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entitled 'Export-Import Bank: Changes Would Improve the Reliability of
Reporting on Small Business Financing' which was released on March 3,
2006.
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Report to the Chairman, Committee on Small Business, House of
Representatives:
March 2006:
Export-Import Bank:
Changes Would Improve the Reliability of Reporting on Small Business
Financing:
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-351]:
GAO Highlights:
Highlights of GAO-06-351, a report to the Chairman, Committee on Small
Business, House of Representatives:
Why GAO Did This Study:
The Export-Import Bank (Ex-Im) provides loans, loan guarantees, and
insurance to support U.S. exports. Its level of support for small
business has been a long-standing issue of congressional interest. Most
recently in 2002, Congress increased the proportion of financing Ex-Im
must make available for small business to 20 percent.
GAO examined legal and policy issues related to Ex-Im’s small business
financing. Specifically, GAO (1) analyzes Ex-Im’s methodology for
calculating its direct support of small business and the reliability of
Ex-Im’s data used in the methodology and (2) describes Ex-Im’s legal
interpretation of its obligations under the statutory 20 percent small
business mandate.
What GAO Found:
While Ex-Im generally classifies companies’ small business status
correctly, weaknesses in its data systems and data limit its ability to
accurately determine its small business financing. Ex-Im uses a
combination of direct counts and estimates to calculate its small
business financing, based on the authorized value of individual
transactions. For most transactions, Ex-Im can identify the exporter
and thus bases its determination of the small business financing share
on whether the exporter qualifies as a small business. For other
transactions, Ex-Im cannot identify the exporter at the time it
authorizes the transaction and estimates the small business share based
on shipment patterns in an earlier period. GAO determined that Ex-Im
generally classifies companies’ small business status correctly.
However, GAO identified weaknesses in Ex-Im’s process for calculating
its small business support. For transactions where Ex-Im can identify
the exporter, GAO found internal control weaknesses such as Ex-Im’s
data systems containing conflicting records for the same company. For
transactions where Ex-Im cannot identify the exporter when it
authorizes the transaction, a weakness is not including a large value
of shipments in its calculations. GAO also determined that Ex-Im’s
reporting on the number of transactions—as opposed to the value of
transactions—that directly benefit small business includes transactions
that do not benefit small business.
Weaknesses in Ex-Im’s Process For Calculating Its Small Business
Financing:
[See PDF for image]
[End of figure]
Prior to the enactment of credit reform legislation, Ex-Im interpreted
the mandate as requiring it to make available for financing small
business exports an amount equal to 10 percent of the aggregate
principal amount of loans, guarantees and insurance specified by
Congress for that fiscal year. Given changes in law including federal
credit reform and the removal of specific financing authority limits,
Ex-Im currently interprets its statutory small business financing
mandate as requiring it to attempt to ensure that 20 percent of the
authorized value of its transactions during a year directly benefits
small business.
What GAO Recommends:
GAO recommends that the Chairman of the Export-Import Bank take steps
to improve the reliability of Ex-Im’s reporting on its direct support
for small business.
Ex-Im commented that the review helped reaffirm its methodology and
identify areas where it can improve its efficiency. Ex-Im generally
concurred with GAO’s recommendations and identified several actions it
is taking or will take that address them.
www.gao.gov/cgi-bin/getrpt?GAO-06-351.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Loren Yager at (202) 512-
4347 or YagerL@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Ex-Im Generally Classifies Companies' Small Business Status Correctly,
but Weaknesses Limit Its Ability to Accurately Measure Small Business
Financing:
Ex-Im's Interpretation of the Small Business Financing Mandate:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Information on Ex-Im's Monitoring and Tracking of Its
Small Business Financing:
Appendix III: Information on How Ex-Im Estimates Its Indirect Support
of Small Business:
Appendix IV: Comments from the Export-Import Bank:
Appendix V: GAO Contact and Staff Acknowledgments:
Figures:
Figure 1: Ex-Im's Reported Fiscal Year 2004 Financing, by Type of
Transaction:
Figure 2: Ex-Im's Reported Proportion of Financing Directly Benefiting
Small Business:
Figure 3: Ex-Im's Methodology for Calculating Its Direct Support of
Small Business:
Figure 4: Ex-Im's Reported Amount of Fiscal Year 2004 Transactions
Directly Benefiting Small Business:
Abbreviations:
CGF: Credit Guarantee Facility:
D&B: Dun and Bradstreet:
Ex-Im: Export-Import Bank of the United States:
NAICS: North American Industry Classification System:
SBA: Small Business Administration:
SIC: Standard Industrial Classification:
Letter March 3, 2006:
The Honorable Donald A. Manzullo:
Chairman:
Committee on Small Business:
House of Representatives:
Dear Mr. Chairman:
The Export-Import Bank's (Ex-Im) level of support for small businesses
has been an issue of long-standing congressional interest. Since the
1980s, Congress has required that Ex-Im, which provides loans, loan
guarantees, and insurance to finance U.S. exports, make available a
specified percentage of its export financing for small businesses. Over
time, there has been considerable debate regarding what this percentage
should be and what should be included in its calculation. In 2002,
Congress established several new requirements for Ex-Im relating to
small business, including increasing from 10 to 20 percent the
proportion of Ex-Im's aggregate loan, guarantee, and insurance
authority that must be made available for the direct benefit of small
businesses. Although Ex-Im consistently reported providing more than 10
percent of the value of its authorized transactions to small business
through 2002, it has not reported providing 20 percent in any year
since then.
Following your request, and given the broad interest in promoting
exports by small businesses and the upcoming reauthorization of Ex-Im's
authorizing legislation, we examined legal and policy issues related to
Ex-Im's small business financing. Specifically, this report (1)
analyzes Ex-Im's methodology for calculating its direct support of
small business and the reliability of Ex-Im's data used in the
methodology and (2) describes Ex-Im's legal interpretation of its
obligations under the 20 percent small business mandate. In addition,
this report includes information on Ex-Im's efforts to monitor and
track its small business financing (see app. II) and how Ex-Im
estimates the share of its financing that indirectly supports small
business (see app. III).
To analyze Ex-Im's methodology for calculating its direct support for
small business and the reliability of the data used in the calculation,
we reviewed Ex-Im documentation regarding the calculation, analyzed
data on Ex-Im transactions from fiscal years 2004 and 2005, and
interviewed knowledgeable Ex-Im staff. We also drew a random
probability sample of 300 of the 2,755 companies receiving Ex-Im
financing in fiscal years 2004 or 2005 to determine whether companies'
small business status was classified correctly. To describe Ex-Im's
legal interpretation of its statutory small business financing mandate,
we reviewed the statutory obligations under the provision and its
legislative history, reviewed other relevant legal documents, and
interviewed Ex-Im legal staff regarding their interpretation. For a
more detailed explanation of our objectives, scope, and methodology,
see appendix I. We conducted our work from June 2005 to January 2006 in
accordance with generally accepted government auditing standards.
