This is the accessible text file for GAO report number GAO-07-1071 
entitled 'Export-Import Bank: Improvements Needed in Assessment of 
Economic Impact' which was released on October 15, 2007. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as part 
of a longer term project to improve GAO products' accessibility. Every 
attempt has been made to maintain the structural and data integrity of 
the original printed product. Accessibility features, such as text 
descriptions of tables, consecutively numbered footnotes placed at the 
end of the file, and the text of agency comment letters, are provided 
but may not exactly duplicate the presentation or format of the printed 
version. The portable document format (PDF) file is an exact electronic 
replica of the printed version. We welcome your feedback. Please E-mail 
your comments regarding the contents or accessibility features of this 
document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

September 2007: 

Export-Import Bank: 

Improvements Needed in Assessment of Economic Impact: 

Export-Import Bank: 

GAO-07-1071: 

GAO Highlights: 

Highlights of GAO-07-1071, a report to congressional requesters. 

Why GAO Did This Study: 

Congress established the Export-Import Bank of the United States (Ex-
Im) to encourage U.S. exports. Congress has directed Ex-Im to consider 
the economic impact of its work and not to fund activities that will 
adversely affect U.S. industry. In this context, GAO reviewed (1) Ex-
Im’s policies and procedures for determining economic impact, (2) the 
extent to which Ex-Im appropriately identifies and analyzes projects 
that could cause adverse economic impact, and (3) the extent to which 
Ex-Im’s process is transparent. To conduct this work, GAO reviewed Ex-
Im’s procedures, data on projects applicable for the economic impact 
process, and detailed economic impact analyses. GAO also interviewed Ex-
Im and reviewing agency officials and industry representatives. 

What GAO Found: 

Congress requires Ex-Im to assess whether a project requesting its 
financial support will negatively impact U.S. industry. Ex-Im uses a 
screening process to identify projects with the most potential to have 
an adverse economic impact, and then subjects the identified projects 
to detailed analysis. A negative finding could result in a denial of Ex-
Im support. The screens—either explicitly required by Ex-Im’s charter 
or introduced under the bank’s statutory authority—include whether (1) 
the financed project will increase foreign production, (2) there are 
trade measures against the resulting product, (3) the resulting product 
is “undersupplied,” (4) the requested financing is over $10 million, 
and (5) the financed project will increase foreign production by 1 
percent or more of U.S. production. Between fiscal years 2003 and 2005, 
this screening process identified 20 projects (out of 771 applicable) 
that required a detailed economic impact analysis. In the detailed 
analysis, Ex-Im assesses whether the resulting product would be in 
surplus on world markets or in competition with U.S. production. 
Between fiscal years 2003 and 2005, Ex-Im approved most projects 
applicable for economic impact analysis, totaling approximately $6.1 
billion in approved financing. 

GAO found challenges and areas for improvement in the screening and 
detailed analysis of projects for economic impact. The effectiveness of 
the $10 million screen, introduced under Ex-Im’s statutory authority, 
is uncertain. Ex-Im has not determined whether it removes from review 
those projects that could meet the statutory definition of substantial 
injury (producing 1 percent or more of U.S. production in an industry). 
For example, a $9.9 million financing request that would allow a 
foreign company to produce an estimated 3.5 percent of U.S. production 
was screened out of the analysis. GAO also found that Ex-Im could 
improve some methods it uses in its detailed analyses, such as how it 
estimates displaced production. In addition, GAO found that Ex-Im could 
clarify how it characterizes the effect of its financing on the U.S. 
trade balance. Finally, GAO found that Ex-Im could strengthen the 
internal controls it uses to ensure that the screening process and 
detailed analysis are conducted consistently and accurately. 

GAO also found limitations in the transparency of Ex-Im’s economic 
impact process. While Ex-Im publicly posts its procedures, they contain 
areas of ambiguity. For example, the procedures do not define the term 
“oversupply.” Also, Ex-Im has not provided all public comments to the 
board of directors. GAO identified two practices—referencing in the 
procedures the list of sectors likely to require extra scrutiny and 
publicizing final economic impact conclusions—that would increase the 
predictability of the process. 

What GAO Recommends: 

To improve the identification and analysis of applications for economic 
impact, GAO recommends that Ex-Im review the $10 million threshold, 
create better methodological guidelines, and strengthen its internal 
controls. To improve transparency, GAO recommends that Ex-Im clarify 
its procedures for conducting economic impact analyses. Ex-Im generally 
concurred with GAO’s recommendations and stated that it will explore 
feasible ways to improve the economic impact process and make it more 
consistent and user-friendly. 

[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-1071]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Loren Yager, 202-512-
4347, YagerL@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Economic Impact Analysis Screening Process Identifies Projects for 
Detailed Analysis: 

Challenges and Limitations Exist in Identifying and Analyzing Projects 
for Economic Impact: 

Transparency of Economic Impact Procedures Has Limitations: 

Conclusions: 

Recommendations: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: List of Detailed Economic Impact Analyses That Ex-Im Began 
between Fiscal Years 2002 and 2006: 

Appendix III: Comments from the Export-Import Bank of the United 
States: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Detailed Economic Impact Analyses and Board of Directors' 
Financing Decisions: 

Table 2: Detailed Economic Impact Analyses, with No Final Board of 
Directors' Decision Because of Transaction Withdrawal: 

Table 3: Detailed Economic Impact Analysis Conducted Postauthorization 
at the Request of the Credit Committee: 

Table 4: Detailed Economic Impact Analysis Conducted Postauthorization 
Pursuant to the Consolidated Appropriations Act of 2004: 

Table 5: Unfinished Detailed Economic Impact Analyses: 

Figures: 

Figure 1: A Conceptual Illustration of How Ex-Im Provides Financing to 
Foreign Companies but Risks Creating a Negative Impact on U.S. 
Producers: 

Figure 2: Ex-Im's Process for Screening Applications, Assigning 
Economic Impact Codes, and Selecting Projects for Detailed Economic 
Impact Analysis: 

Figure 3: Economic Impact Categorization of Ex-Im Applications That 
Were Acted Upon, by Number and Value (Fiscal Years 2003-2005): 

Figure 4: Comparison of Number and Dollar Value by each Economic Impact 
Code for the 525 Approved Applicable Projects (Fiscal Years 2003-2005): 

Abbreviations: 

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

ITA: International Trade Administration: 

ITC: U.S. International Trade Commission: 

OECD: Organisation for Economic Cooperation and Development: 

OMB: Office of Management and Budget: 

USTR: Office of the U.S. Trade Representative: 

United States Government Accountability Office: 

Washington, DC 20548: 

September 12, 2007: 

The Honorable Charles E. Grassley: 
Ranking Member: 
Committee on Finance: 
United States Senate: 

The Honorable Michael Crapo: 
United States Senate: 

Congress established the Export-Import Bank of the United States (Ex- 
Im) in 1934 to support U.S. exports and create jobs for Americans. Over 
time, Congress has recognized that Ex-Im's support of exports by U.S. 
firms in certain sectors could potentially adversely impact U.S. firms 
in other sectors.[Footnote 1] Congress requires Ex-Im to assess whether 
its financial support for a project would likely cause substantial 
injury to U.S. industry or would result in the production of a good 
that is subject to a relevant trade measure. A finding that would lead 
to either of these outcomes could result in a denial of Ex-Im support. 
In reauthorizing Ex-Im in 2002, Congress reiterated its concerns about 
potential adverse economic impacts on U.S. producers by increasing the 
bank's economic impact assessment requirements. Although Ex-Im created 
a multistep process to determine what impact the projects it finances 
could have on the U.S. economy, Congress continued to be concerned that 
these procedures did not ensure that projects were adequately 
identified, analyzed, or disclosed. In December 2006,[Footnote 2] 
Congress again revised the economic impact assessment to require more 
information disclosure. Congress remains interested in how Ex-Im 
assesses the impact that its services have on the competitiveness of 
U.S. producers. 

In this context, we reviewed (1) Ex-Im's overall policies and 
procedures for determining economic impact; (2) the extent to which Ex- 
Im's procedures provide for the identification and appropriate analysis 
of projects that could potentially cause adverse economic impact; and 
(3) the extent to which its policies, procedures, and decisions are 
transparent to interested and affected parties. 

To assess Ex-Im's policies and procedures for identifying applications 
for a detailed economic impact analysis, we obtained and analyzed data 
on applications that were applicable for economic impact analysis from 
fiscal years 2003 through 2005, and discussed these data and Ex-Im's 
screening process with Ex-Im officials. To describe Ex-Im's process for 
conducting detailed economic analyses, we reviewed the 17 economic 
impact analyses that Ex-Im completed between fiscal years 2002 and 2006 
in light of their procedures as they were written in response to the 
2002 reauthorization. We chose 5 detailed analyses to review in greater 
depth, reflecting a range of countries, industries, and economic 
issues. We discussed those analyses with officials from Ex-Im and other 
U.S. government agencies. We also reviewed Ex-Im's updated procedures, 
created in April 2007 in response to the 2006 reauthorization. To 
assess the transparency of Ex-Im's economic impact assessment process, 
we reviewed relevant documentation and interviewed officials from 
agencies that provide comments on Ex-Im's draft economic impact 
analyses and representatives from affected industries. We conducted our 
work from September 2006 through August 2007 in accordance with 
generally accepted government auditing standards. Appendix I contains a 
more detailed description of our objectives, scope, and methodology. 

Results in Brief: 

Ex-Im has established procedures to identify applications for projects 
that have the greatest potential to adversely affect U.S. industry and 
to subsequently conduct detailed analyses of those identified projects. 
All applications are screened for economic impact on the basis of a 
number of criteria either explicitly mentioned in the Export-Import 
Bank Act of 1945, as amended (also referred to as Ex-Im's 
charter)[Footnote 3] or introduced by the bank in the exercise of its 
discretion under the charter. Ex-Im's first screen removes from further 
review applications that do not increase foreign production of an 
exportable good. Then, it screens out applications that would support a 
product subject to trade sanctions, or goods that Ex-Im has deemed to 
be "undersupplied" (oil and gas or diamonds). Next, Ex-Im removes from 
the process applications requesting financing of $10 million or less; 
these projects are reviewed for economic impact in the aggregate after 
the financing is authorized. Finally, Ex-Im conducts a "1 percent test" 
to determine whether financed projects are likely to result in 
"substantial injury." Ex-Im removes from the economic impact process 
those requests to finance projects that would increase foreign 
production by less than 1 percent of U.S. production. Requests to 
finance projects that would increase foreign production by 1 percent or 
more of U.S. production are held for detailed analysis. Between fiscal 
years 2003 and 2005, this screening process identified 20 applications 
for detailed economic impact analysis. In the detailed analysis, Ex-Im 
assesses whether the product that will result from the financing will 
be in surplus on world markets or in competition with U.S. production, 
and estimates a net impact of the transaction on U.S. trade flows. Ex- 
Im also solicits comments from the public and certain U.S. government 
agencies. Between fiscal years 2003 and 2005, Ex-Im ultimately approved 
financing for 525 (or about two-thirds) of the 771 applications that it 
determined through the first screen were applicable for further review, 
totaling approximately $6.1 billion. 

We identified challenges and areas for improvement in Ex-Imís economic 
impact process. Determining the economic impact of financing a project 
is an inherently challenging process that requires defining which 
products and geographic markets will be affected and projecting future 
market trends. Among the screens Ex-Im introduced to identify 
applications for detailed analysis, we found that the screen that 
removes projects involving oil and gas or diamonds from further 
analysis has been effective. However, the effectiveness of Ex-Imís $10 
million screen is uncertain because Ex-Im has not conducted an analysis 
to determine the extent to which the screen identified applications 
whose projects could meet the statutory definition of substantial 
injury (producing 1 percent or more of U.S. production in an industry). 
For example, we learned of a $9.9 million transaction screened out of 
the analysis that would allow a foreign company to produce an estimated 
3.5 percent of U.S. production.[Footnote 4] We also identified areas 
that could be improved in the methods Ex-Im used in its detailed 
analyses. These areas include inconsistencies and limitations in how Ex-
Im has estimated potential costs to U.S. producers from increased 
foreign competition, which can significantly affect estimates of 
negative effects on those producers. In addition, Ex-Imís 
characterization of its financing effect on the U.S. trade balance can 
be clarified. Finally, the internal controls Ex-Im uses to ensure that 
the screening process and the detailed analysis are conducted 
consistently and accurately could be strengthened. 

