOP 50 10 5(E), 
sub. B, ch. 1, para. III. Third, on page 23 the draft report states 
that "the SBJA increased the maximum size of SBA's export loan 
program." The SBJA did not increase the maximum size of SBA's export 
loans program, but instead increased the maximum size of loan and loan 
guarantee amounts. Third, on page 23, GAO indicates that the statewide 
or region-wide SBDC organization is referred to as the Lead Center. 
SBDC program regulations actual refer to the statewide or regional 
organization as the SBDC network, which is managed by a Lead Center. 
(See 13 CFR 130, et seq.) 

We want to thank you for the constructive recommendations for program 
improvements, which SBA will work to implement. The following 
addresses the specific recommendations: 

* Recommendation 1: To help small businesses understand and get the 
most benefit from the various export assistance products and services 
provided by different federal entities, and to efficiently use 
government resources, consult with Commerce and Ex-lm to more clearly 
define roles and responsibilities of export promotion entities' export 
counseling and financing staff at the agency-wide and local levels. 

We agree that a clearer definition of agency roles and 
responsibilities could improve service delivery objectives among the 
agencies. In fact, in line with this recommendation, the Inter-Agency 
Communique issued to TPCC partners and to the SBDCs spells out a 
framework for clarifying roles and responsibilities in export 
promotion and trade financing. (Consequently, the section starting on 
page 18 might need to be amended, or footnoted, for this new 
initiative.) We also believe this new framework, plus the enhanced and 
formalized role of Export Outreach Teams, will facilitate more 
qualified referrals among partners in an effort to more efficiently 
and effectively meet SME exporters' needs. 

* Recommendation 2: To improve collaboration and leverage available 
resources, consult with Commerce and Ex-lm and identify ways to 
increase, where possible, sharing of client information deemed useful 
for SBA, Commerce, and Ex-Im. 

SBA will continue to work with Commerce, Ex-Im, GSA, OMB, and other 
federal agencies to integrate knowledge management within current 
legislative restrictions on information sharing. The Agency is 
optimistic about the potential for emerging information technologies 
to facilitate this objective. 

* Recommendation 3: To more effectively implement SBA's expansion of 
OIT field staff as required by the SBJA, update SBA's plan for 
additional 01T staff to include funding sources and time frames, as 
well as possible efficiencies from clearly defining roles and 
responsibilities and leveraging other entities' export assistance 
resources. 

In the Office of International Trade's next Annual Report to Congress, 
SBA intends to respond to the staffing requirements of the SBJA while 
acknowledging the resource constraints of the Agency. 

Once again, thank you for this detailed report and its 
recommendations. We appreciate the time that your staff has taken to 
understand the importance of small business export assistance programs 
and SBA's critical role in this arena. 

Sincerely, 

Signed by: 

Michael Chodos: 
Associate Administrator, Office of Entrepreneurial Development: 
U.S. Small Business Administration: 

Signed by: 

Dario J. Gomez: 
Associate Administrator, Office of International Trade: 
U.S. Small Business Administration: 

Enclosure: 

Interagency Communique: 

Under the National Export Initiative (NEI), the President committed 
the Federal Government to marshal its full resources in support of 
American businesses that sell their goods and services abroad. These 
efforts have borne considerable fruits — exports hit record levels in 
2011, supporting almost 10 million American jobs, and continue to make 
historic progress in 2012 — ensuring America's continued position as 
the global leader in total exports of goods and services. Yet for many 
small and medium-sized businesses, the Federal Government is still a 
maze of entities with sometimes overlapping export promotion services 
that can be difficult to navigate. 

On February 17, 2012, the President issued a Memorandum to all Federal 
agencies, which directed the Export Promotion Cabinet (EPC), in 
consultation with the Trade Promotion Coordinating Committee (TPCC), 
to take steps to ensure the most efficient use of its members' 
domestic offices and distribution networks, avoid duplication, enhance 
collaboration, and better leverage their services to enhance the 
coordinated services American businesses receive from the Federal 
government. 

Over the last six months, the EPC has worked closely with the TPCC to 
develop a comprehensive report and action plan for an integrated, 
strategic, government-wide export promotion effort that included a 
protocol to establish a "No Wrong Door" policy for all domestic field 
networks whereby: (1) all domestic business development and export 
assistance networks are knowledgeable about the full suite of Federal 
export assistance services and best agency contacts; (2) each agency 
can identify the respective leads for delivering export services and 
operate according to standard operating procedures for referrals; and 
(3) Federal export teams are organized to help coordinate and 
collaborate across networks. 