Results in Brief:
While Ex-Im generally classified companies' small business status
correctly, weaknesses in its data systems and data limit Ex-Im's
ability to accurately determine its small business financing amounts
and share. Ex-Im measures its small business financing share based on
the level of financing that it authorizes for various types of
transactions, using a combination of direct counts and estimates. For
most types of transactions, Ex-Im can identify the exporter when it
authorizes the transaction and calculates its small business financing
based on whether the exporter qualifies as a small business under the
Small Business Administration's definition. For other transactions, the
exporter is not known at the time Ex-Im authorizes the transaction, so
it estimates the amount of small business support for these
transactions based on data regarding previous shipments under these
types of transactions. We determined that Ex-Im generally classifies
companies' small business status correctly. We identified weaknesses in
Ex-Im's process for determining its small business support for both its
calculations based on direct counts and calculations based on
estimates. For transactions where the exporter is known, internal
control weaknesses in Ex-Im data systems, including updating records on
companies in one data system, but not another, limit Ex-Im's ability to
accurately measure its small business financing. For transactions where
the exporter is not known at the time Ex-Im authorizes the transaction,
we identified weaknesses in Ex-Im's estimation process such as not
including a large value of shipments in its calculations. Finally, Ex-
Im's legislatively-mandated reporting on the number--as opposed to the
value--of transactions directly benefiting small business includes
transactions that do not benefit small businesses.
Prior to the enactment of credit reform legislation, Ex-Im interpreted
the mandate as requiring it to make available for financing small
business exports an amount equal to 10 percent of the aggregate
principal amount of loans, guarantees and insurance specified by
Congress for that fiscal year. Given changes in law over time, Ex-Im
currently interprets the statutory small business mandate as requiring
it to attempt to ensure that 20 percent of the authorized value of its
annual transactions directly benefits small business. Ex-Im officials
justify their interpretation of the small business financing
requirement based on the mandate's legislative history, the demand-
driven nature of Ex-Im's operations, and the broader context of Ex-Im's
authorizing legislation. Since the mandate was enacted, federal credit
reform legislation in the 1990s changed how credit agencies, including
Ex-Im, budget and account for the cost of their credit programs. This
change coincided with the removal of the aggregate loan authority
limits in annual appropriations acts on the amount of financing Ex-Im
could provide each year, which affects how Ex-Im implements the small
business financing requirement.
In this report, we recommend that the Chairman of the Export-Import
Bank take steps to improve the reliability of Ex-Im's reporting on its
direct support for small business. We provided a draft of this report
to Ex-Im. Ex-Im commented that the review helped reaffirm its
methodology and identify areas where it can improve its efficiency. It
generally concurred with our recommendations and identified several
actions it is taking or will take that address them. Ex-Im also stated
its view that it had a sound methodology for counting the number of
transactions benefiting small business.
Background:
Established in 1934, Ex-Im operates as an independent agency of the
U.S. government and is the official export credit agency of the United
States under the authority of the Export-Import Bank Act of 1945, as
amended.[Footnote 1] Ex-Im's mission is to assist U.S. companies to
create and maintain American jobs by financing exports of goods and
services and filling gaps in the availability of commercial financing
for creditworthy export transactions. It also helps American exporters
meet government-supported financing competition from other countries so
that American exporters can compete for overseas business on the basis
of price, performance, and service. Its authorizing legislation
requires Ex-Im not to compete with commercial lenders.
To accomplish its mission, Ex-Im offers a variety of financing
instruments, including loan guarantees and direct loans for buyer
financing; export credit insurance; and working capital guarantees for
pre-export financing.[Footnote 2] Under its loan guarantee program, Ex-
Im agrees to guarantee loans made by other lenders to help buyers in
other countries obtain financing to purchase U.S. exports.[Footnote 3]
Ex-Im also provides export credit insurance to protect U.S. exporters
against nonpayment by their customers. It provides this insurance
either directly to exporters, or to banks which in turn finance U.S.
exporters.[Footnote 4] In addition, Ex-Im provides working capital
guarantees to U.S. companies that would like to export but need funds
to produce or market their goods or services for export.
After it receives an application for financing from a U.S. exporter,
bank, or foreign buyer, Ex-Im determines whether the applicant meets
certain eligibility requirements. After Ex-Im approves or "authorizes"
the transaction, it issues the loan, loan guarantee, or insurance
policy. The amount actually exported or shipped as a result of the
transaction may differ from the authorized value of the transaction.
For example, for bank-held insurance policies, the total value of the
policies authorized during the year often exceeds the amount shipped
under these policies.
Figure 1 shows Ex-Im's reported fiscal year 2004 financing, by type of
transaction. Ex-Im reported authorizing more than $13 billion in loans,
guarantees, and export insurance in fiscal year 2004. Of this amount,
Ex-Im reported that more than $2.2 billion, about 17 percent, directly
supported U.S. small businesses.
Figure 1: Ex-Im's Reported Fiscal Year 2004 Financing, by Type of
Transaction:
[See PDF for image]
[End of figure]
Congress has demonstrated its interest in Ex-Im's supporting small
business by, among other things, requiring that Ex-Im make available a
specified portion of its financing for small business. In 1983,
Congress required Ex-Im to make available for fiscal year 1986 and
thereafter not less than 10 percent of its aggregate loan, guarantee,
and insurance authority for financing exports by small
businesses.[Footnote 5] In 2002, Congress increased the percentage,
requiring that Ex-Im "shall make available, from the aggregate loan,
guarantee, and insurance authority available to it, an amount to
finance exports directly by small business concerns. . .which shall be
not less than 20 percent of such authority for each fiscal
year."[Footnote 6] Figure 2 shows the proportion of its total financing
that Ex-Im has reported directly benefits small business. Ex-Im is also
required to report annually (1) the number of its transactions that
directly benefit small business and (2) an estimate of the number of
small businesses Ex-Im indirectly supports as suppliers to companies
receiving Ex-Im financing.[Footnote 7]
Figure 2: Ex-Im's Reported Proportion of Financing Directly Benefiting
Small Business:
[See PDF for image]
[End of figure]
Ex-Im uses the Small Business Administration (SBA) methodology to
determine whether a company qualifies as a small business. SBA uses
"size standards" to identify the largest a company can be and still
qualify as a small business. SBA's size standards vary by industry, as
defined by the North American Industry Classification System
(NAICS),[Footnote 8] which replaced the Standard Industrial
Classification (SIC) system, and are typically expressed in either
millions of dollars or number of employees, reflecting average annual
receipts or average employment of a firm.
To apply the size standards, Ex-Im obtains company information through
its application process. Ex-Im also subscribes to Dun and Bradstreet
(D&B), a commercial information vendor, which provides information
about companies, including sales and employment data and SIC codes. Ex-
Im uses the SIC codes provided by D&B to obtain the corresponding NAICS
codes through the SBA Web site.
The Federal Credit Reform Act of 1990 affects how Ex-Im budgets for and
reports on its various credit programs. It requires that Ex-Im (and
other government credit agencies) obtain budget authority to cover the
cost to the government of new or modified loans and loan guarantees.
Prior to credit reform, Congress annually provided budget authority for
the face value of authorized loans and the value of defaulted
guarantees. Credit reform requires agencies to estimate the cost to the
government, over the life of the credit, of the financing they provide.
Broadly speaking, this cost represents net losses to the government on
a present value basis. By focusing on the cost to the government,
credit reform allows policy makers to compare the costs of credit
programs with each other and with noncredit programs in making budget
decisions.
Ex-Im's financial statements are audited annually by an independent
accounting firm, which does not examine Ex-Im's reporting on the
calculation of its small business financing share. The auditor reviews
the financial information involved in the year's transactions but does
not review whether the figure reported for the small business financing
share is accurate. Ex-Im has received unqualified or "clean" opinions
on its financial statements for the past several years.