We found that the transparency of Ex-Im's economic impact process is 
limited.[Footnote 5] While Ex-Im does publicly post its procedures, 
they contain areas of ambiguity. For example, the procedures do not 
define the term "oversupply"--a key factor in the analysis--or when it 
would apply the concept of "proportionality."[Footnote 6] In addition, 
Ex-Im has not provided to the board of directors all public comments 
that it received concerning applications analyzed for economic impact. 
We also identified two practices--referencing the list of sectors 
likely to receive extra scrutiny in the procedures and publicizing 
final economic impact conclusions--that could increase the 
predictability of the process. 

To improve Ex-Im's identification and analysis of applications for 
economic impact, we recommend in this report that the Chairman of the 
Export-Import Bank of the United States (1) review the $10 million 
threshold to determine whether additional steps are needed to mitigate 
the risk of exempting from more detailed review applications that could 
meet the definition of substantial injury (e.g., these steps could 
include selectively reviewing transactions that would affect relatively 
small U.S. industries or sensitive sectors); (2) create specific 
methodological guidelines for staff analyzing applications for economic 
impact, bearing in mind relevant Office of Management and Budget (OMB) 
guidance where appropriate; and (3) improve Ex-Im's internal controls. 
To improve the public transparency of the economic impact process for 
interested and affected parties, we also recommend that the chairman 
(1) clarify publicly available procedures, (2) cite the list of 
sensitive sectors in the economic impact procedures, and (3) publicize 
final economic impact decisions. We provided a draft of this report to 
the Export-Import Bank of the United States. Ex-Im generally concurred 
with our recommendations and stated that it will continue to explore 
feasible ways to improve the economic impact procedures and make the 
process more consistent and user-friendly. 

Background: 

Ex-Im is the official export credit agency[Footnote 7] of the United 
States, and operates under the authority of the Export-Import Bank Act 
of 1945, as amended. It operates as an independent agency of the U.S. 
government with a staff of approximately 370 full-time permanent 
employees. Ex-Im's core mission is to support U.S. exports and jobs by 
providing export financing that is competitive with the official export 
financing support offered by other governments. To accomplish its 
mission, Ex-Im offers a variety of financing instruments, including 
loan guarantees, export credit insurance, and working capital 
guarantees for preexport financing.[Footnote 8] Between fiscal years 
2003 and 2005, Ex-Im processed a yearly average of 3,055 requests for 
loans, guarantees, and insurance.[Footnote 9] Of the processed 
applications, Ex-Im approved an average of 2,981 applications (or 98 
percent) per year. 

In general, Ex-Im's charter prohibits the bank from extending financing 
for a project if doing so will adversely affect U.S. industry.[Footnote 
10] Ex-Im tests for adverse effects by (1) reviewing projects for 
applicable trade sanctions and (2) conducting its own economic impact 
analysis. For this economic impact analysis, the charter provides that, 
if a commodity for export resulting from Ex-Im financing will compete 
with U.S. production of the same, similar, or competing commodity, or 
will be in surplus on world markets at the time of first production, Ex-
Im must determine whether extending the financing will cause 
substantial injury to U.S. producers. (The charter defines "substantial 
injury" as the establishment or expansion of foreign production 
capacity equal to or exceeding 1 percent of U.S. production.) However, 
under its charter, Ex-Im may fund a project if, in the judgment of the 
board of directors, the short-and long-term benefits to industry and 
employment in the United States are likely to outweigh the injury to 
U.S. producers and employment of the same, similar, or competing 
commodity. This can put Ex-Im in the challenging position of balancing 
the interests of two different industries--the industry of the U.S. 
exporter it is financing and the industry that may face additional 
competition as a result of the initial export (see fig. 1). 

Figure 1: A Conceptual Illustration of How Ex-Im Provides Financing to 
Foreign Companies but Risks Creating a Negative Impact on U.S. 
Producers: 

[See PDF for image] 

Source: GAO, Map Resources (map); and Nova Development (clip art). 

[End of figure] 

Economic impact is one of many factors Ex-Im considers when determining 
whether to finance a project. Other factors that Ex-Im must weigh 
include the project's feasibility from an engineering point of view, 
the project's possible environmental impact, whether the project 
involves small business, and the borrower's creditworthiness. 

Other countries, such as Japan and the United Kingdom, also have export 
credit agencies with broad mandates to finance projects that benefit 
their domestic economies. However, unlike Ex-Im, these export credit 
agencies are not required to weigh the potential economic costs to 
domestic industries against the benefits associated with a specific 
financed export. Furthermore, these agencies do not consider the 
relevance of trade measures to a project, as Ex-Im is required to do. 
In its 2005 competitiveness report,[Footnote 11] Ex-Im states that 
having to consider these additional elements, such as the economic 
impact, when deciding whether to finance a project puts Ex-Im at a 
disadvantage compared with other export credit agencies. 

Economic Impact Analysis Screening Process Identifies Projects for 
Detailed Analysis: 

Ex-Im's economic impact analysis screening process is designed to 
identify projects with the most potential to adversely impact U.S. 
industry; Ex-Im then conducts a detailed analysis of those projects. 
Applications are sequentially screened on the basis of criteria 
specified in Ex-Im's charter or established by Ex-Im in the exercise of 
its discretion under the charter. For the applications that receive a 
detailed analysis, Ex-Im assesses whether the products that will result 
from its financing will be in surplus on world markets or in 
competition with U.S. production, and it estimates the net impact of 
the projects on U.S. trade flows. Ex-Im also solicits public and agency 
comments on the potential projects. Between fiscal years 2003 and 2005, 
Ex-Im approved most of the 771 requests to finance projects that 
involved increasing foreign production of an exportable good, and that, 
therefore, passed the first screen and were deemed applicable for 
further economic impact review. 

Ex-Im Uses a Screening Process to Identify Projects for Detailed 
Analysis: 

Ex-Im's economic impact analysis screening process consists of a series 
of rules used to sequentially remove from further economic impact 
review applications for projects it deems unlikely to adversely impact 
U.S. industry. Ex-Im's charter explicitly requires certain screens and 
Ex-Im introduced others, using its discretion under the charter. 
Between fiscal years 2003 and 2005, the screens identified 20 
applications that required a detailed analysis. The screens remove most 
requests from the process because they involve financing of $10 million 
or less; however, Ex-Im reviews those projects postauthorization in its 
Annual Review of Economic Impact. 

Ex-Im's Charter Specifies Some Analytic Screens, Ex-Im Introduced 
Others: 

Ex-Im screens applications for economic impact on the basis of several 
characteristics, some that Ex-Im's charter explicitly requires, others 
that Ex-Im established exercising its discretion under the charter. 
During the screening process, Ex-Im staff in the Policy Analysis 
Division assign an economic impact code to each application. These 
screens are as follows: 

* Foreign production of an exportable commodity. Ex-Im's charter 
requires it to review for economic impact those requests to finance 
projects that would result in increased foreign production. Under Ex-
Im's procedures, only requests financing the export of capital goods or 
services from the United States that might allow a foreign company to 
increase production of an exportable good are subject to further 
scrutiny. This screen removes the bulk of applications from economic 
impact analysis. (Ex-Im codes requests to finance projects that do not 
increase foreign production as "not applicable," or NA.) 

* Trade measures. Ex-Im's charter requires it to consider whether trade 
measures--antidumping or countervailing duty orders[Footnote 12] and 
section 201 injury determinations[Footnote 13]--apply to products that 
would result from Ex-Im financing. According to Ex-Im officials, Ex-Im 
does not fund projects directly subject to trade measures as a matter 
of practice, although it has the authority to do so if the board 
determines that a project's benefits outweigh its costs. This screen 
removes applications whose projects are subject to trade measures not 
just from further economic impact analysis, but from eligibility for Ex-
Im financing. (Ex-Im codes these requests as "trade sanctions," or TS.) 

* Foreign production of oil and gas or diamonds-- "undersupplied" 
products. Ex-Im has determined, with input from other agencies, that 
all projects increasing the foreign production of oil and gas or 
diamonds are unlikely to adversely impact the U.S. economy. This screen 
removes requests to finance projects involving oil and gas or diamonds 
from further economic impact analysis. (Ex-Im codes these requests as 
"undersupplied," or US.) 

* Financing threshold of $10 million. Ex-Im presumes that projects 
requesting financing of $10 million or less are too small to adversely 
impact the U.S. economy. According to a senior Ex-Im official, Ex-Im 
selected $10 million as the threshold because that figure is used for a 
variety of other bank purposes, including whether applications should 
be reviewed by the board of directors or should receive an 
environmental assessment. The official also stated that the use of this 
threshold is reasonable for the economic impact process because $10 
million financing is likely to result in little foreign production and, 
therefore, is not likely to adversely impact the U.S. economy. This 
screen removes applications requesting financing of $10 million or less 
from further economic impact analysis prior to final financing 
decisions (although these requests are subject to an annual review 
after authorization, which we describe later). (Ex-Im codes these 
requests as "annual review," or AR.)[Footnote 14] 

* One percent substantial injury test. Ex-Im's charter requires it to 
conduct a detailed economic impact analysis when a project will cause 
"substantial injury," defined as an increase in foreign production 
greater than or equal to 1 percent of U.S. production of the same or a 
similar good. To conduct this test, Ex-Im calculates a simple ratio of 
the expected increase in foreign production resulting from the project 
to current U.S. production in that industry. Ex-Im's procedures also 
allow for the use of "proportionality" in conducting the 1 percent 
test, which Ex-Im defines as the relation of the dollar value of the Ex-
Im-financed U.S. component of the project to its overall cost.[Footnote 
15] This screen removes applications whose projects would increase 
foreign production by less than 1 percent from further economic impact 
analysis. (Ex-Im codes these requests as "no substantial injury," or 
NSI.) 

The remaining applications are subject to detailed analysis. (Ex-Im 
codes these requests as "hold for analysis," or HA.) See figure 2 for 
information on how Ex-Im categorizes applications throughout the 
screening process. 

Figure 2: Ex-Im's Process for Screening Applications, Assigning 
Economic Impact Codes, and Selecting Projects for Detailed Economic 
Impact Analysis: 

[See PDF for image] 

Source: GAO analysis of Ex-Im Bank data; Nova Development (clip art). 

[A] Numbers are based on Ex-Im data for applications during fiscal 
years 2003 through 2005; procedures are based on the Ex-Im charter 
reauthorized in 2002. 

[B] Ex-Im also codes Credit Guarantee Facilities and Medium Term Risk 
transactions as "annual review," regardless of the transaction's value. 

[End of figure] 

Few Applications Receive a Detailed Analysis: 

The screens Ex-Im uses in its economic impact analysis identify a small 
share of applications for detailed analysis. Between fiscal years 2003 
and 2005, the vast majority of applications was determined not to 
support foreign production of exportable goods and, therefore, was not 
applicable for economic impact analysis. Of the 771 requests that 
involved foreign production of an exportable good and that, therefore, 
were applicable for economic impact analysis, 679 were eliminated from 
the process because they were $10 million or less. Of the remaining 92 
applications, 72 were eliminated by other screens and 20 were held for 
detailed analysis.[Footnote 16] Figure 3 illustrates the composition of 
applications by screening category, both in terms of the number of 
projects and the dollar value of applications. 

Figure 3: Economic Impact Categorization of Ex-Im Applications That 
Were Acted Upon, by Number and Value (Fiscal Years 2003-2005): 

[See PDF for image] 

Source: GAO analysis of Ex-Im Bank data. 

[End of figure] 

Projects Financed for $10 Million or Less Are Reviewed 
Postauthorization: 

At the end of every fiscal year, Ex-Im aggregates projects it financed 
for less than $10 million by foreign buyer, and then by product, to 
determine if, collectively, a buyer's portfolio of projects meets the 
definition of substantial injury.[Footnote 17] Ex-Im staff report their 
findings in a document entitled Annual Review of Economic Impact Cases. 
Ex-Im cannot rescind funding if it finds after the review that a 
buyer's projects collectively meet the definition of substantial 
injury. 