Description of Export Assistance Resources: 

U.S. businesses can access a range of export assistance services via 
several Federal agency networks. Which network is best positioned to 
provide assistance to a company depends on a number of factors 
including the agency's business model, state of export-preparedness. 
and the industry in which the company operates 

U.S. Department of Commerce (DOC): 

U.S. Export Assistance Centers (USEACs): Located in 93 U.S. cities and 
territories with trade specialists who provide export-ready businesses 
with market intelligence, market-entry strategies, advice on 
distribution channels, and assistance in identifying trade finance 
options. 

Manufacturing Extension Partnerships (MEPs): 70 non-profit centers 
that provide small/medium-sized manufacturers with assistance in 
technology acceleration, supplier development, sustainability, and 
workforce training. 

U.S. Small Business Administration (SBA): 

Trade Finance Specialists: 
SBA Trade Finance Specialists are co-located with DOC at 19 USEACs, 
providing export working capital loans, counseling on international 
methods of payments, and information on other SBA loans for exporters. 

Small Business Development Centers (SBDCs): 63 networks with over 900 
sites across the country provide individualized, long-term business 
counseling, group training, and market research services to small 
business owners. 

District International Trade Officers (DITOs): SBA District 
International Trade Officers (DIT0s) located at each of its 68 
District Offices as a trade resource to small businesses. 

U.S. Department of Agriculture (USDA): 

State Regional Trade Groups (SRTGs): Four non-profit trade 
associations, funded by USDA, provide a wide range of comprehensive 
programs and services to SMEs, including, customized export 
assistance, cost-share export promotion funding, trade show exhibition 
support, technical training, and international and reverse-trade 
missions. 

Export-Import Bank of the United States (Ex-Im): 

Ex-Im Bank: Over a dozen bank locations across the country that 
provide working capital guarantees, export credit insurance, loan 
guarantees, and direct loans that allow U.S, companies—-large and 
small-—to harness export opportunities. 

* Note SBA's other resource partners (SCORE and Women's Business 
Centers (WBCs)) are available as business resources, and can refer to 
5BDCs for export assistance where appropriate. They are not required 
to have trained expert export counselors as the SBDC5 are. There are 
110 WBCs and 350 SCORE chapters with over 12,000 volunteers. 

OPIC - The Overseas Private Investment Corporation provides political 
risk insurance and project financing for investment projects in 
emerging economies. 

USTDA - The U.S. Trade and Development Agency helps U.S. businesses 
connect with U.S. supported foreign procurement opportunities on 
transportation and infrastructure projects. 

USTR - The Office of the U.S. Trade Representative develops and 
coordinates international trade, commodity, and direct investment 
policy and oversees negotiations in these areas with other countries 
on behalf of the U.S. Government. USTR administers, in cooperation 
with other agencies, the trade advisory committee system, including 
the Industry Trade Advisory Committees (ITACs) which are jointly 
administered with DOC, which provides information and advice to help 
ensure U.S. trade policy and negotiating objectives adequately reflect 
U.S. public and private sector interests. 

DOC/BIS - The Department of Commerce's Bureau of Industry and Security 
administers an export control system, including licensing of exports 
of dual use technologies. 

State - The State Department through the Bureau of Economic and 
Business Affairs promotes commercial advocacy on behalf of U.S. 
businesses that are bidding on foreign goverment projects. The State 
Department works in coordination with the Advocacy Center housed 
within the Department of Commerce. 

This memorandum is a guide to help support the client referral and 
counseling process in the field by ensuring there is a standard 
operating procedure across the country that can then be enhanced and 
modified by customized local practices. 

Client Segmentation and Protocol for Referrals: 

When a U.S. firm determines it wants to utilize Federal or Federal 
resource partner export assistance services, an assessment needs to be 
conducted to determine whether it is "export ready." Generally, a firm 
is considered to be "export ready" when it has met the following four 
criteria: 

I) has been established as a U.S. business entity; 

2) sells an exportable and/or commercially available product or 
service; 

3) exhibits executive-level management commitment to dedicating the 
requisite personnel and resources; and; 

4) has developed an international business plan, including an 
assessment of the best export markets as well as a market entry 
strategy. 

The attached export client segmentation tool will help counselors 
determine a company's export readiness, as well as its specific export 
needs. (See attachment). Once a business has been classified as: I) 
not a good candidate for exporting; 2) not ready to export; 3) ready 
to export; or 4) an existing exporter, it can then be referred via the 
general protocol channels outlined below. This assessment tool can be 
found on Export.gov under the begin export button. 