Ex-Im Generally Classifies Companies' Small Business Status Correctly,
but Weaknesses Limit Its Ability to Accurately Measure Small Business
Financing:
While Ex-Im generally classifies companies' small business status
correctly, weaknesses in its data systems and data limit Ex-Im's
ability to accurately determine its small business financing amounts
and share. Ex-Im bases its estimate of the small business share of its
financing on authorized values for various types of transactions. Ex-
Im's methodology for calculating its small business financing is based
on directly counting the value of small business financing for
transactions where the exporter can be identified and estimating the
small business value of transactions where the exporter cannot be
identified at the time Ex-Im authorizes the transaction. While we found
that Ex-Im generally classifies companies' small business status
correctly, we identified several weaknesses in Ex-Im's process for
calculating its small business support. For transactions where the
exporter can be identified, internal control weaknesses in Ex-Im's data
systems affect the reliability of Ex-Im's analysis of the value of its
small business financing. For transactions where the exporter cannot be
identified at the time Ex-Im authorizes the transaction, weaknesses in
Ex-Im's system for estimating small business financing also limit Ex-
Im's ability to accurately measure and report on the amount of small
business financing. In addition, in its required reporting on the
number--as opposed to the value--of transactions benefiting small
business, Ex-Im includes transactions which do not directly benefit
small business.
Ex-Im's Overall Calculation of Small Business Financing Is Based on the
Authorized Value of Transactions; Specific Calculations Vary by Type of
Transaction:
Ex-Im calculates the small business share of its total financing during
a year by dividing the value of authorized transactions directly
benefiting small businesses by the total value of all transactions
authorized. For some types of transactions, the amount of money
authorized may be significantly different from the amount of financing
that the exporters actually utilize. For most transactions, Ex-Im can
identify the exporter at the time the transaction is authorized and, in
those cases, it bases its calculation on whether the exporter qualifies
as a small business under the SBA definition. About one-quarter of the
time, such as in cases where Ex-Im provides an insurance policy to a
bank, which in turn finances exports, Ex-Im cannot, when it approves
the transaction, identify the company that will be the exporter. In
these cases, Ex-Im estimates the share of the financing benefiting
small business based on data regarding previous shipments under those
types of transactions.
To determine the value of the small business share of its financing
authorized during a year, Ex-Im adds the value of small business
financing for the types of transactions where the exporter can be
identified at the time of authorization and the estimated small
business value of the types of transactions where the exporter cannot
be identified at that time. To determine the portion of financing
directly supporting small business, Ex-Im divides this total by the
total dollar value of all transactions authorized. According to Ex-Im
officials, they have used this general methodology for calculating the
small business portion since the late 1980s. (See fig. 3.)
For transactions where the exporter can be identified, Ex-Im bases its
calculation on actual data on the value of the transaction and the
participants. For most of these transactions, Ex-Im generally counts
100 percent of the value of the transaction as benefiting small
business if the exporter is a small business. For medium-and long-term
loans and guarantees, only the amounts associated with small business
suppliers to small business exporters are counted as directly
supporting small business. Ex-Im officials noted that by not including
the value of a transaction associated with a nonsmall business
supplier, the small business share is reduced. They said this indicates
Ex-Im's desire to not overrepresent its direct support of small
business. When the exporter is not a small business, none of the value
of the transaction is counted as directly supporting small business.
Figure 3: Ex-Im's Methodology for Calculating Its Direct Support of
Small Business:
[See PDF for image]
[End of figure]
For transactions where the exporter is not known at the time Ex-Im
authorizes the transaction, Ex-Im estimates the small business share
based on data on the size of companies making shipments under these
types of transactions for a previous period.[Footnote 9] To make these
estimates, Ex-Im analyzes data on exports under each type of
transaction and determines whether each exporter is small, nonsmall, or
unknown. For each type of transaction, Ex-Im estimates the percentage
of the value of shipments by small businesses. Ex-Im divides the value
of shipments made by small business exporters by the sum of the
shipments by small and nonsmall business exporters. (Shipments by
companies of unknown size are excluded from the calculation.) Ex-Im
applies this percentage to the value of the entire year's authorized
transactions of this type, resulting in its estimate of the value of
direct support for small business from that transaction type.
In some cases, these estimates of the small business share of
authorized transactions can differ significantly from the small
business amounts actually shipped under the authorizations. For
example, in 2005 Ex-Im authorized a $10 million short-term insurance
policy under which no shipments have been reported. In contrast, in
2005 Ex-Im also authorized a $50 million short-term insurance policy
where shipments under the policy exceeded $87 million for a 6-month
period (or $174 million on an annualized basis). A 2004 authorization
for Iraq provides another example. In February 2004 Ex-Im issued a $250
million short-term bank-held insurance policy involving Iraq. Using the
methodology described above, Ex-Im estimated that 21 percent of the
value of bank-held insurance, overall, would directly benefit small
business, and thus credited approximately $53 million of this
authorization for Iraq to its accounting of small business
financing.[Footnote 10] According to Ex-Im officials, companies have
just begun making shipments under this policy.
Figure 4 shows Ex-Im's reported small business share of each type of
transaction for fiscal year 2004.
Figure 4: Ex-Im's Reported Amount of Fiscal Year 2004 Transactions
Directly Benefiting Small Business:
[See PDF for image]
[End of figure]
Ex-Im Generally Classifies Companies' Small Business Status Correctly:
Ex-Im's classification of companies' small business status is generally
correct, based on our review of independent data and Ex-Im's paper
transaction files. Based on our review of Ex-Im's electronic databases
and D&B data on companies' sales and employment, we estimate that, 83
percent of the time, Ex-Im's small business designation[Footnote 11]
matches the designation based on D&B data. Based on a review of Ex-Im's
official paper transaction files in instances where Ex-Im's small
business designation differed from the designation indicated by D&B, we
determined that Ex-Im's designation was justified in most instances,
although we observed a significant number of errors related to loans
and guarantees.
Comparison of Ex-Im's Small Business Designation with Designation Based
on D&B Data:
Based on our review of a statistical sample of 300 companies, we
estimate that for those companies for which we were able to obtain
credible matching data from D&B, 83 percent[Footnote 12] of the time Ex-
Im's small business designation in its electronic database matched the
designation indicated by D&B company data.[Footnote 13] We estimate
that there is credible D&B matching data for 90 percent of the
companies in the Ex-Im database.[Footnote 14] Our analysis shows that,
where Ex-Im's small business designation differed from the designation
indicated by D&B data, Ex-Im almost always identified a company that
appears to qualify as a small business as a nonsmall business. Ex-Im
officials stated that these results reflect their practice of being
conservative in identifying companies as small businesses. Because the
value of individual transactions can vary significantly, these results
do not necessarily mean that Ex-Im undercounted the value of its small
business financing.