When Congress reauthorized Ex-Im's charter in 2006, it introduced a new 
process to ensure that smaller projects do not collectively meet the 
definition of substantial injury. The new legislation requires Ex-Im to 
review a foreign borrower's requests on an ongoing basis, aggregating 
its applications over the previous 24 months to ensure that its 
financed portfolio does not surpass $10 million. If the aggregate 
financing does exceed $10 million, the bank must subject the entire 
aggregate production from the proposed project and relevant projects 
approved during the preceding 24-month period to further economic 
impact analysis. According to Ex-Im's revised procedures, only the most 
recent, proposed project will be affected by the results of this 
economic impact scrutiny. 

Detailed Economic Impact Analysis Assesses Oversupply, Competition, and 
Net Trade Impacts: 

For applications that remain after the screening process, Ex-Im 
conducts a detailed analysis. The detailed analysis's components are 
designed to address specific legislative requirements, including 
comments solicited from the public and relevant U.S. government 
agencies. Ex-Im compiles its findings, along with its conclusion 
regarding whether the project will negatively impact the U.S. economy, 
in a memorandum to the board of directors. (See app. II for a list of 
applications for which Ex-Im began a detailed economic impact analysis 
between fiscal years 2002 and 2006.) 

In its detailed economic impact assessments, Ex-Im addresses the 
specific statutory requirements concerning the assessment of whether a 
foreign product will be in surplus in world markets or in competition 
with U.S. production, and estimates an overall impact on trade flows. 
The components of this analysis include (1) an assessment of whether 
the foreign product potentially supported by Ex-Im financing will be in 
surplus on world markets--which Ex-Im terms as being "in oversupply," 
(2) an estimate of U.S. production that could be displaced by 
competition with the increased foreign production, and (3) the net 
impact on U.S. trade flows. According to its procedures, Ex-Im assesses 
whether the product to be produced by the foreign buyer is in 
oversupply using a set of indicators that include trade measures, such 
as antidumping duties on related products, and stagnating global 
prices.[Footnote 18] Finally, Ex-Im estimates the net effect on the 
U.S. economy by comparing the trade flows associated with the initial 
U.S. export and any follow-on, spare-part sales with the potential 
displaced production. This net economic impact assessment provides the 
type of analysis that, according to a senior Ex-Im official, could be 
informative to a board of directors' decision to exercise its 
discretion in approving applications where, for example, foreign 
production could compete with U.S. producers and represents 1 percent 
or more of U.S. production. 

Ex-Im's charter also requires it to solicit public comments. Ex-Im 
publishes a public notice in the Federal Register when beginning a 
detailed analysis and allows for a 14-day public comment period. For 
the applications we reviewed, Ex-Im's public notices contained (1) the 
project's value, (2) the country where the foreign borrower was 
located, (3) the goods to be produced, (4) the expected resulting 
amount of increased production of that good, and (5) the potential 
areas where the end product would be marketed. We found that Ex-Im 
consistently posted Federal Register notices containing the requisite 
information. The 2006 reauthorization codifies that practice and also 
requires Ex-Im to include information about the amount of the financing 
involved. In addition, the new legislation requires the bank to publish 
a revised public notice and allow for another comment period if a 
project changes materially[Footnote 19]. Ex-Im also consistently 
solicited comments on draft analyses from relevant U.S. government 
agencies: the Departments of Commerce, State, and the Treasury and the 
Office of the U.S. Trade Representative (USTR). The 2006 
reauthorization codifies that practice and additionally requires Ex-Im 
to notify relevant congressional committees that it is conducting a 
detailed economic impact analysis.[Footnote 20] 

Ex-Im staff create an economic impact memorandum that is used to 
describe their findings, along with their conclusion regarding whether 
the project is likely to have a positive or negative impact on the U.S. 
economy. 

Ex-Im Approved Most Projects Applicable for Economic Impact Review 
between Fiscal Years 2003 and 2005: 

Between fiscal years 2003 and 2005, Ex-Im approved financing for about 
two-thirds of the projects that involved foreign production of a 
exportable good, and that, therefore, were applicable for economic 
impact review. When reviewing applications, Ex-Im's board of directors 
considers economic impact and other factors. Ex-Im's 2006 
reauthorization requires the bank to provide a nonconfidential summary 
of the facts found and conclusions reached in any detailed economic 
impact analysis to the affected party, when requested. 

Ex-Im considered 771 applications applicable for economic impact review 
between fiscal years 2003 and 2005 and approved 525 projects, or 67 
percent, which represented approximately $6.1 billion in financing. Of 
the approved projects, most had been removed from the economic impact 
process because the financing value was $10 million or less; however, 
these projects represented a relatively small portion of the approved 
financing ($615 million). Conversely, applications removed from the 
economic impact process because the project involved an "undersupplied" 
sector comprised a small number of approved projects (49) but the 
majority of approved financing ($3.8 billion). Of the 20 applications 
held for detailed analysis, Ex-Im approved 11, representing $1.7 
billion. Figure 4 compares the number of approved projects by each 
economic impact code with the respective dollar value. 

Figure 4: Comparison of Number and Dollar Value by each Economic Impact 
Code for the 525 Approved Applicable Projects (Fiscal Years 2003-2005): 

[See PDF for image] 

Source: GAO analysis of Ex-Im Bank data. 

[End of figure] 

The board or its designee[Footnote 21] decides whether to approve or 
deny any application on the basis of the economic impact designation in 
conjunction with many factors, including several other evaluations, 
such as an engineering feasibility study, an environmental impact 
assessment, and credit information about the applicant and the project. 
For those applications that undergo a detailed analysis, Ex-Im's 
charter provides an exception that allows the board to approve the 
application if it finds that the short-and long-term benefits to 
industry and employment in the United States outweigh the costs to U.S. 
producers of a competing good. Under this authority, the board of 
directors could approve an application even if the staff concluded that 
the project would create a negative economic impact. 

The 2006 reauthorization requires Ex-Im to provide affected parties 
with a nonconfidential summary of the facts and conclusions of any 
detailed economic impact analysis within 30 days of receiving a written 
request. Prior to the reauthorization, Ex-Im published the board of 
directors' financing decisions, but not information on whether the bank 
had conducted an economic impact analysis or the analysis's findings. 

Challenges and Limitations Exist in Identifying and Analyzing Projects 
for Economic Impact: 

We identified substantial challenges and certain limitations in Ex-Imís 
economic impact process. Determining the economic impact of a project 
is an inherently challenging process that requires defining which 
products and geographic markets will be affected and projecting future 
market trends. With respect to Ex-Imís screening of applications to 
identify those for detailed analysis, we found varying effectiveness; 
the effectiveness of the $10 million threshold used by Ex-Im is 
uncertain and has not been analyzed by Ex-Im. We identified certain 
methods used in the detailed analysis that could be improved. These 
methods featured inconsistencies and limitations in how Ex-Im has 
estimated potential costs to U.S. producers related to their production 
being displaced over time by increased foreign competition. Also, how 
Ex-Im characterizes the net effect of its financing on the U.S. trade 
balance can be clarified. In addition, Ex-Imís internal controls could 
be strengthened to better ensure that the identification process and 
analysis is conducted consistently and accurately. 

Screens Used to Identify Applications for Detailed Analysis Vary in 
Effectiveness: 

While the number of applications for financing received by Ex-Im 
annually creates challenges in assessing all potential applications for 
economic impact, we found that the screens Ex-Im established using its 
discretion under the charter varied in effectiveness. Excluding 
requests to finance projects in the oil and gas sector and the diamond 
sector from detailed economic impact analysis because they are 
undersupplied has been an effective screen; however, the effectiveness 
of the $10 million screen is uncertain. 

Volume of Applications Creates Challenges in Screening for Economic 
Impact: 

The number of applications for financing received by Ex-Im annually 
creates challenges in assessing all potential applications for economic 
impact. As we have previously discussed, Ex-Im processed 9,255 requests 
for financing from fiscal years 2003 through 2005, 771 of which 
involved foreign production of an exportable good and, therefore, were 
applicable for economic impact review. While Ex-Im reviews all 
applications for potential economic impact, the additional procedures 
it has introduced to screen out projects that are unlikely to have an 
adverse impact on U.S. producers are also intended to more effectively 
allocate Ex-Imís limited resources. 

Exemption of "Undersupplied" Sectors from Analysis Has Been Effective: 

Ex-Im's exclusion of the oil and gas sector and the diamond sector from 
detailed analysis because they are "undersupplied" has been an 
effective tool developed with input from other agencies and previous 
analyses in those sectors. Ex-Im initially developed a list of 31 
natural resource sectors for which imports accounted for more than 50 
percent of U.S. consumption as potentially "undersupplied." Ex-Im 
reduced the list to 2 sectors (Ex-Im designated oil and gas as a single 
sector) with input from the U.S. government agencies that review the 
detailed analyses and the Department of Energy. Importantly, Ex-Im 
officials stated that, in the past, economic impact analyses of 
applications for projects in these sectors had always yielded a 
positive impact on the U.S. economy, and that, because these sectors 
were natural resources, the United States had limited ability to expand 
production domestically. Ex-Im created the undersupplied list to more 
effectively allocate its resources. 

Effectiveness of the $10 Million Threshold Has Not Been Determined: 

The $10 million thresholdís effectiveness as a screen is uncertain 
because Ex-Im has not determined the extent to which it identifies 
projects that could meet the statutory definition of substantial 
injury. As we have previously discussed, the threshold was chosen, in 
part, on the basis of other Ex-Im practices that are triggered at $10 
million, such as a board review and an environmental impact assessment. 
Ex-Im officials stated that requests for financing $10 million or less 
would generally be too small to increase foreign production by 1 
percent or more of U.S. production. However, Ex-Im has not conducted an 
analysis to support that the $10 million threshold captures the 
appropriate projects. In theory, even a relatively small export of 
capital goods or services could be used to produce 1 percent or more of 
production in a small U.S. industry.[Footnote 22] More generally, the 
dollar value of a capital good project can be an imperfect signal of 
the size of the project in terms of its production as a percentage of 
the corresponding U.S. industry. For example, Ex-Im estimated that a 
$14 million export of equipment to Russia would allow production of 
polystyrene to expand by 1.4 percent of U.S. polystyrene production. In 
contrast, Ex-Im estimated that a $16.25 million export of mining 
equipment to Japan would allow a foreign company to produce roughly 
14.6 percent of annual titanium production in the United States. 

We learned of or identified two requests for financing less than $10 
million whose projects were associated with estimated foreign 
production of over 1 percent of U.S. production in an industry; data 
limitations did not allow us to do a thorough review of projects with a 
financed value of $10 million or less. First, an export of $9.9 million 
of ethanol dehydration equipment to Trinidad would allow a foreign 
company to produce an estimated 3.5 percent of U.S. production of 
anhydrous ethanol. We learned of the ethanol project because Congress 
required Ex-Im to conduct a postapproval detailed analysis in the 
Consolidated Appropriations Act of 2004. Second, we identified a $9.8 
million export of mining equipment that would allow a foreign company 
to produce an estimated 1.73 percent of production in a U.S. industry. 
We identified the mining project when we attempted to sample 10 
applications requesting financing for $10 million or less, from a 
universe of 80 applications between $5 and $10 million, to examine 
whether they resulted in foreign production equal to or greater than 1 
percent of U.S. production in an industry.[Footnote 23] Of the 10 
capital good exports in our sample, Ex-Im could provide information on 
the amount of production for 2ó1 of which was the $9.8 million mining 
project that we have previously described.[Footnote 24] Thus, we were 
largely unable to determine the extent to which Ex-Im's $10 million 
threshold screened out applications that would have met the 1 percent 
substantial injury test. The mining project and the ethanol project, 
while treated in accordance with Ex-Im's procedure to exclude requests 
for financing $10 million or less from detailed economic impact 
analysis, indicate that requests of $10 million or less can be 
associated with production of over 1 percent of a corresponding U.S. 
industry. As we have previously noted, the 1 percent threshold is an 
important legislative criterion because it establishes whether a 
project meets the definition of substantial injury. 

