Export-Import Bank: Performance Standards for Small Business	 
Assistance Are in Place but Ex-Im Is in the Early Stages of	 
Measuring Their Effectiveness (17-JUL-08, GAO-08-915).		 
                                                                 
The Export-Import Bank (Ex-Im) provides loans, loan guarantees,  
and insurance to support U.S. exports, and its support for small 
businesses has been a long-standing issue of congressional	 
interest. Most recently in 2006, Congress required Ex-Im to	 
develop, and GAO to review, performance standards for Ex-Im's	 
assistance to small businesses, especially those owned by	 
socially and economically disadvantaged individuals and by women.
In response to the mandate, GAO evaluated the extent to which	 
Ex-Im's standards address the functions referred to in the	 
Export-Import Bank Reauthorization Act of 2006's (2006		 
Reauthorization Act) requirement for performance standards; how  
well Ex-Im is measuring its achievement of the standards,	 
including those related to small businesses owned by socially and
economically disadvantaged individuals and by women; and Ex-Im's 
use of performance information to improve operations and results.
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-915 					        
    ACCNO:   A82922						        
  TITLE:     Export-Import Bank: Performance Standards for Small      
Business Assistance Are in Place but Ex-Im Is in the Early Stages
of Measuring Their Effectiveness				 
     DATE:   07/17/2008 
  SUBJECT:   Critical infrastructure				 
	     Critical infrastructure protection 		 
	     Data collection					 
	     Data integrity					 
	     Databases						 
	     Employees						 
	     Export regulation					 
	     Exporting						 
	     Government guaranteed loans			 
	     Government information dissemination		 
	     Importing						 
	     Information management				 
	     Information resources management			 
	     Information storage and retrieval			 
	     Internal controls					 
	     Loans						 
	     Monitoring 					 
	     Performance measures				 
	     Program evaluation 				 
	     Small business					 
	     Small business assistance				 
	     Small business loans				 
	     Small disadvantaged business contractors		 
	     Standards						 
	     Standards evaluation				 
	     Strategic planning 				 
	     Systems analysis					 

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GAO-08-915

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Report to Congressional Committees:

United States Government Accountability Office: 
GAO:

July 2008:

Export-Import Bank:

Performance Standards for Small Business Assistance Are in Place but Ex-
Im Is in the Early Stages of Measuring Their Effectiveness:

GAO-08-915: 

GAO Highlights:

Highlights of GAO-08-915, a report to congressional committees. 

Why GAO Did This Study:

The Export-Import Bank (Ex-Im) provides loans, loan guarantees, and 
insurance to support U.S. exports, and its support for small businesses 
has been a long-standing issue of congressional interest. Most recently 
in 2006, Congress required Ex-Im to develop, and GAO to review, 
performance standards for Ex-Imï¿½s assistance to small businesses, 
especially those owned by socially and economically disadvantaged 
individuals and by women. 

In response to the mandate, GAO evaluated the extent to which Ex-Imï¿½s 
standards address the functions referred to in the Export-Import Bank 
Reauthorization Act of 2006ï¿½s (2006 Reauthorization Act) requirement 
for performance standards; how well Ex-Im is measuring its achievement 
of the standards, including those related to small businesses owned by 
socially and economically disadvantaged individuals and by women; and 
Ex-Imï¿½s use of performance information to improve operations and 
results. 

What GAO Found:

Ex-Imï¿½s small business performance standards address most, but not all, 
functions referred to in the 2006 Reauthorization Act. Ex-Im developed 
28 performance standards for its assistance to small businesses, 
ranging from providing excellent customer service to increasing 
outreach. We found that Ex-Im has performance standards relevant to 
most of the legislative functions, but the standards do not directly 
address some functions. For example, none of the standards directly 
addresses the function calling for increased outreach to businesses 
employing fewer than 100 employees. In addition, the standards address 
only some aspects of several functions. 

Ex-Imï¿½s performance measures generally address attributes of successful 
performance measures, such as clarity and linkage to goals, but 11 out 
of 27 measures lack targets and time frames to help decision makers 
evaluate progress toward meeting the performance standards. 
Additionally, Ex-Im has no measures to assess progress toward some 
standards. For example, while Ex-Im has established a measure for 
outreach to small businesses owned by socially and economically 
disadvantaged individuals and by women, it has no measure for 
monitoring progress toward its performance standard for increasing the 
amount made available to finance their exports. Ex-Im officials 
reported challenges to developing measures for financing exports by 
these businesses, such as the difficulty of obtaining reliable data. 

Ex-Im is in the early stages of compiling and using small business 
performance information. As an example of using this information to 
improve small business operations, Ex-Im officials cited raising limits 
on financing amounts for Letters of Credit, a type of guarantee, when 
customer feedback indicated an issue in that area. However, we found 
such examples are limited and Ex-Im has instituted few practices to 
date to ensure that small business performance information is used 
effectively. We previously reported on several practices that agencies 
can apply to enhance the use of performance information in management 
decisions, including improving the usefulness of performance 
information. To improve the usefulness of performance information, Ex-
Im recently centralized its data analysis functions and is beginning to 
implement a new data reporting system; however, Ex-Im has no systematic 
processes in place for collecting, analyzing, and disseminating small 
business performance data. 