The frequency of differences in companies' small business designation
in Ex-Im's data and our analysis of D&B data varied based on the type
of transaction examined. For companies involved in nonbank-held
insurance and working capital transactions, we estimate that 10 and 11
percent, respectively, of Ex-Im's small business designations in its
electronic data systems differ from the small business designation
resulting from applying the SBA methodology to D&B data.[Footnote 15]
For medium-and long-term loans and guarantees, which account for about
half of the value of total transactions but only about 2 percent of the
value of small business transactions, we estimate that 50 percent of Ex-
Im's small business designations differ from the small business
designation resulting from applying the SBA methodology to D&B
data.[Footnote 16]
Ex-Im's Basis for Categorizing Some Companies Differently Than
Designation Based on D&B Data:
According to our review of Ex-Im's official paper records, Ex-Im's
small business designations are generally justified when they differ
from designations based on D&B data. We reviewed Ex-Im's paper records
for 90 percent of the companies where we observed differences between
Ex-Im's small business designation in its electronic database and the
designation based on D&B data. We determined that Ex-Im's designation
was justified in the majority of instances. However, we found a large
number of errors regarding companies involved in loans and guarantees.
With respect to insurance or working capital transactions, we
determined that, for 18 of the 19 companies involved in these
transactions, documentation in Ex-Im's paper files supported its small
business designation in the paper and electronic files.[Footnote 17] In
some of these instances, we determined that Ex-Im's designation was
correct because the company receiving Ex-Im financing was the
subsidiary of a larger company that did not qualify as a small
business, thus disqualifying the subsidiary from being considered a
small business. In other instances, other information in the paper
transaction files supported Ex-Im's designation of the company's small
business status. For about half of the companies involved in loans and
guarantees, however, Ex-Im's small business designation in the paper
file differed from the designation in the electronic database. In these
cases, Ex-Im's paper files and our analysis identified the companies as
small businesses, but Ex-Im's electronic files used to calculate its
small business financing identified them as nonsmall businesses. Thus,
none of these errors caused Ex-Im to inappropriately take "credit" for
small business financing.
Weaknesses Exist in Ex-Im's Process for Calculating Its Small Business
Financing:
We identified weaknesses in Ex-Im's process for calculating its small
business financing, ranging from internal control weaknesses that may
affect only a few transactions a year to more significant weaknesses in
Ex-Im's system for estimating about one-third of its small business
support. For transactions where the exporter is known, we found
weaknesses related to internal controls in Ex-Im's data systems. For
transactions where the exporter is not known at the time Ex-Im
authorizes the transaction, we identified weaknesses such as analyzing
shipments equaling a small portion of the authorized value of
transactions, excluding a large share of exports, and misclassifying
companies' small business status for the purpose of estimating small
business shares based on shipments in previous periods. We did not
determine the cumulative effect of these weaknesses on Ex-Im's overall
calculation of its small business support.
Internal Control Weaknesses Exist in Ex-Im's Data Systems Used to
Calculate Ex-Im's Small Business Financing:
Two internal control weaknesses exist in Ex-Im data systems used to
calculate and report on Ex-Im's small business financing. Three
databases are relevant to Ex-Im's small business financing calculation-
-two store information on companies involved in the transactions, and a
third integrates information from these databases and performs the
actual calculation.
First, Ex-Im's electronic data systems used to calculate its small
business support do not contain complete or up-to-date information on
companies' small business status. As a result, to obtain the most
current information for these companies, Ex-Im officials must identify
and locate their paper transaction files. As discussed above, while Ex-
Im's paper files generally supported its small business designation, we
found a significant number of discrepancies between Ex-Im's paper and
electronic files. We found that Ex-Im's electronic data systems had no
small business designation for 350 (or 66 percent) of the 531 companies
we examined that had received medium-or long-term loans or guarantees.
According to Ex-Im officials, if a company's small business designation
is left blank, they do not credit any part of the transaction as
benefiting small business. Ex-Im also does not consistently maintain
the latest information in the databases. Ex-Im officials told us they
had not performed a general update of the company records since
September 2004.[Footnote 18]
Second, Ex-Im's data systems sometimes contain conflicting information
for the same company. Ex-Im maintains information about insurance
transactions and participants in one data system and information about
loans and guarantee transactions and participants in another data
system. According to Ex-Im, updating information in a company's record
(including its small business designation) in one database does not
update the company's record in the other database. As a result, the two
databases can, and in some cases do, have conflicting information about
the same company. Our analysis identified 34 companies[Footnote 19]
involved in about 180 transactions that were treated as small
businesses in some transactions and as nonsmall businesses in other
transactions.
Weaknesses Exist in Ex-Im's System for Estimating Small Business
Financing When the Exporter Is Not Immediately Knowable:
We found weaknesses in Ex-Im's system for developing estimates of small
business financing where the exporter is not known at the time Ex-Im
authorizes the transaction, which applied to about one-third of Ex-Im's
total small business financing for fiscal year 2004. These weaknesses
are a function of Ex-Im's methodology, which focuses on the authorized
value of transactions, and Ex-Im's implementation of its methodology.
First, Ex-Im's estimates may not accurately reflect the amount of small
business financing under bank-held insurance policies because of large
differences between the amounts authorized and actually shipped under
these policies. For both fiscal years 2004 and 2005, the value of
shipments under bank-held insurance policies was a fraction of the
total authorized value of the bank-held insurance policies. For
example, according to Ex-Im records, they authorized $3.4 billion of
bank-held insurance transactions for fiscal year 2004, but there were
only $280 million in shipments under bank-held insurance policies in
the first 6 months of the fiscal year. Ex-Im applied its estimate of
the small business share of transactions, based on these shipments, to
the $3.4 billion of bank-held insurance policies it authorized during
the year, and determined that about $720 million of the authorized
value of bank-held insurance policies during the year directly
benefited small business. Thus, this method results in estimates of
small business shares for the authorized value of these types of
transactions that are based on a very small share (about 8 percent) of
the total authorized value. Ex-Im officials stated that the difference
between amounts authorized and amounts actually shipped can be very
large because banks sometimes want as much flexibility as possible in
the amount of insurance they can provide and request that Ex-Im
authorize large policies. Ex-Im officials acknowledge that, as a
result, the total authorized value of bank-held insurance transactions
can be significantly greater than the value of shipments under these
policies.
Second, Ex-Im classifies the small business status of a significant
portion of the companies making shipments as "unknown" and excludes
them from its calculation of the estimate of its small business
support. For the $280 million of shipments under bank-held insurance
discussed above, an Ex-Im official reviewed the data and classified
about $128 million (or nearly half) as shipments by companies whose
small business status was "unknown." It then excluded these shipments
from its calculation of total shipments.
For credit guarantee facilities, which account for about 1 percent of
Ex-Im's small business financing, Ex-Im's system for calculating its
small business share led to errors. Specifically, Ex-Im relies on an
automated system, which classifies a company's small business status as
"unknown" unless it finds an exact match in Ex-Im's company records,
for identifying the small business status of companies shipping under
these policies. Within the companies classified as "unknown" are some
clearly large, easily recognized companies. No Ex-Im official reviews
the results of these automated classifications, so these companies are
not included in the calculation. Ex-Im officials stated that, since
credit guarantee facilities account for such a small portion of Ex-Im's
overall small business financing, errors in its estimation of the small
business share of these transactions would not materially affect Ex-
Im's reporting on its total small business financing.
Third, as is the case with calculations when the exporter is known, Ex-
Im, at times, inconsistently identifies the small business status of
the same company in its estimates when the exporter is not known at the
time Ex-Im authorizes the transaction. For example, in comparing Ex-
Im's classification of companies' small business status in its separate
analyses of shipments under bank-held insurance and credit guarantee
facilities, we found that Ex-Im inconsistently coded the small business
status of a company exporting solar turbines. In one analysis, Ex-Im
designated the company as a nonsmall business, but in another analysis
Ex-Im designated the company's small business status as "unknown" and
excluded it from its calculation. Excluding this company increased Ex-
Im's estimate of small business support for one type of transaction for
the year.