Detailed Analysis Has Challenges and Certain Limitations: 

Determining the economic impact of a project is an inherently 
challenging process; however, we identified limitations in certain 
assumptions Ex-Im makes to estimate potential costs to U.S. producers, 
and in how it characterizes the net effect of its financing on the 
trade balance. 

Detailed Analysis Has Inherent Challenges: 

The modeling of international economic markets to determine the impact 
of government decisions and policies, including Ex-Im financing 
decisions, features a number of inherent challenges. Simplifications 
are always necessary to model complex economic interactions, and, even 
under simplified assumptions, precise data may not exist to address the 
question at hand. 

In some analyses, Ex-Im has found it challenging to define the 
industries that would be affected by Ex-Im-supported production, both 
in terms of products and geographic extent, a determination that will 
also influence estimates of the costs to U.S. producers. To calculate 
displaced production, Ex-Im must define the relevant industry, 
determine the regional or global markets in which there could be 
competition with U.S. producers, and collect trade and consumption data 
that are based on those markets. One case where Ex-Im officials noted 
challenges in obtaining the appropriate product data concerned a 
project supporting a denim plant in Turkey. To estimate potential 
displacement of U.S. denim exports, Ex-Im used data on U.S. exports of 
high-cotton-content denim (to reflect the Turkish manufacturer's plan 
to produce "high-end" jeans). However, Ex-Im stated there was a lack of 
data on broader supply-and-demand factors for this denim--such as 
global capacity utilization for denim plants--and, thus, Ex-Im relied 
on projections for the price of jeans because 85 percent of all denim 
is used to produce jeans. In addition, an analysis of a semiconductor 
production facility in Singapore also illustrates market definition 
challenges. Ex-Im identified a type of ìleading edgeî semiconductor as 
the relevant product market, but also noted that because of the on- 
demand nature of production in the facility, it was difficult to 
conduct a trade flow analysis or determine potential displacement of 
semiconductors made in the United States.[Footnote 25] Defining the 
industry appropriately and collecting data to match that definition is 
an inherent challenge in conducting an analysis of this kind. 

More broadly, the full economic impact on U.S. industries of projects 
financed by Ex-Im depends on determinations or assumptions regarding 
what would happen in the absence of the financing. For Ex-Im, 
predicting these effects can involve determining or making assumptions 
regarding (1) what would happen to U.S. productive resources if Ex-Imís 
financing for a project did not exist or (2) how global prices would 
evolve if new capacity were not added. Foreign competition for 
financing could also have implications for what would happen in the 
absence of Ex-Im financing. For example, if Ex-Im denied financing, the 
borrower might seek financing from another country's export credit 
agency, resulting in similar capacity being added abroad without the 
use of U.S. goods or services. However, because foreign competition for 
financing can exist for many projects, a senior Ex-Im official noted 
that the application of this rationale would risk undercutting other 
economic impact provisions. In contrast, if a particular U.S. exporter 
would supply a foreign producer whether Ex-Im financed the project or 
not, then those exports would not be in addition to what would happen 
without Ex-Im support. 

Calculation and Presentation of Some Potential Costs Could Be Improved: 

There are limitations in certain assumptions that Ex-Im has made to 
estimate potential costs to U.S. producers related to displaced 
production that is spread over time or lower prices for U.S. 
competitors, which are important elements of the detailed economic 
impact analyses. 

Calculation of Displaced U.S. Production: 

There are limitations and inconsistencies in how Ex-Im has calculated 
displaced U.S. production that is spread out over time. In measuring 
the potential cost of Ex-Im financing to U.S. industries, Ex-Im staff 
generally begin by estimating the annual level of displaced production 
in specific countries where U.S. production is expected to compete with 
the production supported by the Ex-Im loan or guarantee. This estimate 
is based on how much of the increased foreign production will be sold 
to countries that U.S. producers also supply, and on the current U.S. 
market share in those countries. While Ex-Im rightly considers both the 
present and future costs and benefits of its projects, we identified 
limitations and inconsistencies in its estimates--including its 
assumptions regarding (1) whether displacement, when it occurs, will 
happen every year or every other year and (2) how Ex-Im accounts for 
expected growth in global demand for a product in its estimates of 
displaced production--that can reduce or eliminate the amount of 
displaced production as initially estimated. These assumptions can, in 
some cases, significantly affect estimates of displaced production and, 
hence, net economic impact. Importantly, OMB notes that in cost-benefit 
analyses, major assumptions should be varied to determine how sensitive 
outcomes are to changes in the assumptions. 

Ex-Im has sometimes used an every-other-year method of calculating 
displaced production that occurs over time. Assuming that U.S. 
production would be displaced only every other year can significantly 
reduce estimates of displaced production as compared with an annual 
approach; it can reduce the estimated displaced production by close to 
half. In one 2005 case where Ex-Im used this approach, it estimated a 
net-positive trade impact with increased exports of $14.9 million and 
displaced production of $9.8 million over 8.5 years. Assuming every 
year displacement would have yielded a net negative impact. In a 2006 
analysis, estimated costs were reduced from $221,000 to $123,000 by 
assuming that displacement would occur every other year, although in 
that case the estimated value of exports was substantially higher than 
the estimated displacement, so the assumption did not change the net 
trade effect estimate. Ex-Im has explained the use of every-other-year 
discounting on varying grounds, including normal supply-and-demand 
cycles and regular cyclical fluctuations in the industry. However, such 
cyclical fluctuations are not likely to reduce the level of displaced 
production relative to what would occur without Ex-Im's financing, 
because the cyclical variation is not induced by the additional 
capacity supported by Ex-Im. In contrast, Ex-Im did not use an every- 
other-year approach to displaced production in a case where it 
characterized the industry as cyclical. 

Ex-Im has assumed in some analyses that growing demand for the 
commodities it is analyzing would eliminate the initial amount of 
displaced production it estimated. For example, in an analysis of a 
potential facility to increase foreign production of polypropylene, Ex- 
Im assumed that an estimated $83 million in displaced U.S. production 
over 8 years would not actually be displaced because of growing global 
demand for polypropylene. However, this implicitly assumes that, in the 
absence of Ex-Im support for the larger facility, U.S. production would 
not have expanded on its own to take advantage of that growing 
demand.[Footnote 26] Therefore, Ex-Imís estimate of displaced 
production will be highly sensitive to assumptions regarding how U.S. 
producers would meet growing world demand if new Ex-Im-supported 
capacity did not exist. Ex-Im made similar assumptions--that growing 
demand would offset potential displaced production--in an analysis of 
flat glass production in Mexico.[Footnote 27] Officials at one agency 
from which Ex-Im solicits comments stated that these assumptions were 
very optimistic, and that a sensitivity analysis would be appropriate. 

Potential Costs Related to Lower Prices: 

Ex-Imís method of estimating displaced production does not adequately 
acknowledge the potential costs to U.S. producers in some cases as a 
result of lower global prices. Ex-Imís methodology for estimating the 
economic losses to U.S. competitors does not capture indirect costs 
that are transmitted through changes in global market prices. As we 
have previously noted, the estimate of displaced production is focused 
on specific countries in which U.S. firms are expected to directly 
compete with the new foreign production. However, some costs to U.S. 
firms may come in the form of lower prices for homogeneous globally 
traded commodities, instead of directly displaced production.[Footnote 
28] These price changes could occur even in markets where there is no 
direct competition with the Ex-Im-supported foreign production, and 
should be acknowledged even if they cannot be calculated precisely. An 
official from one of the agencies that Ex-Im consults on economic 
impact also stated that one cannot necessarily assume that an increase 
in production in a single region will not affect global prices. 

For example, in a detailed analysis of the economic impact of a plant 
in Egypt that would produce ammonia, Ex-Imís estimate of the costs to 
domestic producers may not have captured the potential effect of lower 
global prices on those producers. Ex-Im stated that output from this 
plant was not expected to directly compete with U.S. ammonia exports. 
However, the United States procures ammonia globally and, therefore, is 
not insulated from even distant changes in market conditions. In 
comments provided to Ex-Im, industry officials also noted that because 
ammonia is a commodity, any increase in global supply would drive down 
prices. Similarly, in a detailed analysis of the economic impact of a 
plant in Israel that would produce polypropylene, Ex-Im focused on 
potential losses to U.S. producers in specific export markets. However, 
Ex-Im also noted in the analysis that polypropylene is a ìbulk 
commodity that is widely traded and can easily be transported 
worldwide.î This suggests that additional polypropylene capacity abroad 
could reduce the polypropylene prices faced by U.S. producers, even if 
they are not in direct regional competition with the new production. 

There are a number of potential techniques, which vary in complexity, 
to estimate or characterize the potential impact of certain types of Ex-
Im financing on global prices. The United States International Trade 
Commission often uses sophisticated and resource-intensive economic 
models to estimate an array of effects of changes in U.S. trade 
policies on, among other things, the prices faced by U.S. producers. 
However, other less complicated and less resource-intensive techniques 
could be used to approximate the impact of global supply changes on 
prices.[Footnote 29] According to OMB guidance, an enumeration of the 
different types of costs and benefits can be helpful in identifying the 
full range of potential effects, and, in addition, analyses should 
include a statement of the strengths and weaknesses of assumptions. Ex- 
Im officials stated that the separate assessment of oversupply should 
address some of these price effects. However, while the oversupply 
analysis may indicate the overall direction of global prices, it is not 
intended to measure the impact of Ex-Im-supported production on global 
prices or the potential effect of relatively lower prices on U.S. 
producers. 

Characterization of Financing Effect on Trade Balance Can Be Clarified: 

Ex-Imís characterization of its net trade flow analysis as reflecting 
impacts on the overall U.S. trade balance is misleading and can be 
clarified. As we have previously noted, a net comparison of how trade 
in two industries--the exporting industry and U.S. producers of the 
foreign-produced good--would be affected by Ex-Im financing is a key 
component of the detailed analyses. In its economic impact memorandums 
concerning its detailed analyses, Ex-Im generally presents the amount 
of this estimated net impact as a change in the U.S. trade balance, 
stating that the trade balance will ìimproveî by the full dollar value 
of the exports it finances, less lost production. This characterization 
is misleading because the incremental impact of Ex-Im financing is 
likely to be less than the total value of those exports.[Footnote 30] 
Economists generally agree that the aggregate trade balance is largely 
determined by macroeconomic factors, especially the domestic balance 
between savings and investment. Thus, the incremental impact of Ex-Im 
financing is likely to be much smaller than the total value of U.S. 
exports supported by Ex-Im or the total value of displaced production. 
However, while the size of the impact on the U.S. balance of trade is 
overstated, Ex-Im's conclusions about net economic impact are likely to 
have been unaffected by this practice because these cost and benefits 
are both overstated. 

Controls on Ex-Im's Economic Impact Process Could Be Strengthened: 

We found that the internal controls Ex-Im uses to ensure the accuracy 
of its economic impact identification and analysis process could be 
strengthened. According to the Standards for Internal Control of the 
Federal Government,[Footnote 31] internal controls should reasonably 
ensure the effectiveness and efficiency of operations and the 
compliance with applicable laws and regulations. Control activities 
include a wide range of diverse activities, such as training, approvals 
and verifications, and the creation and maintenance of related records 
that provide evidence of execution of these activities as well as 
appropriate documentation. The manner in which Ex-Im conducts at least 
three control activities does not reasonably ensure effective analyses. 
First, Ex-Im did not provide the employees conducting the analyses with 
formal training or guidance on how to conduct the analysis. Second, Ex- 
Im did not consistently document internal review of the analysts' work. 
Third, Ex-Im does not maintain documentation of certain important 
pieces of information. Without strong internal controls, Ex-Im cannot 
ensure that all requests for financing are appropriately analyzed. 

