Audit of EXIM's Approach for Determining Additionality

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,...

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the additionality guidelines and checklist to: b) establish a reason code for additionality for applications denied or withdrawn due to additionality requirements.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.

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.

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