Ex-Im's Reporting on the Number of Transactions Directly Benefiting
Small Business Includes Transactions That Do Not Benefit Small
Business:
Ex-Im is also statutorily required to report on the number of its
authorized transactions that directly benefit small business; we found
that Ex-Im's reported tally includes some transactions that do not
benefit small business. In recent years, Ex-Im has frequently reported
that about 85 percent of its authorized transactions directly benefit
small business. For instance, in fiscal year 2004, it reported that
2,572 (or 83 percent) of its authorized transactions directly supported
small businesses. This count was based on counting all six credit
guarantee facilities and 698 bank-held insurance policies as directly
benefiting small business. While many of these transactions may
directly benefit small business, they do not all directly benefit small
business, as evidenced by the fact that Ex-Im's own estimate showed
that about 20 percent of the value of bank-held insurance policies
directly benefited small business.
Ex-Im's Interpretation of the Small Business Financing Mandate:
Prior to the enactment of credit reform legislation, Ex-Im interpreted
the mandate as requiring it to make available for financing small
business exports an amount equal to the legislatively established
percent of the aggregate principal amount of loans, guarantees and
insurance specified by Congress for that fiscal year. Given changes in
law over time, Ex-Im currently interprets the small business financing
mandate as requiring Ex-Im to attempt to ensure that 20 percent of the
value of its transactions is provided directly to small business. As a
result of credit reform legislation and related changes in law, Ex-Im
cannot precisely determine at the beginning of the year its "aggregate
loan, guarantee, and insurance authority available," for the purpose of
setting aside a certain percentage of that authority for small
business, as originally intended under the requirement.
Ex-Im's Current Interpretation of the Mandate:
Given the changes in law over time, Ex-Im's current interpretation of
the small business financing mandate is that it must attempt to ensure
that 20 percent of the value of all the transactions Ex-Im authorizes
during a year directly benefits small business. Ex-Im's approach for
implementing the requirement is to divide the dollar value of
authorized transactions directly benefiting small business by the
authorized dollar value of all transactions, as described above, and
monitor this proportion throughout the year, aiming to reach 20
percent.
According to Ex-Im's officials, this approach is consistent with (1)
congressional intent in establishing the small business requirement,
(2) the demand-driven nature of Ex-Im's operations, and (3) the broader
mandate of Ex-Im's authorizing legislation. First, Ex-Im's General
Counsel stated that, in establishing the requirement, Congress
generally intended to ensure that a specified percentage of Ex-Im's
loan, guarantee, and insurance authority be available for small
businesses.[Footnote 20] At the time the requirement was created,
Congress exercised control over Ex-Im's financing by establishing
specific dollar limitations (in annual appropriations acts) on the
value of transactions Ex-Im could approve during the year. Thus,
according to Ex-Im, doing the calculation on the basis of the
authorized value of transactions is reasonable based on the legislative
history of the provision.
Second, Ex-Im officials stated that Ex-Im interprets and implements the
small business requirement in the broader context of Ex-Im's operation
as a demand-driven institution that provides financing to U.S.
exporters who apply for Ex-Im financing. Because of the demand-driven
nature of its business, Ex-Im has limited control over how much
financing U.S. exporters apply for each year or, consequently, how much
financing it provides during the year. Third, Ex-Im also implements the
small business financing requirement in the broader context of Ex-Im's
other legislative mandates to support U.S. exports and increase
domestic employment. Moreover, Ex-Im officials stated that, under Ex-
Im's approach to implementing the requirement, it has never had to turn
down a small business transaction due to a lack of funds.
Changes in Law Have Occurred Since Original Enactment of the
Requirement:
Circumstances have changed since the small business financing
requirement was enacted that have affected how Ex-Im implements it.
Specifically, the removal of a direct congressional cap on annual Ex-Im
financing and enactment of the Federal Credit Reform Act of 1990
changed how Congress exercised control over Ex-Im's financing
activities.[Footnote 21] Prior to credit reform, Ex-Im interpreted the
mandate as requiring it to make available for financing small business
exports an amount equal to 10 percent of the aggregate principal amount
of loans, guarantees and insurance specified by Congress for that
fiscal year. Following the implementation of credit reform, the
authority available, or the amount of financing Ex-Im can provide
during a year, is determined by the amount of subsidy appropriation Ex-
Im receives from Congress and the estimated subsidy cost to the
government of each transaction.[Footnote 22] Some transactions do not
require a subsidy (or even make money), so the subsidy appropriation
covers the expected total net losses of all transactions during the
year. Thus, for the same amount of subsidy appropriation, Ex-Im could
provide different amounts of total financing depending on the
characteristics of the transactions it authorizes. It could authorize
relatively few large, but risky transactions, or it could authorize
many smaller, less risky transactions.
At the time the small business financing requirement was enacted,
Congress had historically specified in annual appropriations acts the
total principal amount of loans and guarantees that Ex-Im could
provide. Ex-Im could then make available for financing small business
exports an amount equal to the required percentage, regardless of the
actual budget authority utilized by Ex-Im by the end of the year. In
these circumstances, Ex-Im could easily determine how much financing it
needed to make available for small business to satisfy the
requirement.[Footnote 23] However, in 1994 (and subsequent years),
Congress did not specify any limitation on the total principal amount
of loans, guarantees, and insurance that Ex-Im could provide during the
year. As a result, Ex-Im no longer has a specific, pre-determined,
amount from which it could calculate the required percentage to be made
available for small business financing.
Conclusions:
While Ex-Im generally classifies companies' small business status
correctly, we identified several areas for improvement related to the
processes and data it uses to determine and report on its support of
small business. We observed a variety of weaknesses related to Ex-Im's
calculation of its small business support, ranging from data system
weaknesses that may affect only a few transactions per year to
shortcomings in Ex-Im's system for estimating about one-third of its
small business financing annually. While we did not determine whether
these weaknesses result in Ex-Im overstating or understating the value
of its small business financing, improvements are needed to address
internal control weaknesses and improve the reliability of Ex-Im's
reporting on its small business financing. With more reliable data and
data systems, Ex-Im could more effectively and accurately report to
Congress regarding the number of its transactions that directly benefit
small business and their progress toward meeting the 20 percent small
business financing mandate.
Recommendations for Executive Action:
To improve the reliability of Ex-Im Bank reporting on its direct
support for small business we recommend that the Chairman of the Export-
Import Bank take the following four steps:
* improve the completeness, accuracy, and consistency of the data Ex-Im
maintains on its customers, especially with regard to their small
business status;
* improve the system for estimating the value and proportion of direct
small business support for those transactions where the exporter is not
known at the time Ex-Im authorizes the transaction;
* more accurately determine and clearly report the number of
transactions that directly benefit small business; and:
* have its external auditor audit Ex-Im's annual legislatively-mandated
reporting of its direct support for small business as a part of its
review of Ex-Im's compliance with laws and regulations.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Export-Import Bank of the
United States. Ex-Im commented that the review helped reaffirm its
methodology and identify areas where it can improve its efficiency. It
generally concurred with our recommendations and identified several
actions it is taking or will take that address them. Ex-Im stated that
a new on-line application system that it is implementing will include
updating electronic participant records and that it is strengthening
its internal controls regarding small business status. Ex-Im also
stated that its new on-line system will improve its information base
regarding small business designations when the exporter is not known at
the time of authorization. Ex-Im further stated that it is arranging
for an independent audit of its direct small business reporting. With
respect to its reporting on the number of its transactions directly
supporting small business, Ex-Im stated its view that it has a sound
methodology for counting transactions made available for the direct
support of small business exporters. We believe greater clarity is
needed in Ex-Im's reporting of this measure. Ex-Im's official comments
are reprinted in appendix IV.