Limited Training or Systematic Guidance Was Provided on How to Conduct 
a Detailed Analysis: 

Although appropriate training is a key internal control, Ex-Im provided 
the analysts with whom we spoke[Footnote 32] with limited training or 
systematic guidance on how to conduct an economic impact analysis. 
According to the Standards for Internal Control of the Federal 
Government, management should ensure that employees have the required 
skills to achieve organizational goals. Training should be aimed at 
developing and retaining employee skill levels to meet changing 
organizational needs. According to the five analysts with whom we 
spoke, Ex-Im's training includes reading the economic impact procedures 
and previously conducted analyses and informal mentoring from 
coworkers. One analyst relied on a notebook compiled by his predecessor 
and another analyst relied on a template; however, according to bank 
officials, neither of these documents had been sanctioned by Ex-Im. 
This training and guidance may not be sufficient to ensure the use of 
the same fundamental, methodological approach across analyses, 
particularly given that the Policy Analysis Division, which is 
responsible for conducting the analyses, has had a lot of turnover 
since 2002.[Footnote 33] 

Approvals and Verification Were Not Systematically Obtained: 

Officials from the Policy Analysis Division stated that the economic 
impact analysts always consult with the engineers when conducting a 
detailed analysis because they provide important technical expertise; 
however, the engineers do not consistently approve final analyses. 
According to the Standards for Internal Control of the Federal 
Government, key duties and responsibilities need to be divided or 
segregated among different people to reduce the risk of error. This 
includes separating the responsibilities for reviewing the analyses. 
The Ex-Im policy division relies on the engineering division for 
industry-specific information. For example, the Engineering and 
Environment Division generally calculates the 1 percent tests for all 
applications and helps the analysts define the appropriate commodity 
markets. In addition, engineers contact the exporters and borrowers to 
gather the technical information necessary to make those 
determinations. However, while the employee who conducted the analysis 
and the head of the policy division always signed the final economic 
impact analyses to denote their concurrence with the analysis, the 
engineers did not. Engineers signed only 6 of the 14 economic impact 
analyses for which the board of directors made final financing 
decisions. Ex-Im officials acknowledged that, although the policy 
division does consult with engineers for every detailed analysis, Ex-Im 
does not have any rigorous procedures prescribing when an engineer 
should sign an analysis. Without the consistent signatures denoting 
engineer review, Ex-Im loses an important layer of assurance that their 
analyses were accurately conducted. 

Ex-Im Does Not Maintain Some Important Documentation: 

We also found that Ex-Im does not maintain documentation of important 
information concerning its detailed analyses. According to the 
Standards for Internal Control of the Federal Government, all 
transactions and other significant events need to be clearly 
documented, and the documentation should be readily available for 
examination. The policy division does not maintain records of the 
underlying data sources for its 1 percent test calculations, just the 
results of the calculations. Without the underlying data, the test 
cannot be replicated. The policy division also does not keep copies of 
draft analyses that it circulates to the reviewing agencies for their 
comments. The policy division also does not keep records of projects 
for which it began a detailed analysis, but which the applicants 
withdrew prior to the board making a final financing decision. A senior 
bank official noted that it probably would be a good idea for the 
policy division to start keeping files on the withdrawn data. 

U.S. Government Agencies Have Provided an Important Review Function: 

Commerce, State, Treasury, and USTR have played an important role in 
the quality assurance process regarding Ex-Im transactions that undergo 
a detailed economic analysis. In addition to specifically notifying 
these agencies when it begins a detailed analysis, Ex-Im provides them 
with a copy of the draft detailed analysis and asks that they provide 
their analytic and policy opinions. An Ex-Im official noted that the 
bank has voluntarily circulated the draft analyses to be as inclusive 
as possible, but it is not required to do so by its charter. Each of 
the four agencies reviews the detailed economic impact analysis in 
light of larger U.S. government policies, laws, and economic 
principles. The agencies often provided Ex-Im with important quality 
assurance feedback through informal dialogue. For example, when 
reviewing a draft of a transaction concerning denim, USTR noted in an e-
mail to Ex-Im that the analysis had not considered how the end of 
textile quotas, which had happened just prior to the transaction's 
application for financing, would impact the global supply of textiles, 
including denim. Ex-Im modified its analysis to incorporate this 
consideration. 

In addition to providing quality assurance, the agencies' comments can 
influence a transaction's outcome. For example, when agencies expressed 
the opinion that steel production was in overcapacity, Ex-Im's staff 
changed their conclusion that the transaction would have a "net 
positive impact" to that the transaction would have a "net negative 
impact." In an early draft of a detailed analysis concerning direct 
reduced iron production, Ex-Im staff concluded that steel would not be 
in oversupply when the foreign buyer's factory came on-line. However, 
three of the four agencies disagreed with this assessment. According to 
the economic impact memorandum for this transaction, Ex-Im staff 
deferred to the collective expertise among the agencies and changed its 
conclusion. 

Ex-Im generally requests the agencies' comments 1 week after it 
circulates the draft detailed analysis to them. Several agency 
officials stated that 1 week is not enough time to thoroughly review an 
analysis because of the complexity of the analysis and the need to get 
the views of those in official, senior-level positions on the analysis. 
However, some agency officials noted that Ex-Im does try to accommodate 
their requests for additional information and review time. 

Transparency of Economic Impact Procedures Has Limitations: 

We found that some aspects of Ex-Im's economic impact process lacked 
transparency. While Ex-Im publicly posts their procedures, the 
procedures are difficult to understand and contain undefined terms. In 
addition, Ex-Im does not provide all public comments to its board of 
directors as required by its procedures. 

Publicly Available Procedures Contain Areas of Ambiguity: 

Ex-Im's publicly available procedures do not clearly lay out how it 
analyzes applications for economic impact; therefore, interested 
parties are unable to reasonably assess their project's viability. In 
addition, Ex-Im could increase the process's transparency by 
referencing its list of sensitive sectors in its procedures and 
publishing the detailed analyses' outcomes. 

Economic Impact Process Is Not Easily Understood: 

Ex-Im's procedures for analyzing applications are unclear to lenders 
and exporters directly involved in those projects, other industry 
officials, and U.S. government officials. According to Ex-Im's annual 
competitiveness report,[Footnote 34] many lenders and exporters 
involved in projects requesting the bank's financial support expressed 
particular concern that the economic impact issue needs greater 
transparency and predictability. One exporter who participated in Ex- 
Im's annual competitiveness survey noted that, because the economic 
impact process is unpredictable, project sponsors may consider finding 
an alternative to the U.S. product and financing if the project would 
be subject to economic impact analysis. Industry officials with whom we 
spoke also generally noted that the process was not clear. One industry 
official called the process "a black box." Similarly, officials from 
one U.S. government agency with whom we spoke noted that Ex-Im's 
criteria and methodological assumptions were unclear. 

Ex-Im's Procedures Do Not Provide a Clear Basis for the Assessment of 
Oversupply: 

Ex-Imís oversupply assessment--which can be a key factor in determining 
economic impact--lacks a clear basis because Ex-Im has not defined 
oversupply or matched the list of oversupply indicators in its 
procedures with those that they actually use. As we have previously 
noted, a determination of oversupply--Ex-Im's interpretation of the 
statutory consideration of whether production is in surplus on world 
markets--can be a basis for denial of an application. Ex-Im has also 
referred to information gathered in its assessment of oversupply in its 
determination of potential displaced production and, thus, its estimate 
of net economic impact. There is no generally accepted definition of 
oversupply, which Ex-Im's procedures and staff both acknowledge. In 
fact, the excess supply of a good over demand is not likely to be a 
persistent condition because, in most markets, prices will adjust to 
bring the supply of the good in balance with the demand. However, 
various indicators can provide perspectives on the outlook for supply 
and demand, and on whether expansions in capacity might come at a time 
of falling prices. 

Ex-Im officials stated that they have not created an operational 
definition of oversupply to guide their assessment of it in detailed 
economic impact analyses. Instead, according to its procedures, Ex-Im 
analyzes transactions on a case-by-case basis and assesses oversupply 
according to a series of possible indicators. These indicators are as 
follows: 

* Final antidumping and countervailing duty orders on similar products 
elsewhere.[Footnote 35] 

* Section 201 investigations. 

* Stagnating or falling global prices. 

* Falling gross margins of domestic producers. 

* Industry bankruptcy and unemployment trends. 

* Trade Adjustment Assistance petitions. 

* Preliminary antidumping and countervailing duty determinations. 

* Multilateral production limitation agreements. 

Ex-Im has not generally used the more domestically focused indicators 
listed in its procedures to support conclusions regarding oversupply, 
and the procedures do not include a key indicator that it has used. Ex- 
Im officials stated that the oversupply assessment is made on a global 
basis. (Ex-Im's charter refers to surplus on "world markets.") However, 
most of the indicators listed in Ex-Im's procedures refer to laws, 
programs, or conditions in the United States that are not necessarily 
reflective of conditions on global markets. These include, for example, 
trade measures used by U.S. firms to mitigate the adverse effects of 
competition from foreign imports. While Ex-Im's economic impact 
memorandums often contained information on these trade measures in a 
separate section, the presence or absence of these measures is not 
generally identified as the basis for support of oversupply 
determinations. Furthermore, an indicator that has been important to Ex-
Im's determinations, capacity utilization, is not listed among the 
indicators of oversupply in its procedures. Ex-Im's conclusions about 
oversupply are typically supported by information related to prices, 
capacity utilization, and direct measures or forecasts of global supply 
and demand. 

Differences in criteria considered important for determining oversupply 
have been the basis for disagreements regarding whether Ex-Im should 
deny an application on economic impact grounds. An Ex-Im official 
stated that the lack of a definition for oversupply has been 
problematic because individuals may differ regarding whether a 
commodity is in oversupply, depending on the factors they consider. As 
a result of such disagreements, some transactions at Ex-Im have 
"stopped in their tracks," according to the Ex-Im official. This was 
illustrated in the case of a transaction that would have increased 
steel capacity in Saudi Arabia. Ex-Im and several agencies initially 
disagreed regarding oversupply on the steel project. Ex-Im's final 
economic impact assessment concluded that the transaction would likely 
have a net negative impact on the U.S. economy, and Ex-Im's board 
denied the transaction. An official with one of the agencies from which 
Ex-Im solicits comments also stated that oversupply has been an area of 
disagreement. 

Procedures Do Not Have Criteria for when to Use Proportionality: 

Similarly, Ex-Im does not clearly define when the concept of 
"proportionality" would be used. An Ex-Im official noted that the bank 
included proportionality in its procedures after the 2002 
reauthorization to retain some flexibility in how it analyzed the 
applications.[Footnote 36] A senior official stated that, in some 
cases, it is not reasonable for the bank to assume responsibility for 
all of a project's increased production when it only finances a portion 
of the overall project. Instead, the concept of proportionality allows 
the bank to measure the potential for its financing to displace the 
production of U.S. competitors in proportion to its funding. Applying 
proportionality would reduce the estimated costs to U.S. producers. For 
example, if Ex-Im financed $100 million worth of U.S. exports 
associated with a larger $2 billion project, the bank would be 
supplying 5 percent of the total project cost. If the $2 billion 
facility produced 10,000 metric tons of an exportable good, Ex-Im would 
assess the impact of its financial support on U.S. competitors on the 
basis of only 5 percent of the output--in proportion with its funding-
-or 500 metric tons. 

Using proportionality can change a net negative determination to a net 
positive determination. For example, Ex-Im applied the proportionality 
concept to the estimate of displaced production regarding a project 
that would allow a Chinese company to increase production of 
petrochemicals. According to documents provided by other government 
officials, Ex-Im's analysis of a petrochemical project noted 
approximately $170 million in expected benefits from the U.S. export 
sale, but approximately $750 million in potential indirect "lost 
opportunity" costs. Using standard calculations, the analysis would 
have yielded a net negative impact of over $580 million. However, Ex-Im 
applied proportionality and found that its share of the project 
financing equaled only 4.5 percent of project costs--therefore, Ex-Im 
financing was associated with about $34 million in potential indirect 
lost opportunity costs. This use of proportionality yielded a net 
positive impact of $134 million.[Footnote 37] Ex-Im approved the 
project in fiscal year 2003. 