Figure: Refer to PDF for image: table] 

Not a Good Candidate for Exporting: 
Definition: U.S. entries that are not an established business or
do not have an exportable product or service: 
Recommended Referral: 
* SDBC, WBC or SCORE for business advice; 
* SBA District International Trade Officers (DITOs). 

Not Ready to Export[1]: 
Definition: Established business entities that have an exportable 
product or service, but do not have an international business plan; 
Recommended Referral: 
* SBDC Lead Center for counseling and training; 
* MEP center (if a manufacturer); 
* MBC (if a minority-owned business). 

New Exporter Ready to Export: 
Definition: Established U.S. businesses that have an exportable good, 
executive commitment, and an international business plan, but have not 
consummated an overseas transaction; 
Recommended Referral: 
* USEAC; 
* SRTG/Cooperator (if an agricultural product) to identify buyer; 
* SBDC International Trade Center. 

Existing Exporter[2]: 
Definition: Existing exporters seeking to enter new markets or expand 
their exports; 
Recommended Referral: 
* USEAC; 
* SRTG/Cooperator; 
* SBDC International Trade Center. 

Notes: 

[1] If a firm would qualify for more than one of these, they can be 
referred to any of these networks. 

[2] Depending on the triage, these clients may also need trade finance 
assistance, in which case many SBA and Ex-Im trade finance specialists 
are co-located with USEACs. These exporters should be referred to 
these agencies depending on their needs. 

All clients should use Export.gov and Business.USA.gov throughout the 
export counseling process. 

[End of figure] 

All EPC/TPCC agencies will establish a "No Wrong Door" policy that 
requires all domestic offices to direct U.S. firms to the correct 
Federal export assistance services regardless of their agency. This 
referral process includes work between state and local economic 
development partners where appropriate. When non-Federal partners 
refer exporters to Department of Commerce international offices they 
should go through the local USEAC. 

Beyond the general referral channels there are additional referral 
protocols that will be defined by the end of January 2013. These 
include referrals between: 1) USEACs and USDA's Foreign Agricultural. 
Service with regard to agricultural products and services; and 2) SBA, 
Ex-Im Bank, and USDA for clients requiring trade financing products. 

Export Outreach Teams: 

In order to coordinate local field resources and unique export eco-
systems, each region will assemble and coordinate interagency Export 
Outreach Teams. Export Outreach Teams combine the client relationships 
of SBA resource partners, the SBA District Offices with the expertise 
of international trade service providers, such as the, U.S. Commercial 
Service (CS), Ex-Im Bank and SBA's Export Solutions Group and local 
economic development stakeholders and organizations, such as chambers 
of commerce. The teams are designed to: 

* Make local partners aware of the international trade expertise 
available in their area; and; 

* Enhance communication and collaboration between resource partners 
and international trade experts. 

Formation: 

The SBA District Director and/or his or her designee and US Department 
of Commerce USEAC Directors will lead the assembly and coordination of 
regional Export Outreach Teams and will be responsible for identifying 
potential team members in their coverage area. Each team's composition 
is flexible and should reflect the resources available in the 
community, such as state and local trade officers, Chambers of 
Commerce, and Economic Development organizations. At a minimum, each 
team should be composed of the local DOC USEAC Director, SBA District 
Director/DITO, SBA Trade Finance Specialist, and SBDC official. Ex-Im, 
MBC, MEP, SRTG, SCORE and WBC officials are welcome to join in areas 
where they are available and focus on international trade. 

In preparation, an Export Outreach Team Facilitators Guide will be 
provided to each District Office and USEAC. 

Once members are identified, the DOC USEAC Director will work closely 
with the SBA District Director and/or his or her designee to 
coordinate an Export Outreach Workshop to provide training with the 
following objectives: 

* Increased understanding of the network's international trade 
resources. 

* Development of referral protocols and understanding of respective 
metrics. 

* Recognition of client trade readiness/export potential and ongoing 
discussion of shared clients. 

* Sharing best practices for client service. 

Timeline: 

* SBA District Directors and DOC USEAC Directors will be responsible 
for identifying and contacting anticipated EOT participants by April 
30, 2013, and must schedule and hold a workshop by September 30, 2013. 

* Export Outreach Teams should convene at least quarterly. 

Client Segmentation Assessment Questions: 

1. Does your company have a product or service that has been 
successfully sold in the domestic market? 

2. Does your company have or is your company preparing an 
international marketing plan with defined goals and strategies? 

3. Is your company's management committed to developing export markets 
and willing and able to dedicate staff, time and resources to the 
process? 