We are sending copies of this report to the Chairman of the Export-
Import Bank, appropriate congressional committees, and other interested
parties. We will also make copies available to others upon request. 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 [Hyperlink, YagerL@gao.gov]. Contact
points for our Offices 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 V.
Sincerely yours,
Signed by:
Loren Yager:
Director, International Affairs and Trade:
[End of section]
Appendixes:
Appendix I: Objectives, Scope, and Methodology:
The Chairman of the House Committee on Small Business requested that we
review legal and policy issues related to the Export-Import Bank's (Ex-
Im) support for small business. This report (1) analyzes Ex-Im's
methodology for calculating its direct support of small business and
the reliability of Ex-Im's data used in the methodology and (2)
describes Ex-Im's legal interpretation of its requirement under the
statutory 20 percent small business mandate. In addition, it includes
information on Ex-Im's efforts to monitor and track its small business
financing (see app. II) and how Ex-Im estimates the share of its
financing that indirectly supports small business (see app. III).
To analyze Ex-Im's methodology for calculating its direct support for
small business and the reliability of the data used in the calculation,
we interviewed knowledgeable Ex-Im staff, reviewed Ex-Im documentation
regarding the calculation, and analyzed data on Ex-Im transactions and
participants from fiscal years 2004 and 2005. To review the operation
of Ex-Im data systems involved in the calculation of small business
financing, we interviewed knowledgeable Ex-Im officials and staff from
Ex-Im's external auditor (Deloitte & Touche), reviewed annual audit
reports of Ex-Im's financial statements, viewed a demonstration of the
data systems, and obtained detailed and summary data related to
transactions from fiscal years 2004 and 2005. We performed basic
electronic tests of the data's reliability, including determining
whether the data fell within the expected time periods, contained the
types of transactions we expected, and were generally comparable to Ex-
Im's summary data from its Annual Reports. On this basis, we determined
that the data were sufficiently reliable for our use in further
analysis. We then identified the individual companies involved in Ex-Im
transactions and analyzed data on companies' industry classifications
(Standard Industrial Classification [SIC]), number of employees, and
annual revenues. We also reviewed Ex-Im's electronic records for
companies receiving financing in fiscal years 2004 and 2005 to identify
whether there were any instances where Ex-Im's small business
designation for the same company differed in the insurance and loan and
guarantee databases. We identified the Small Business Administration's
(SBA) "size standard" for each company based on the SIC code in Ex-Im's
electronic records and applied the SBA methodology to Ex-Im's
electronic company records to determine how frequently Ex-Im's decision
regarding companies' small business status was supported by the data in
Ex-Im's databases.
To test whether Ex-Im's classification of companies' small business
status is accurate, we drew a stratified random probability sample of
300 companies from a population of 2,755 companies receiving Ex-Im
financing[Footnote 24] in fiscal years 2004 or 2005, stratified by type
of transaction. We developed our list of 2,755 companies from a
transaction-level data set provided to us by Ex-Im by identifying all
unique company identification numbers and then checking to ensure that
there was no repetition of company names across the identification
numbers. We stratified the population into three types of transactions:
loans and guarantees, nonbank-held insurance, and working capital
guarantees. We obtained data regarding the sampled companies' industry
classification, employment, and revenues from a commercial information
vendor, Dun and Bradstreet (D&B), which Ex-Im also uses to update its
company records.[Footnote 25] We obtained 269 credible matches based on
searches either for each company's DUNS number or name. We then applied
the SBA "size standards" to the Dun and Bradstreet data for these
companies to determine whether they qualify as small businesses. We
then compared these results to Ex-Im's small business designation for
each company. Three potential limitations could affect this analysis:
(1) the D&B data may be inaccurate or outdated, (2) companies' small
business status may have changed between the time Ex-Im authorized the
transaction (2004 or 2005) and when we obtained the D&B data (December
2005), and (3) Ex-Im's small business designation may have been based
on data not available to D&B.
With our probability sample, each member of the study population had a
nonzero probability of being included and that probability could be
computed for any member. Each sample company was subsequently weighted
in the analysis to account statistically for all the companies in the
population, including those who were not selected. Most estimates
provided in this report apply only to the subset of companies for which
we were able to obtain enough credible matching information in the D&B
data to determine a classification into small or nonsmall.
Because we followed a probability procedure based on random selections,
our sample is only one of a large number of samples that we might have
drawn. Since each sample could have provided different estimates, we
express our confidence in the precision of our particular sample's
results as 95 percent confidence intervals (e.g., plus or minus 7
percentage points). These are intervals that would contain the actual
population values for 95 percent of the samples we could have drawn. As
a result, we are 95 percent confident that each of the confidence
intervals in this report will include the true values in the study
population.
We also reviewed a selection of the 61 companies identified from our
statistical sample for which Ex-Im's small business designation did not
match the designation based on applying the SBA methodology to the D&B
data. This selection included companies involved in medium-and long-
term loans and guarantees, working capital transactions, and nonbank-
held insurance transactions. For these companies, we reviewed Ex-Im's
paper transaction files to (1) identify whether Ex-Im designated the
company as a small business and (2) determine what supporting
documentation existed regarding Ex-Im's designation.
To determine the reliability of Ex-Im's estimates of small business
financing when the exporter is not known at the time of the
transaction, we interviewed Ex-Im staff and analyzed Ex-Im's data for
fiscal years 2004 and 2005. Our review of the data included verifying
Ex-Im's calculation, comparing Ex-Im's classification of companies'
small business status in different Ex-Im data sets, and reviewing the
names of companies to identify obvious classification errors. We also
compared the value of the shipments in these analyses with the value of
these types of transactions as reported in Ex-Im's Annual Reports.
To describe Ex-Im's legal interpretation of its statutory small
business financing mandate, we reviewed the statutory provision and its
legislative history, reviewed other relevant legal documents, and
interviewed Ex-Im legal staff, including the Acting General Counsel,
regarding their interpretation.
To review Ex-Im's efforts to monitor and track its small business
financing, we obtained Ex-Im reports and interviewed Ex-Im staff.
To examine how Ex-Im estimates the share of its financing that
indirectly supports small business, we obtained documents detailing Ex-
Im's estimates and interviewed Ex-Im staff regarding the methodology
for developing the estimates.
We conducted our work from June 2005 to January 2006 in accordance with
generally accepted government auditing standards.
[End of section]
Appendix II: Information on Ex-Im's Monitoring and Tracking of Its
Small Business Financing:
The Export-Import Bank (Ex-Im) monitors and tracks the proportion of
its financing that directly benefits small business, and thus its
progress toward meeting the small business financing requirement, using
reports produced by electronic databases maintained by Ex-Im staff. One
tool is a standard report generated by an electronic Ex-Im database
that details the number, amount, and proportion of Ex-Im transactions
that directly benefit small business. In addition, Ex-Im's Office of
the Chief Financial Officer produces a monthly financial report that
compiles a variety of data, including the amount and proportion of Ex-
Im's financing that directly benefits small business.