Ex-Im also has not systematically used the proportionality concept or 
specified when it would be applicable. For example, in an application 
to finance an ethanol facility in Trinidad,[Footnote 38] Ex-Im argued 
that the equipment they financed did not allow the company to produce 
ethanol, but rather to introduce a "simple refinement step"--that is, 
dehydration. At that time, the price of hydrous ethanol (the input) was 
10 percent lower than anhydrous ethanol (the end product). Therefore, 
using the proportionality approach, Ex-Im asserted that its financing 
was only responsible for 10 percent of the output. Using 
proportionality, Ex-Im concluded that the project would increase 
foreign production by 0.35 percent of U.S. production. Using standard 
calculations, foreign production would have increased by 3.5 percent of 
U.S. production. Ex-Im asserts that its decision to use proportionality 
when equipment refines a product rather than produces a new product is 
fair and reasonable. However, in a similar project involving the 
refinement of hot-rolled steel to galvanized steel, Ex-Im did not apply 
proportionality. 

In addition, several reviewing agencies have expressed concerns about 
the use of proportionality when determining a project's economic 
impact. Without knowing the conditions under which Ex-Im would apply 
proportionality, interested parties do not have a sense of the 
viability of their proposed project. 

Ex-Im acknowledged that both the oversupply and proportionality 
language in the procedures is confusing. A senior Ex-Im official also 
noted that the bank struggles with determining when to use the 
proportionality concept. The bank also acknowledged that it should 
create more specific guidelines in their procedures for defining 
oversupply and proportionality. Specific criteria would make the 
process more transparent. However, Ex-Im has not altered the language 
in its most recent procedures. 

Public Comments Are Not Fully Included in Board Memorandums: 

Ex-Im does not regularly include the full text of the public comments 
that they receive. Ex-Im's economic impact procedures require it to 
attach the full set of comments as an appendix to the economic impact 
memorandums. In some cases, staff members attached selected 
communications. There were seven cases that received public comments 
and went to the board for decision but only two included copies of all 
of the comments received. According to Ex-Im, the Policy Analysis 
Division does not append copies of all public comments received because 
they are sometimes too numerous. Instead, the policy division 
summarizes the main arguments and often includes a representative 
letter. An Ex-Im official noted that the division retains all public 
comments and would make them available to the directors if requested. 
However, Ex-Im does not note in its procedures what criteria it uses 
for deciding which comments not to include, nor does it note in the 
memorandums that the letters were available for perusal upon request. 
The 2006 reauthorization now requires Ex-Im to provide in writing the 
views of all people who submit comments. 

Incorporating New Practices Would Increase Process's Predictability: 

We identified two practices that Ex-Im does not currently incorporate 
into their economic impact procedures that would increase the 
predictability of the process's outcomes--namely, referencing the 
sensitive sector list and publishing detailed analyses results. First, 
in its revised procedures, Ex-Im does not reference its list of 
industries unlikely to be financed for economic impact reasons. In the 
2006 reauthorization legislation, Congress required Ex-Im to create a 
"sensitive sectors list" denoting sectors that are unlikely to receive 
Ex-Im financing. Ex-Im has created this list and makes it publicly 
available on its Web site. However, Ex-Im's updated procedures do not 
specify the list's implications and indicate that requests for 
financing projects in sectors on the list will receive close scrutiny 
during the economic impact process. In contrast, the procedures do list 
"undersupplied" sectors (oil and gas and diamonds) that will not be 
denied on economic impact grounds. A direct reference to the sensitive 
sectors list would enable interested parties to quickly identify 
whether their projects were viable. Second, Ex-Im does not currently 
publicize the results of its detailed economic impact analyses. Ex-Im 
publicly announces when it begins a detailed analysis. It also posts 
minutes of board meetings on its Web site that announce ultimate 
financing decisions. However, the financing decisions do not include 
statements regarding whether the project was subject to an economic 
impact analysis, or the determination regarding whether there would be 
a net negative or net positive impact on the economy. Publicizing such 
information would provide interested parties with a record of what 
types of projects passed the detailed analysis. 

Conclusions: 

While many requests for Ex-Im's financing do not require economic 
impact analysis, the bank often faces the difficult task of balancing 
the interests of different industries while working to achieve its 
broad mission to promote U.S. exports and increase U.S. jobs. Ex-Im's 
board of directors must consider the economic impact of proposed 
projects while also weighing other factors, such as creditworthiness, 
environmental impact, and small business participation. Congress has 
given Ex-Im's board wide discretion in how it implements the economic 
impact requirements specified in the bank's charter. It directs Ex-Im 
to examine certain factors, such as whether products are in surplus on 
global markets (or in "oversupply," according to Ex-Im), but gives the 
board the authority to approve applications that it believes will have 
an overall benefit on U.S. production and employment, despite some 
negative impacts. Determining the various economic impact aspects that 
weigh into the board's decision can be challenging, requiring Ex-Im to 
identify what international markets are likely to be involved and to 
quantify how economic trends may play out in the future. While Ex-Im's 
board of directors may sometimes have to consider economic impact in 
the face of imperfect information, it needs to be able to rely on a 
process that involves sound methodology and consistent application of 
procedures, and to understand key assumptions and areas of uncertainty. 
Moreover, Ex-Im clients and affected U.S. industries need a process 
that is transparent and, where possible, predictable. 

Although Ex-Im generally follows its broad economic impact procedures, 
we identified several areas for improvement related to the screening of 
applications for economic impact, the analysis methodology, and the 
transparency of the overall process. First, while Ex-Im has the 
discretion to use screens to identify applications for further review 
and to allocate its staff resources effectively, the effectiveness of 
Ex-Im's $10 million screen is uncertain because Ex-Im has not conducted 
an analysis to determine the extent to which it identifies projects 
that could meet the statutory definition of substantial injury. Next, 
we identified limitations in certain assumptions Ex-Im makes to 
estimate economic impact in its detailed analyses. In some cases, these 
limitations had not been adequately disclosed nor had the sensitivity 
of economic impact conclusions to these assumptions been explored. In 
addition, while Ex-Im makes the economic impact procedures publicly 
available, the procedures do not provide adequate transparency and 
predictability. This has been noted by exporters, industry, and U.S. 
government agency officials. Ex-Im's own competitiveness survey cites 
one respondent as saying that the unpredictability of the economic 
impact process hurts U.S. sourcing in projects. 

Congress demonstrated in Ex-Im's 2006 reauthorization its continuing 
interest in Ex-Im having a sound and transparent economic impact 
process, and addressed certain transparency concerns. We believe that 
several improvements in Ex-Im's process are still needed to ensure that 
its decisions stand up to the inevitable scrutiny of interested and 
affected parties. 

Recommendations: 

To improve Ex-Im's identification and analysis of applications for 
economic impact, we recommend that the Chairman of the Export-Import 
Bank of the United States take the following three steps: 

* Review the $10 million threshold to determine whether additional 
steps are needed to mitigate the risk of exempting from more detailed 
review applications that could meet the definition of substantial 
injury. The additional steps could include, for example, selectively 
reviewing transactions that would affect relatively small U.S. 
industries or sensitive sectors. 

* Create specific methodological guidelines for staff analyzing 
applications for economic impact, bearing in mind relevant OMB guidance 
where appropriate. 

* Review and strengthen internal controls concerning the economic 
impact analysis to ensure, for example, that staff members conducting 
the analyses have sufficient training and guidance in Ex-Im's economic 
impact methodology, that relevant Ex-Im staff verify and approve the 
analyses, and that sufficient documentation is maintained to record key 
information. 

To improve the public transparency of the economic impact process for 
interested and affected parties, we also recommend that the Chairman of 
the Export-Import Bank of the United States take the following three 
steps: 

* Clarify publicly available procedures by including more information 
regarding Ex-Im's methodology for analyzing applications, such as 
defining how it incorporates "oversupply" determinations in its 
analysis and what measures it uses and specifying under what conditions 
"proportionality" would be used. 

* Inform interested parties about the sensitive sector list by 
including a reference to the list in the economic impact procedures. 

* Publish either individually, or in the publicly available board 
minutes, the final determinations regarding whether a project would 
have a positive or negative impact. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Export-Import Bank of the 
United States. Ex-Im generally concurred with our recommendations and 
stated that it will continue to explore feasible ways to improve the 
economic impact procedures and make the process more consistent and 
user-friendly. Ex-Im stated that it will (1) review the $10 million 
threshold to ensure that it satisfies its intended function; (2) 
enhance existing quality assurance measures by attempting to 
standardize staff training and to expand document maintenance; and (3) 
clarify the basis for an assessment of "oversupply," and create 
criteria for using "proportionality." In addition, Ex-Im agreed to seek 
to incorporate our suggestions as it refines its analytic methodology, 
but the bank noted that a single approach would not address the 
diversity of transactions it considers. We acknowledge that a single 
approach is not necessarily appropriate for all analyses, but we 
believe that a consistent set of methodological principles, such as 
those embodied in OMB guidance, would nevertheless enhance the economic 
impact analysis process. Lastly, Ex-Im agreed that increased 
transparency and predictability will improve the economic impact 
process and notes that it has amended its economic impact procedures to 
reflect increased transparency requirements laid out in the Export- 
Import Bank Reauthorization Act of 2006. We believe that the process's 
transparency and predictability can be further improved by several 
practices, such as referring to the sensitive sector list in the 
procedures and publishing the bank's determination regarding whether a 
project will have a positive or negative net impact. Ex-Im also 
provided technical comments, which we have incorporated where 
appropriate. Ex-Im's official comments are reprinted in appendix III. 

As agreed with your offices, unless you publicly announce the contents 
of this report, we plan no further distribution until 30 days from the 
report date. At that time, we will send copies of this report to other 
interested congressional committees. We also will provide copies of 
this report to the Chairman of the Export-Import Bank of the United 
States. In addition, this report will be available at no charge on the 
GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff members have any questions about this report, 
please contact me at (202) 512-4347 or YagerL@gao.gov. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this report. Other GAO contacts and staff 
acknowledgments are listed in appendix IV. 

Signed by: 

Loren Yager: 
Director, International Affairs and Trade: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

The Ranking Member of the Senate Committee on Finance and a member of 
the Senate Committee on Banking, Housing, and Urban Affairs requested 
that we review the Export-Import Bank of the United States' (Ex-Im) 
economic impact analysis process. In this report, we reviewed (1) Ex- 
Im's overall policies and procedures for determining economic impact; 
(2) the extent to which Ex-Im's procedures provide for the 
identification and appropriate analysis of applications that could 
potentially cause adverse economic impact; and (3) the extent to which 
its policies, procedures, and decisions are transparent to interested 
and affected parties. 

We reviewed the 17 economic impact memorandums that Ex-Im finalized 
between fiscal years 2002 and 2006. We chose this time frame because 
all analyses were conducted using the same procedures, and were adapted 
after the 2002 reauthorization but before the 2006 reauthorization. Of 
those cases, we chose 5 to review in greater depth: Russia/polystyrene, 
Egypt/ammonia, Singapore/semiconductors, Turkey/denim, and Saudi 
Arabia/direct reduced iron. We selected case studies that would provide 
a broad representation of elements in the following categories: 

* Country. 

* Type of industry/commodity. 

* Finance amount. 

* Final board decision. 

* Staff members conducting analyses. 

* Methodological issues.[Footnote 39] 

Given the small universe (17) of detailed economic impact analyses 
conducted by Ex-Im from fiscal years 2002 through 2006, we determined 
that selecting a random sample would not be necessary or appropriate. 
While we used these 5 case studies to guide some of our work, we 
reviewed all 17 detailed analyses because findings that are based 
solely on a judgmental sample would not necessarily be generalizable to 
all detailed economic impact analyses conducted. 

To describe Ex-Im's legal interpretation of its statutory economic 
impact analysis mandate, we reviewed the statutory provision as it was 
written in the bank's 2002 reauthorizing legislation; reviewed other 
relevant legal documents; and interviewed Ex-Im legal staff, including 
the General Counsel, regarding their interpretation. To describe Ex- 
Im's economic impact analysis process, we reviewed Ex-Im's economic 
impact analyses procedures published in March 2003 and compared them 
with the 2002 reauthorization legislation for consistency. To describe 
how Ex-Im's 2006 reauthorization will impact the economic impact 
procedures, we reviewed the relevant legislation and the revised 
economic impact procedures, and spoke with cognizant Ex-Im officials. 
To describe how Ex-Im implements the economic impact procedures, we 
spoke with the analysts who analyzed our 5 case studies, the engineers 
who assisted with the analysis, and the supervising officials. 