4. Does your company have the financial resources to actively support 
the marketing of your products in the targeted overseas markets?
5. Does your company have sufficient production capacity that can be 
committed to the export market? 

6. Is your company committed to providing the same level of service 
given to your domestic customers? 

7. Does your company have adequate knowledge in modifying product 
packaging and ingredients to meet foreign import regulations and 
cultural preferences? 

8. Does your company have adequate knowledge in shipping its product 
overseas, such as identifying and selecting international freight 
forwarders and freight costing? 

9. Does your company have adequate knowledge of export payment 
mechanisms, such as developing and negotiating letters of credit or 
insuring overseas accounts receivable to mitigate risk? Or accessing 
export working capital to fund transactions? 

Per the protocols above, if the answer to the first three questions is 
yes and it is a U.S. based company then it is regarded as an export —
ready company. If no to any of the first three questions then the 
company is considered not ready to export or not a good candidate for 
exporting. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Loren Yager, (202) 512-4347, or yagerl@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Adam Cowles, Assistant 
Director; Lina Khan; Victoria Lin; and Kara Marshall made key 
contributions to this report. The team benefited from the expert 
advice and assistance of David Dayton, David Dornisch, and Grace Lui. 

[End of section] 

Footnotes: 

[1] Small Business Jobs Act of 2010, Pub. L. No. 111-240, §§ 1201-
1209, 124 Stat. 2504, 2520-36. 

[2] SBDCs are partially funded by SBA and located primarily at 
colleges and universities as a cooperative effort among SBA, the 
academic community, the private sector, and state and local 
governments. For the purposes of our report, we refer to SBDCs as 
SBA's partner entities. 

[3] The scope of our work does not cover the Overseas Private 
Investment Corporation (OPIC) because export promotion is not its 
primary stated goal. OPIC is a development finance institution 
providing investors with financing, guarantees, political risk 
insurance, and support for private equity investment funds. OPIC 
officials informed us that OPIC's work may result in U.S. exports, but 
the agency does not conduct its work to seek U.S. export 
opportunities. We include SBA export promotion activities that may 
directly or indirectly support exports by small businesses, which 
includes SBDCs' export promotion activities. We did not include SBA's 
Women's Business Centers and Service Corps of Retired Executives 
because those entities generally have a limited role in export 
promotion. Moreover, we did not include the State Trade and Export 
Promotion (STEP) program, a 3-year pilot trade and export initiative 
authorized by the Small Business Jobs Act of 2010. Funded by federal 
grants and matching funds from the states, the STEP Program is 
designed to help increase the number of small businesses that are 
exporting and to raise the value of exports for those small businesses 
that are currently exporting. 

[4] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21, 
2005). 

[5] Pub. L. No. 102-429, Title II, 106 Stat. 2186. 

[6] Pub. L. No. 102-429, § 201. 

[7] The National Export Strategy for 2012 was expected to be released 
in September 2012 but was delayed. The TPCC issued the 2012 National 
Export Strategy in December 2012, too late for us to review its 
contents for our report. 

[8] Executive Order 13534 established the Export Promotion Cabinet on 
March 11, 2010. 

[9] The term "USEAC" refers to the 108 domestic offices where 
Commerce's Commercial Service operates, including where SBA and Ex-Im 
have staff colocated with Commerce's staff. 

[10] SBA has district offices in every state that provide export and 
nonexport-related services. 

[11] There are four such groups located throughout the United States. 
The State Regional Trade Groups are jointly funded by state 
agricultural departments and USDA's Market Access program. They 
provide a variety of services to help U.S. companies export 
agricultural goods. 

[12] GAO, National Export Initiative: U.S. and Foreign Commercial 
Service Should Improve Performance and Resource Allocation Management, 
[hyperlink, http://www.gao.gov/products/GAO-11-909] (Washington, D.C.: 
Sept. 29, 2011). 

[13] In commenting on our draft report, USTDA officials stated that 
USTDA does not provide export financing, but instead provides 
financial assistance to pursue trade leads through grants and contract 
opportunities. 

[14] USDA does not track export loan guarantee financing by business 
size and, therefore, was not able to provide data on financing for 
small businesses. 

[15] For example, see GAO, 2012 Annual Report: Opportunities to Reduce 
Duplication, Overlap and Fragmentation, Achieve Savings, and Enhance 
Revenue, [hyperlink, http://www.gao.gov/products/GAO-12-342SP] 
(Washington, D.C.: Feb. 28, 2012). 