Ex-Im Uses Electronic Databases to Produce Up-to-Date Data on Small
Business Financing:
Ex-Im uses a "canned" report produced by an Ex-Im database that pulls
information from multiple other Ex-Im databases. This database
integrates information, including data relating to specific
transactions and information related to the companies participating in
each transaction. Ex-Im officials told us this database is updated each
night. The report breaks down Ex-Im's financing for the year-to-date
into five categories of transactions--medium-and long-term loans and
guarantees, credit guarantee facilities, working capital, bank-held
insurance, and nonblank-held insurance. For each category, the report
includes summary data on the number, amount, and proportion of Ex-Im
transactions that directly benefit small business for the year-to-
date.[Footnote 26]
Ex-Im's Monthly Financial Reports Compare Its Small Business Financing
to the Legislative Mandate:
Ex-Im also monitors and tracks its small business financing in a
monthly financial report produced by the Office of the Chief Financial
Officer. According to the Chief Financial Officer, this report is a key
management tool and contains data on a variety of issues relevant to Ex-
Im management, including small business financing. Specifically with
regard to small business, it includes data on the dollar value of
transactions authorized that directly benefit small business and the
percentage this represents of total transactions. The report indicates
that the "Small Business Target" is 20 percent and measures Ex-Im's
actual performance against this "target."
[End of section]
Appendix III: Information on How Ex-Im Estimates Its Indirect Support
of Small Business:
The Export-Import Bank's (Ex-Im) authorizing legislation requires it to
estimate its indirect support of small business. To meet this
requirement, Ex-Im analyzes a subset of transactions and uses multiple
sources of information to develop its estimate.
Ex-Im's Authorizing Legislation Requires It to Estimate Its Indirect
Support of Small Business:
Ex-Im's authorizing legislation[Footnote 27] requires it to estimate
its indirect support for small business. Specifically, it requires Ex-
Im to "estimate on the basis of an annual survey or tabulation the
number of entities that are suppliers of users of Ex-Im and that are
small business concerns." Ex-Im then reports this information in its
Annual Report. Ex-Im officials emphasized that (in contrast to the
legislative requirement related to Ex-Im's direct support of small
business) this requirement only necessitates Ex-Im report an estimate
of its indirect support of small business rather than a precise
calculation. They further noted that the requirement provides
significant leeway regarding how to gather and report this information.
For instance, they said that since the requirement refers to a "survey
or tabulation" they infer that Congress intended for Ex-Im to rely on
its customers to provide estimates to Ex-Im.
Ex-Im's Rationale and Methodology for Estimating Its Indirect Support
of Small Business:
Resource considerations were the key factor in Ex-Im's rationale for
developing a methodology to estimate its indirect support of small
business. Ex-Im officials said they did not want to devote a
significant amount of resources to developing the information because,
regardless of the amount of resources expended, it would still only be
an estimate. Similarly, Ex-Im recognized that it would rely on its
customers to provide information to develop the estimate and wanted to
minimize the burden on the customers.
To establish a methodology, Ex-Im officials decided to examine a subset
of Ex-Im transactions, based on the term (i.e., short-term, medium-
term, or long-term) of the financing. Ex-Im considered analyzing the
indirect support for small business from all the short-term
transactions for the year. However, there are a large number (about
1,900 in fiscal year 2004) of these transactions, so analyzing them all
would require a significant amount of resources. Additionally, a high
percentage of short-term transactions directly benefit small business,
so an analysis of these transactions would yield an unrealistically low
amount of indirect support for small business. Ex-Im also considered
analyzing medium-term transactions, but since there are a large number
of such transactions (about 700 in fiscal year 2004), such an analysis
would still take a significant amount of resources. Therefore, Ex-Im
decided to analyze the indirect small business support resulting from
its long-term transactions. Ex-Im officials told us that analyzing long-
term transactions is appropriate because (1) there are a small number
of such transactions each year (42 in fiscal year 2004), (2) the
analysis would yield a "well-rounded" view of Ex-Im's total support for
small business when combined with its data on its direct support of
small business, and (3) long-term transactions account for a
significant share of the value of Ex-Im's financing each year ($7.3
billion, or nearly half of the value of all transactions for fiscal
year 2004).
Ex-Im officials said they have been estimating Ex-Im's indirect support
of small business since the 1980s and use three sources of information
to develop their estimate. These three sources of information are the
following:
* Information directly from the primary exporter: Some of Ex-Im's
customers compile and provide data directly to Ex-Im regarding their
small business suppliers. According to Ex-Im officials, this happens
most frequently when the company is a large and well-established
company and collects a significant amount of information from its
suppliers. For instance, Boeing (a frequent Ex-Im customer) maintains a
variety of data on its suppliers and subcontractors and reports this
information to Ex-Im. According to Ex-Im, it based its estimate of
indirect support of small business solely on information directly from
the primary exporter for 19 of 42 long-term transactions for fiscal
year 2004.
* Ex-Im analysis of the exporter's list of subcontractors or sub-
suppliers: For each long-term transaction, Ex-Im customers must submit
a list of major contractors. The Ex-Im official assigned to the
transaction reviews this list and, among other things, identifies which
of the companies on the list is a small business by checking data on
each company's sales and employment in the Dun and Bradstreet database.
According to Ex-Im, it based its estimate of indirect support of small
business solely on its analysis of the exporter's list of major
contractors for 5 of 42 transactions for fiscal year 2004.
* Ex-Im officials' judgment: Ex-Im officials sometimes must use their
judgment to estimate the amount of indirect support for small business
associated with a transaction. According to Ex-Im officials, the Ex-Im
official assigned to the transaction can use his or her knowledge of
the exporter (including any past history of its indirect support of
small business), industry (including industry benchmarks regarding
small business contracting), and the specific details of the
transaction. According to Ex-Im, it based its estimate of indirect
support of small business solely on an Ex-Im officials' judgment for 10
of 42 transactions for fiscal year 2004.
According to Ex-Im, for some transactions, it estimates the amount of
indirect support for small business using a combination of sources of
information. For example, for fiscal year 2004, Ex-Im estimated the
indirect support of small business for four transactions based on a
combination of information directly from the primary exporter and Ex-
Im's analysis of the exporter's list of subcontractors or subsuppliers.
For four other transactions in fiscal year 2004, Ex-Im estimated the
indirect support for small business based on a combination of Ex-Im's
analysis of the exporter's list of subcontractors or subsuppliers and
an Ex-Im official's judgment.
[End of section]
Appendix IV: Comments from the Export-Import Bank:
EXPORT-IMPORT BANK OF THE UNITED STATES:
JAMES H. LAMBRIGHT:
CHAIRMAN AND PRESIDENT (ACTING):
February 22, 2006:
Loren Yager:
Director, International Affairs and Trade:
U.S. Government Accountability Office:
Washington, D.C. 20548:
Dear Mr. Yager:
Thank you for providing the Export-Import Bank of the United States
("Ex-Im Bank") with the opportunity to comment on GAO's February 6,
2006 draft report.
We are pleased that GAO has concluded that Ex-Im Bank "generally
classifies small business status correctly." As we have conveyed to
your team throughout the course of this review, Ex-Im Bank has a
transparent and reliable methodology for determining our customers'
small business status and reporting our direct support for small
business.