To determine how many applications Ex-Im coded for economic impact, we 
reviewed data on all projects processed between fiscal years 2003 and 
2005. Ex-Im did not use the same set of economic impact procedures when 
reviewing applications in fiscal year 2002; therefore, we did not use 
data from that fiscal year. In addition, Ex-Im did not have complete 
data for fiscal year 2006 projects at the time of our review. These 
data have some limitations that could result in small deviations from 
the values and quantities that we reported. Despite limitations, we 
determined that the transaction data provided by Ex-Im were 
sufficiently reliable for our purposes. 

To determine whether the exportable goods in each of our five case 
studies were subject to antidumping orders and countervailing duty 
orders, we reviewed the United States International Trade Commission's 
(ITC) list of current antidumping and countervailing duty orders in 
place as of October 23, 2006, and February 15, 2007; the Federal 
Register from 1997 to the present for notices posted by ITC or the 
Department of Commerce's International Trade Administration (ITA); and 
ITA's AD/CVD Investigations Federal Register History. To determine 
whether the exportable goods in our five case studies were subject to 
"safeguards," we searched the Federal Register from 1997 up to the date 
of the case for notices posted by ITC or ITA that mentioned the name of 
the product involved in our cases. 

To assess the extent to which Ex-Im's procedures provide for the 
identification and appropriate analysis of requests to finance projects 
that could potentially cause adverse economic impact, we reviewed the 
economic impact provisions of Ex-Im's charter and the procedures 
implementing those provisions. To determine the effectiveness of the 
$10 million threshold, we attempted to judgmentally sample 10 
applications that requested financing for capital good exports between 
$5 and $10 million. However, our ability to do so was limited because 
Ex-Im could provide the relevant information for only 2 of the 10 
projects. We reviewed 17 detailed economic impact analyses and 
documentation related to some applications that had not received a 
detailed analysis, and conducted interviews with Ex-Im officials on the 
5 analyses that we chose as case studies. We also reviewed the case 
studies within a panel of Ph.D. economists in GAO. In addition, we 
interviewed officials from agencies that conduct similar analyses at 
the ITC and the Overseas Private Investment Corporation, and reviewed 
cost-benefit analysis guidance from the Office of Management and 
Budget. We also reviewed relevant reports from GAO, the Congressional 
Budget Office, and the Congressional Research Service. 

To assess the economic impact analysis process's transparency, we 
reviewed the Federal Register to confirm that Ex-Im posted public 
notices for all detailed analyses it began. We reviewed Ex-Im's Web 
site to establish what information Ex-Im made public (including current 
procedures and final transaction decisions). We also reviewed internal 
Ex-Im documents. We interviewed agency officials from the Departments 
of Commerce, State, and the Treasury and from the Office of the U.S. 
Trade Representative who formally review the economic impact 
memorandums. We compared draft analyses that the agencies received from 
Ex-Im with final analyses and reviewed communications between the 
agencies and Ex-Im. We also interviewed representatives from companies 
whose exports relied on Ex-Im financing, and representatives from 
organizations that expressed concern over the projects' potential 
impact on the industries they represent. We used our 5 cases to 
determine which agency officials, exporters, and industry officials to 
interview. 

We conducted our work from October 2006 through August 2007 in 
accordance with generally accepted government auditing standards. 

[End of section] 

Appendix II: List of Detailed Economic Impact Analyses That Ex-Im Began 
between Fiscal Years 2002 and 2006: 

We requested and received copies of all detailed economic impact 
analyses Ex-Im conducted in fiscal years 2002 through 2006. We also 
requested data on all transactions processed during the same fiscal 
years. However, Ex-Im only had complete and reliable data for fiscal 
years 2003 though 2005. Transactions processed in fiscal years 2002 
were governed by a different charter than the other fiscal years, and 
data for transactions processed in 2006 were not available at the time 
of our review. Thus, the number of detailed analyses presented in this 
appendix does not correspond exactly with numbers cited in the report 
text. 

Table 1: Detailed Economic Impact Analyses and Board of Directors' 
Financing Decisions: 

Dollars in millions. 

1; 
Country: Japan; 
Commodity: Titanium (electron beam furnace); 
Net contract price: $16.3; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 08/22/06; 
Final action: Fiscal year[A]: 2006. 

2; 
Country: Saudi Arabia; 
Commodity: Direct Reduced Iron Facility; 
Net contract price: 74.3; 
Finding: Net negative; 
Final board decision: Denied; 
Final action: Date: 03/09/06; 
Final action: Fiscal year[A]: 2006. 

3; 
Country: Turkey; 
Commodity: Denim (equipment); 
Net contract price: 21.5; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 09/08/ 05; 
Final action: Fiscal year[A]: 2005. 

4; 
Country: Qatar; 
Commodity: Petrochemicals (equipment and services); 
Net contract price: 235.0; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 07/14/05; 
Final action: Fiscal year[A]: 2005. 

5; 
Country: Egypt; 
Commodity: Ammonia; 
Net contract price: 186.9; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 02/03/05; 
Final action: Fiscal year[A]: 2005. 

6; 
Country: Israel; 
Commodity: Polypropylene; 
Net contract price: 35.4; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 02/03/ 05; 
Final action: Fiscal year[A]: 2005. 

7; 
Country: Russia; 
Commodity: Polystyrene (production equipment); 
Net contract price: 17.3; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 12/22/04; 
Final action: Fiscal year[A]: 2005. 

8; 
Country: Singapore; 
Commodity: Semiconductors; 
Net contract price: 757.5; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 11/12/ 04; 
Final action: Fiscal year[A]: 2005. 

9; 
Country: Ukraine; 
Commodity: Galvanizing line (steel); 
Net contract price: 18.5; 
Finding: Net positive; 
Final board decision: Effective denial (split vote); 
Final action: Date: 05/24/04; 
Final action: Fiscal year[A]: 2004. 

10; 
Country: Argentina; 
Commodity: Gold and silver; 
Net contract price: 72.4; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 03/26/ 04; 
Final action: Fiscal year[A]: 2004. 

11; 
Country: India; 
Commodity: Pure Terephthalic Acid; 
Net contract price: 83.6; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 06/05/03; 
Final action: Fiscal year[A]: 2003. 

12; 
Country: Russia; 
Commodity: Mettallurgical coal; 
Net contract price: 25.0; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 04/03/03; 
Final action: Fiscal year[A]: 2003. 

13; 
Country: Uzbekistan; 
Commodity: Gold mine; 
Net contract price: 78.0; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 01/30/ 03; 
Final action: Fiscal year[A]: 2003. 

14; 
Country: China; 
Commodity: Petrochemical production; 
Net contract price: 200.0; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 10/25/02; 
Final action: Fiscal year[A]: 2003. 

Source: GAO analysis of Ex-Im data. 

[A] The U.S. government fiscal year runs from October 1st through 
September 30th. The fiscal year is named by the calendar year in which 
it ends. 

[End of table] 

Table 2: Detailed Economic Impact Analyses, with No Final Board of 
Directors' Decision Because of Transaction Withdrawal: 

Dollars in millions. 

1; 
Country: Portugal; 
Commodity: Photovoltaics modules; 
Amount: $14.9; 
Finding: Net positive; 
No final board decision made: Withdrawn; 
Final action: Date: 03/20/06; 
Final action: Fiscal year: 2006. 

2; 
Country: Greece; 
Commodity: Photovoltaics modules; 
Amount: 38.0; 
Finding: Net positive; 
No final board decision made: Withdrawn; 
Final action: Date: 08/03/05; 
Final action: Fiscal year: 2005. 

3; 
Country: Mexico; 
Commodity: Flat glass; 
Amount: 24.0; 
Finding: Net positive; 
No final board decision made: Withdrawn; 
Final action: Date: 11/02/04; 
Final action: Fiscal year: 2005. 

Source: GAO analysis of Ex-Im data. 

[End of table] 

Table 3: Detailed Economic Impact Analysis Conducted Postauthorization 
at the Request of the Credit Committee: 

Dollars in millions. 

1; 
Country: Russia; 
Commodity: Mettallurgical coal; 
Amount: $9.8; 
Finding: Net positive; 
Final board decision: Approved; 
Final action: Date: 09/21/04; 
Final action: Fiscal year: 2004. 

Source: GAO analysis of Ex-Im data. 

[End of table] 

Table 4: Detailed Economic Impact Analysis Conducted Postauthorization 
Pursuant to the Consolidated Appropriations Act of 2004: 

Dollars in millions. 

1; 
Country: Trinidad and Tobago; 
Commodity: Ethanol; 
Amount: $9.9; 
Finding: No definitive finding[A]; 
Final board decision: Approved; 
Final action: Date: 03/26/04; 
Final action: Fiscal year: 2004. 

Source: GAO analysis of Ex-Im data. 

Note: Title I, Division D, of Pub. L. No. 108-447. 

[A] In its analysis, Ex-Im concluded the following: "whether Ex-Im Bank 
support for this project will be associated with a positive or negative 
impact on the U.S. balance of trade largely depends on the outcome of 
the pending proposal to limit duty-free CBI ethanol imports to 90- 
million gallons per year. If the '7% cap' remains in place, then it is 
likely that Ex-Im support will be associated with a net negative trade 
flow. If the pending '90-million gallon cap' gets enacted, then it is 
likely that Ex-Im support will be associated with a net positive trade 
flow." 

[End of table] 

Table 5: Unfinished Detailed Economic Impact Analyses: 

Dollars in millions. 

1; 
Country: Saudi Arabia; 
Commodity: Petrochemicals (equipment and services); 
Amount: $480.0; 
Federal Register posting: Date: 07/25/06; 
Federal Register posting: Fiscal year: 2006. 

2; 
Country: Kenya; 
Commodity: Soda ash (locomotives for transport); 
Amount: 14.0; 
Federal Register posting: Date: 02/09/06; 
Federal Register posting: Fiscal year: 2006. 

3; 
Country: China; 
Commodity: Semiconductors; 
Amount: 1,200.0; 
Federal Register posting: Date: 12/23/04; 
Federal Register posting: Fiscal year: 2005. 

3; 
Country: China; 
Commodity: Semiconductors; 
Amount: 500.0; 
Federal Register posting: Date: 08/05/04; 
Federal Register posting: Fiscal year: 2004. 

4; 
Country: Turkey; 
Commodity: Soda ash production; 
Amount: 50.0; 
Federal Register posting: Date: 07/19/04; 
Federal Register posting: Fiscal year: 2004. 

5; 
Country: Mexico; 
Commodity: Aluminum engine blocks; 
Amount: 14.0; 
Federal Register posting: Date: 05/23/02; 
Federal Register posting: Fiscal year: 2002. 

6; 
Country: Mexico; 
Commodity: Automotive crankshaft (equipment); 
Amount: 35.0; 
Federal Register posting: Date: 03/04/02; 
Federal Register posting: Fiscal year: 2002. 

7; 
Country: South Africa; 
Commodity: Phosphate fertilizers; 
Amount: 12.5; 
Federal Register posting: Date: 03/04/02; 
Federal Register posting: Fiscal year: 2002. 

Source: GAO analysis of Ex-Im data and Federal Register notices. 

Note: Ex-Im posts Federal Register announcements when it begins 
detailed economic impact analyses. Ex-Im made no final financing 
decisions on these transactions. 

[End of table] 

[End of section] 

Appendix III: Comments from the Export-Import Bank of the United 
States: 

Export-Import Bank Of The United States: 
811 Vermont Avenue, N.W.: 
Washington, D.C. 20571: 
Phone: (202) 565-3500:  
Fax: (202) 565-3513: 

James II. Lambright: 
Chairman And President: 

September 5, 2007: 

Mr. Loren Yager: 
Director, International Affairs and Trade: 
United States Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Yager, 

Thank you for providing the Export-Import Bank of the United States 
("Ex-Im Bank" or the "Bank") a draft of the United States Government 
Accountability Office ("GAO") report entitled "Export- Import Bank: 
Improvements Needed in Assessment of Economic Impact." We appreciate 
GAO's efforts to understand and analyze Ex-Im Bank's economic impact 
policies and procedures, and we welcome the opportunity to share our 
thoughts on the proposed recommendations. 