[16] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[17] In addition, the Government Performance and Results Act 
Modernization Act of 2010 requires agencies to describe in annual 
performance plans how they are working with other agencies to achieve 
their own performance goals as well as relevant federal government 
performance goals. See Pub. L. No. 111-352, 124 Stat. 3866 (2011). 

[18] The 2012 National Export Strategy provided the first year-to-year 
comparison of results for the performance measures outlined in the 
2011 Strategy, according to Commerce officials. 

[19] Commerce Office of Inspector General, U.S. Export Assistance 
Centers Could Improve Their Delivery of Client Services and Cost 
Recovery Efforts, Audit Report Number OIG-13-010-1 (Washington, D.C.: 
Nov. 30, 2012). 

[20] After we submitted a draft of our report to the agencies, SBA 
provided us with an Interagency Communiqué developed by TPCC agencies. 
The communiqué establishes a "No Wrong Door" policy and provides 
guidance on referring U.S. businesses seeking export assistance to one 
or more specific entities based on an assessment of a client's export 
readiness and its needs for counseling and training and/or trade 
leads; however, the communiqué does not include referral protocols for 
clients requiring trade financing products, which the communiqué said 
would be issued by the end of January 2013. 

[21] In December 2012, TPCC agencies sent field staff the Interagency 
Communiqué that provides guidance on how to assess the export 
readiness of clients and identifies general referral channels once a 
business has been classified as: (1) not a good candidate for 
exporting; (2) not ready to export; (3) ready to export; or (4) an 
existing exporter. 

[22] In November 2012, the Commerce Office of Inspector General found 
that restrictions on sharing of client information constrained 
Commerce's ability to collaborate with other agencies and recommended 
that it explore the possibility of requiring clients to waive 
confidentiality as a condition for receiving services. Commerce 
concurred with this recommendation. 

[23] See 15 U.S.C. § 648(a)(7)(A). 

[24] Pub. L. No. 111-240, §§ 1201-1209. 

[25] Pub. L. No. 111-240, §§ 1203 and 1206. 

[26] Pub. L. No. 111-240, § 1205(a). 

[27] Each statewide or region-wide SBDC network is managed by a Lead 
Center. There are 63 Lead Centers throughout the states that manage 
and administer the 63 small business assistance networks, each 
consisting of the Lead Center and its Service Centers. 

[28] Pub. L. No. 111-240, § 1204(a)(7). 

[29] Pub. L. No. 111-240, § 1205(a). 

[30] Id. 

[31] Pub. L. No. 111-240, § 1205(a). The SBJA required that SBA, to 
the maximum extent possible, fill new OIT staff positions at those 
USEACs that (1) had OIT staff before January 2003 and (2) had not had 
OIT staff between January 2003 and September 27, 2010, due to 
retirement or reassignment. 

[32] For SBDCs with cooperative agreements that begin and end on the 
federal fiscal year cycle, the deadline is September 30, 2013. For 
SBDCs with cooperative agreements that begin and end on a calendar 
year cycle, the deadline is December 31, 2013. 

[33] The Certified Global Business Professional program is an 
internationally recognized independent certification for advanced 
proficiency in global trade assistance, available through training 
offered by a third party, such as a community college. 

[34] A total of 195 SBDC staff were certified because they passed 
SBA's online competency test, and 132 staff were certified through the 
Certified Global Business Professional program. 

[35] According to SBA officials, some SBDC networks have one or more 
separately budgeted International Trade Centers that specialize in 
export and international trade assistance. In 2012, there were nine 
designated International Trade Centers. Other SBDCs within a given 
network may be very active in providing export assistance although 
they are not designated as a separate International Trade Center. The 
designation is based on each SBDC network's preferred organizational 
structure and small business needs. 

[36] SBA started with 18 OIT field staff and then hired 2 additional 
staff. Given the attrition of one existing OIT staff and the placement 
of one of the new staff to fill the vacated position, SBA had a total 
of 19 at the end of September 2012. 

[37] We include SBA export promotion activities that may directly or 
indirectly support exports by small businesses, including the export 
promotion activities of the Small Business Development Centers. We did 
not include SBA's Women's Business Centers and Service Corps of 
Retired Executives because those entities generally have a limited 
role in export promotion. 

[38] The scope of our work does not cover the Overseas Private 
Investment Corporation (OPIC) because export promotion is not its 
primary stated goal. OPIC is a development finance institution 
providing investors with financing, guarantees, political risk 
insurance, and support for private equity investment funds. OPIC 
officials informed us that OPIC's work may result in U.S. exports, but 
the agency does not conduct its work to seek U.S. export opportunities. 

[39] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21, 
2005). 

[End of section] 

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