Ex-Im Bank very much appreciates GAO's cooperative approach to the
small business review. This has been a very positive exercise for Ex-Im
Bank, both in terms of reaffirming our methodology and from the
perspective of identifying areas in which Ex-Im Bank can improve the
efficiency with which we determine and report our direct small business
support.
The following are Ex-Im Bank's responses to GAO's recommendations:
1. "Improving the completeness, accuracy and consistency of the data Ex-
Im maintains on its customers, especially with regard to their small
business status."
In conjunction with the introduction of our Ex-Im Online platform, Ex-
Im Bank is in the process of updating electronic participant records
for FY 2006. Complete data on all exporters will be entered into the
electronic participant file, including name, address, sales, number of
employees, and SIC code. Ex-Im Bank is also strengthening our internal
controls to require dual signoff when determining small business status
of our customers.
2. "Improving the system for estimating the value and proportion of
direct small business support for those transactions where the exporter
is not known at the time Ex-Im authorizes the transactions."
Ex-Im Online will have a direct feed from Dun and Bradstreet, which
will result in the Bank receiving timely updates of participant file
data. This increases the base of information to support the small
business authorizations for the transactions where the exporter is not
known at the time of authorization. If the systemic review does not
result in classification of an exporter's status, then Ex-Im Bank will
manually review and input the appropriate status into the participant
file. This should result in a refined ratio to be applied to the CGF
and Bank-Held authorizations.
3. "Accurately determining the number of transactions that directly
benefit small business."
Ex-Im Bank has a sound methodology for counting transactions that are
made available for the direct benefit of small business exporters.
Historically, the actual number of direct small business transactions
attributable to credit guarantee facilities and bank-held insurance
policies has exceeded the number of authorizations.
4. "Having its external auditor audit Ex-Im Bank's annual legislatively-
mandated reporting of its direct support for small business as a part
of its review of Ex-Im Bank's compliance with laws and regulations."
We are arranging for an independent external audit of Ex-Im Bank's
direct small business reporting starting with FY 2006.
Ex-Im Bank is prepared to work with Congress in our upcoming
reauthorization to make changes that, consistent with Ex-Im Bank's
broad mission and resources, position the Bank to maximize support for
U.S. small business exports.
Sincerely,
Signed by James H. Lambright:
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Loren Yager (202) 512-4347:
Staff Acknowledgments:
In addition to the individual named above, Celia Thomas (Assistant
Director), Jason Bair, Eugene Beye, David Dornisch, Ernie Jackson, and
Bill Tuceling made key contributions to this report. Joe Carney, Carlos
Diz, and Etana Finkler also provided editorial, technical, and graphics
support.
(320361):
FOOTNOTES
[1] 12 U.S.C. 635 et seq.
[2] Ex-Im also provides a small number of direct loans, which are
primarily used to offer concessionary financing to U.S. exporters to
match concessionary financing by other countries' export credit
agencies. For additional information regarding Ex-Im products, see Ex-
Im's official Web site at http://www.exim.gov.
[3] One specific type of loan guarantee is a credit guarantee facility.
Credit guarantee facilities are lines of credit between a bank or
corporation in the United States and a foreign bank (or occasionally a
large foreign buyer). Ex-Im Bank guarantees the repayment of the
foreign bank's obligations. The foreign bank then makes credit
available to the end user of the U.S. exports and takes the repayment
risk of that local company.
[4] For the bank-held insurance policies, Ex-Im authorizes the policy
for the bank, which does not know at the time it applies for the
financing which exporters will eventually use the export credit
insurance.
[5] Pub. L. No. 98-181. The law provided for this percentage to
increase from 6 percent in fiscal year 1984 to 10 percent in 1986 and
thereafter.
[6] Pub. L. No. 107-189.
[7] 12 U.S.C. 635g.
[8] NAICS was developed jointly by the United States, Canada, and
Mexico to provide comparability in statistics about business activity
across North America.
[9] For bank-held insurance policies, Ex-Im analyzes data on shipments
during a 6-month period. For credit guarantee facilities, Ex-Im
analyzes data on shipments from the previous year.
[10] Our review of Ex-Im's shipment data for the first 6 months of 2004
and 2005 identified one company that exported products using Ex-Im
financing through the bank that received this financing. That company
made four shipments totaling approximately $20 million during these two
6-month periods, and is classified in Ex-Im's records as a nonsmall
business. We did not identify any shipments by small businesses under
this policy.
[11] The term "small business designation" refers to the decision
regarding whether or not a company qualifies as a small business.
[12] We are 95 percent confident that the percentage of cases where Ex-
Im's small business designation differs from the designation that would
result from applying the SBA methodology to D&B data ranges from 13 and
22 percent. This estimate and the estimates for specific transaction
types below apply only to the portion of companies for which we were
able to obtain D&B data. For more on our sampling methodology, see
appendix 1.
[13] We also reviewed 1,831 cases where Ex-Im's electronic data system
had enough information to apply the SBA definition, and we found that
Ex-Im's small business designation was not supported by Ex-Im's data on
sales and employees in 191 instances, or just over 10 percent of the
time. In the majority (157) of these cases, the SBA methodology would
have classified the companies as small businesses, but Ex-Im had
designated the companies as nonsmall businesses.
[14] We are 95 percent confident that the percentage of companies in
the Ex-Im database for which there is credible matching D&B data ranges
from 86 percent to 93 percent.
[15] The 95 percent confidence interval for these estimates ranges from
5 to 18 and 5 to 19 percent, respectively.
[16] The 95 percent confidence interval surrounding this estimate
ranges from 40 to 60 percent.
[17] For one of these 19 companies, Ex-Im's designation of the
company's small business status was incorrect based on data in the
paper file.
[18] Ex-Im officials said they are updating companies' records in
advance of the conversion to a new data system.
[19] This is out of about 3,000 companies that received Ex-Im financing
in fiscal years 2004 or 2005.
[20] The legislative history of the 1983 provision creating the small
business financing requirement focused on providing a specific
percentage of the value of Ex-Im's transactions to small business. See
H. Conf. Rep. No. 107-487, 107th Cong., 2ND Sess. (2002); H. Rep. No.
107-292, 107th Cong., 1st Sess.
[21] Pub. L. No. 101-508.
[22] The estimated cost of a transaction is the net present value of
the estimated payments by the government (e.g., loan disbursements)
minus the estimated payments to the government (e.g., loan repayments
and fees).
[23] For example, for fiscal year 1993, Congress imposed a limitation
of $15.5 billion on "gross obligations for the principal amount of
direct loans, and tied-aid grants, and total loan principal, any part
of which is to be guaranteed, including insurance" that Ex-Im could
authorize during the fiscal year. Accordingly, Ex-Im interpreted the
small business financing requirement (10 percent at the time) as
requiring it to make available 10 percent of $15.5 billion, or $1.55
billion, for loans, guarantees, and insurance for small business.
[24] For this analysis, we excluded companies involved in only bank-
held insurance or credit guarantee facility transactions because the
amount of small business credit Ex-Im takes for these transactions does
not depend on the small business status of the company that obtains the
financing.
[25] We did not review the reliability of D&B's data.
[26] The database calculates the share of the value of transactions
directly benefiting small business in the same manner as was discussed
earlier in this report.
[27] 12 U.S.C. 635g(d).
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