Transactions involving economic impact issues are among the most 
difficult cases the Bank considers. As the GAO report underscores, 
determining the economic impact of a project is an inherently complex 
process. GAO correctly notes the Bank's challenge in attempting to 
balance the often times competing economic interests of two different 
U.S. industries: the industry represented by the exporter and the 
industry affected by new foreign competition. This challenge involves 
the examination of a vast array of industries, the attendant difficulty 
of information accessibility, and the consideration of diverse industry 
expertise. 

The GAO report examines the Bank's $10 million threshold for economic 
impact case review. Ex- Im Bank has utilized this threshold for the 
past 17 years without any adjustment for inflation. GAO recognizes the 
Bank's discretion to establish the threshold, but recommends that the 
Bank review its effectiveness and whether the threshold satisfies its 
intended function. Ex-Im Bank appreciates the importance of an 
effective threshold and agrees with the GAO recommendation. 

The GAO report also recommends that Ex-Im Bank create better 
methodological guidelines for analyzing economic impact. Ex-Im Bank 
transactions represent a broad spectrum of U.S. industries, and this 
diversity can be incompatible with a single methodological approach. As 
a result, over the years, the Bank has identified, developed and 
employed various reasonable and appropriate methodologies for 
evaluating economic impact on a case and industry specific basis. 
Within this context, Ex-Im Bank will seek to incorporate GAO's 
suggestions as we continue to refine our methodological approach.

GAO further recommends that Ex-Im Bank review and strengthen economic 
impact analysis internal controls. Senior economic impact officers are 
substantively involved in and consistently review all detailed economic 
impact analyses and staff members retain extensive records. Ex-Im Bank 
will, however, attempt to standardize staff training and expand 
document maintenance. 

GAO also advises that the Bank's procedures clarify the basis for an 
assessment of "oversupply" and set forth criteria for the use of 
"proportionality." Ex-Im Bank agrees that the economic impact process 
would benefit from these changes and will reexamine these areas. 

Finally, Ex-Im Bank agrees with GAO that increased transparency and 
predictability will improve the Bank's economic impact process. In the 
December 2006 Export-Import Bank Reauthorization Act, Congress passed 
legislation with the goal of creating more efficient, transparent and 
predictable economic impact procedures to serve the collective 
interests of exporters, industry and other interested parties. As the 
GAO report notes, Ex-Im Bank has amended its economic impact procedures 
to reflect this legislation, and we are optimistic that the changes 
will result in greater transparency and predictability. 

Ex-Im Bank has steadfastly responded to the challenging undertaking of 
our economic impact mandate. We will continue to explore feasible ways 
to improve our procedures and make the economic impact process more 
consistent and user-friendly. 

Sincerely,

Signed by: 

James H. Lambright: 
Chairman and President: 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Contact: 

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

Staff Acknowledgments: 

In addition to the person named above, the following people made key 
contributions to this report: Celia Thomas, Assistant Director; Miriam 
A. Carroll; Michael Hoffman; and Amber Simco. The following people 
provided technical assistance: Karen Deans, David Dornisch, Etana 
Finkler, Ernie Jackson, and Mark Speight. 

[End of section] 

Footnotes: 

[1] As an illustrative example, the concern has been that if Ex-Im 
provided favorable financing to a steel plant in Asia to expand 
capacity, using exported U.S. goods in building the plant, the project 
could potentially have a negative impact on U.S. steel producers 
through increased foreign competition. 

[2] Export-Import Bank Reauthorization Act of 2006 (Pub. L. No. 109- 
438). 

[3] 12 U.S.C. 635, et seq. 

[4] Limitations in data supplied by Ex-Im did not allow us to do a 
thorough review of requests for financing below $10 million. 

[5] We use the term "transparency" to mean the full, accurate, and 
timely disclosure of information. 

[6] Under proportionality, Ex-Im calculates economic impacts on the 
basis of the proportion of its financing related to the overall project 
value. 

[7] According to the Organisation of Economic Cooperation and 
Development (OECD), export credit agencies provide export credits in 
support of national exporters competing for overseas sales. Export 
credit agencies provide credits to foreign buyers either directly or 
via private financial institutions benefiting from their insurance or 
guarantee cover. Export credit agencies can be government institutions 
or private companies operating on behalf of the government. Many other 
OECD member countries also have export credit agencies, such as Canada, 
France, Germany, Japan, and the United Kingdom. 

[8] 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 [hyperlink, http://www.exim.gov]. 

[9] Ex-Im defines a transaction as "processed" if an application has 
been received and then authorized, denied, or withdrawn or if funds 
have been disbursed. 

[10] An economic impact consideration was first incorporated into Ex- 
Im's charter in 1968 and has been subsequently modified. 

[11] Ex-Im, Report to the U.S. Congress on Export Credit Competition 
and the Export Import Bank of the United States (Jan. 1, 2005, through 
Dec. 31, 2005). 

[12] As defined in Title VII of the Tariff Act of 1930. 

[13] As defined in Title II of the Trade Act of 1974. This legislation 
requires Ex-Im to consider final and preliminary determinations that 
may apply to the foreign production. 

[14] Ex-Im also codes Credit Guarantee Facilities and Medium Term Risk 
transactions as "annual review," regardless of the transaction's value. 

[15] Ex-Im's procedures note that proportionality "shall not be the 
only element used to avoid a full economic analysis." 

[16] Ex-Im identified and began a detailed analysis for 20 applications 
between fiscal years 2003 and 2005. Three applications were withdrawn 
by the applicants before the detailed analyses were completed. Three 
applications were withdrawn by the applicants after the detailed 
analyses were completed, but before the board of directors made a final 
financing decision. Fourteen applications received a complete detailed 
analysis and a final board decision. We also reviewed some applications 
that received a detailed analysis in fiscal years 2002 and 2006; 
appendix II contains a list of all analyses begun during fiscal years 
2002 through 2006. 

[17] Between fiscal years 2002 and 2006, Ex-Im only identified one such 
buyer whose portfolio on financed projects exceeded the $10 million 
dollar threshold in a single fiscal year. The bank conducted an 
economic impact review and concluded these projects did not produce 1 
percent or more of U.S. production. 

[18] As we have previously mentioned, Ex-Im as a matter of policy does 
not finance exports to produce products in countries where there are 
current trade sanctions on those products. In its detailed economic 
impact analyses, Ex-Im may consider trade measures on related products 
or identical products in other countries. 

[19] The term "material change," with respect to an application, 
includes a change of at least 25 percent in the amount of Ex-Im 
financing requested in the application and a change in the principal 
product to be produced by the foreign buyer. 

[20] Relevant congressional committees include the Senate Committee on 
Banking, Housing, and Urban Affairs and the House Committee on 
Financial Services. 

[21] All authority to approve or deny applications stems from the board 
of directors. The board generally reviews all applications over $10 
million. It has delegated authority to the Credit Committee to approve 
or deny medium-term transactions (generally speaking, those that are 
less than $10 million). The board has also delegated decision authority 
to individuals for certain categories of financing. 

[22] For example, according to the Census Bureau's Survey of 
Manufactures, roughly one-fourth of manufacturing industries at the 
seven-digit NAICS level (one definition of industries based on the 
North American Industrial Classification System) had annual shipments 
of less than $300 million in 2005. 

[23] We judgmentally selected a sample of 10 capital good projects 
requesting financing of $10 million or less. All 10 applications in the 
sample were between $5 and $10 million, and most were between $7 and 
$10 million. The sample was drawn from 80 applications that were 
approved, had funds disbursed, or were denied between fiscal years 2002 
and 2005. 

[24] An Ex-Im official stated that, in general, only large project 
finance transactions require information on increased production 
capacity for the bank's credit underwriting (since Ex-Im bases the 
project's creditworthiness on the project's future potential). Credit 
decisions for smaller projects are often based on criteria such as the 
borrower's credit history, financial statements, and the bank's 
experience with the exporter. There is no standard procedure for 
collecting or capturing production data, particularly for small 
applications (i.e., $10 million or less). 

[25] According to Ex-Im, the semiconductors to be produced at the 
facility would generally be Application Specific Integrated Circuits 
for consumption in the sectors of communications, computers, and 
consumer electronics. 

[26] An Ex-Im official told us that the bank had not used this 
assumption since the Israel polypropylene analysis in 2005. 

[27] This application was withdrawn by the buyer after a draft economic 
impact analysis was prepared but prior to board consideration. 

[28] Prices would not necessarily fall in absolute terms, but they 
might be lower than would be the case in the absence of Ex-Im 
financing. 

[29] For example, existing estimates of the price elasticity of demand 
for an industry's product could be used to estimate the impact of 
changes in global supply on prices. 

[30] OMB guidance for cost-benefit analyses by federal agencies, for 
example, states that calculations should be based on incremental 
benefits and costs. In particular, OMB notes that ìanalyses should take 
particular care to identify the extent to which a policy such as a 
subsidy program promotes substitutes for activities of a similar nature 
that would occur without the policy.î In this case, Ex-Im financing may 
promote the use of productive capacity in the United States that could 
find similar or alternative use even in the absence of Ex-Im support. 
For example, the firm that owns the productive capacity would seek 
other buyers for its products, although perhaps selling them later or 
at less favorable prices. 

[31] The Federal Managers' Financial Integrity Act of 1982 requires GAO 
to issue standards for internal control in government. The Standards 
for Internal Control of the Federal Government provide the overall 
framework for establishing and maintaining internal control and for 
identifying and addressing major performance and management challenges 
and areas at greatest risk of fraud, waste, abuse, and mismanagement. 
According to OMB, these standards are applicable to all executive 
agencies. 

[32] Between fiscal years 2002 and 2006, six Ex-Im staff members 
conducted the detailed economic impact analyses. 

[33] Of the 6 Ex-Im staff members who conducted the detailed economic 
impact analyses, 1 no longer works at Ex-Im. One analyst has changed 
positions within the bank and no longer works on detailed analyses. Two 
analysts work on the analyses as a collateral, rather than a primary, 
duty. Two analysts recently began working on the analyses. 

[34] Ex-Im, Report to the U.S. Congress on Export Credit Competition 
and the Export Import Bank of the United States (June 2006). 

[35] As we have indicated in a previous section of this report, when 
the foreign-produced good is directly subject to a final antidumping or 
countervailing duty order or a final section 201 determination, Ex-Im 
eliminates it from consideration for financing through its screening 
process. 

[36] We identified two instances where Ex-Im applied proportionality 
after the 2002 reauthorization. 

[37] According to documentation we received from the reviewing 
government agencies, two agencies objected to the use of 
proportionality for this project; therefore, Ex-Im provided them an 
alternative analysis supporting a net positive impact without using 
proportionality. However, this alternate calculation was not included 
in Ex-Im's final memorandum to the board of directors. 

[38] This project was initially not screened for economic impact, given 
that the finance value was less than $10 million. Ex-Im conducted this 
analysis after authorizing the project as required pursuant to Title I, 
Division D, of Pub. L. No. 108-447, the Consolidated Appropriations 
Act, 2005. 

[39] Methodological issues include determining "oversupply," estimating 
displaced production or the impact on the trade balance, and case- 
specific issues as noted in appendix II. 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink, http://www.gao.gov] 
and select "Subscribe to Updates." 

Order by Mail or Phone: 

The first copy of each printed report is free. Additional copies are $2 
each. A check or money order should be made out to the Superintendent 
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 
more copies mailed to a single address are discounted 25 percent. 
Orders should be sent to: 

U.S. Government Accountability Office: 
441 G Street NW, Room LM: 
Washington, D.C. 20548: 

To order by Phone: 
Voice: (202) 512-6000: 
TDD: (202) 512-2537: 
Fax: (202) 512-6061: 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]: 
E-mail: fraudnet@gao.gov: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Gloria Jarmon, Managing Director, JarmonG@gao.gov: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Susan Becker, Acting Manager, Beckers@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: