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Audit of EXIM's Approach for Determining Additionality

Report Information

Date Issued
Report Number
OIG-AR-22-07
Report Type
Audit
Joint Report
Yes
Participating OIG
Export-Import Bank of the United States OIG
Agency Wide
Yes (agency-wide)
Questioned Costs
$0
Funds for Better Use
$0

Recommendations

Update the additionality guidelines and checklist to: b) establish a reason code for additionality for applications denied or withdrawn due to additionality requirements. EXIM should include this information in EXIM’s Annual Additionality Report.

Separated 1a and 1b on 6/21/2023. 1b verified closed on 6/7/2023

Update the additionality guidelines and checklist to: a) explicitly state the minimum documentation requirements for establishing additionality whether that be source documentation or contemporaneous memos with the required elements of source, timing, and context

Separated on 6/21/2023 into Rec 1a and 1b

Establish a formal policy assigning independent oversight responsibility for additionality determinations. Ensure that all transactions and supporting evidence are reviewed for consistent application of additionality policies and procedures.

Closed as of 5/1/23

Conduct refresher training or briefing with loan officers on revised additionality procedures and requirements.

Recommendation #3 CLOSED as of 4/20/2023.