What GAO Recommends:

This report recommends that Ex-Im establish performance standards for 
functions not currently addressed, revise several current measures to 
include measurable targets and time frames, and take steps to establish 
a measure for financing for small businesses owned by socially and 
economically disadvantaged individuals and women. Ex-Im concurred with 
GAOï¿½s recommendations. 

To view the full product, including the scope and methodology, click on 
GAO-08-915. For more information, contact Loren Yager at (202) 512-4128 
or [email protected]. 

[End of section] 

Contents:

Letter:

Results in Brief:

Background:

Ex-Im's Performance Standards Generally Address Most, but Not All, 
Functions Referred to in the 2006 Reauthorization Act:

Absence of Measurable Targets and Time Frames May Reduce the Value of 
Performance Measures and Make It More Difficult to Gauge Progress in 
Meeting Standards:

Ex-Im Is in the Early Stages of Using Small Business-Related 
Performance Information:

Conclusions:

Recommendations for Executive Action:

Agency Comments and Our Evaluation:

Appendix I: Scope and Methodology:

Appendix II: Ex-Im's Small Business Performance Standards:

Appendix III: Analysis of Ex-Im's Performance Standards Relative to 
Legislative Functions:

Appendix IV: Analysis of Targets and Time Frames in Ex-Im's Performance 
Measures:

Appendix V: Comments from the Export-Import Bank:

Appendix VI: GAO Contact and Staff Acknowledgments:

Tables:

Table 1: Status of Ex-Im's Efforts to Apply Practices to Facilitate Use 
of Small Business Performance Information:

Table 2: Ex-Im's Performance Standards for Assisting Small Business 
Exporters:

Table 3: Extent to Which Ex-Im's 27 Performance Measures Have 
Measurable Targets and Time Frames:

Figures:

Figure 1: Ex-Im's Performance Standards and the Major Sections of This 
Report:

Figure 2: Extent to Which the Functions Referred to in the 2006 Export- 
Import Bank Reauthorization Act Are Addressed by Ex-Im's Performance 
Standards for its Assistance to Small Businesses:

Abbreviations:

2006 Reauthorization Act: The Export-Import Bank Reauthorization Act of 
2006:

Commerce: The Department of Commerce:

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

SBA: Small Business Administration:

USEAC: U.S. Export Assistance Centers: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548:

July 17, 2008:

The Honorable Christopher J. Dodd: 
Chairman: 
The Honorable Richard C. Shelby: 
Ranking Member: 
Committee on Banking, Housing, and Urban Affairs: 
United States Senate:

The Honorable Barney Frank: 
Chairman: 
The Honorable Spencer Bachus: 
Ranking Member: 
Committee on Financial Services: 
House of Representatives:

The Export-Import Bank (Ex-Im) operates as an independent agency of the 
U.S. government and is the official export credit agency of the United 
States. Ex-Im provides loans, loan guarantees, and insurance to finance 
U.S. exports. The bank's level of support for small businesses has been 
an issue of long-standing congressional interest. Since the 1980s, 
Congress has required that Ex-Im make available a specified percentage 
of its export financing for small business. The Export-Import Bank 
Reauthorization Act of 2006 (the 2006 Reauthorization Act) calls for Ex-
Im to develop--and GAO to conduct a study of--performance standards to 
determine the extent to which Ex-Im is successfully carrying out 
certain functions in the act related to small businesses, especially 
those owned by socially and economically disadvantaged individuals and 
by women. The standards are to cover areas such as outreach, feedback, 
and financing related to small business exports.

In response to the mandate that we assess Ex-Im's performance standards 
and the bank's efforts to carry them out, this report (1) evaluates the 
extent to which Ex-Im's performance standards address certain functions 
of the Export Import Bank Act referred to in the 2006 Reauthorization 
Act related to small businesses, (2) evaluates how effectively Ex-Im is 
measuring the achievement of these performance standards related to 
small businesses, including those related to small businesses owned by 
socially and economically disadvantaged individuals and by women, and 
(3) evaluates how Ex-Im has used performance information in assisting 
small businesses and what steps Ex-Im has taken to facilitate and 
enhance that use.

To evaluate the extent to which Ex-Im's performance standards address 
relevant functions referred to in the act, we reviewed the 2006 
Reauthorization Act and identified specific functions of the Export- 
Import Bank Act subject to performance standards. To identify Ex-Im's 
performance standards, we reviewed Ex-Im documents including its most 
recent annual report, its 2006 Small Business Plan, and its recently 
updated 2008 Small Business Plan. We determined, and Ex-Im officials 
concurred, that the "goals," "key goals," and "key performance 
standards" in the 2008 Small Business Plan constitute the performance 
standards Ex-Im developed as the level of performance to be achieved by 
a program or activity. We compared the standards to the relevant 
functions referred to in the 2006 Reauthorization Act to determine the 
extent to which those standards address each function. To evaluate how 
effectively Ex-Im is measuring the extent to which it is meeting its 
performance standards, we assessed Ex-Im's performance measures in its 
2008 Small Business Plan, using key attributes of successful 
performance measures developed in our previous work. To evaluate how Ex-
Im has used performance information in assisting small businesses and 
the steps it has taken to facilitate and enhance that use, we 
considered several practices for improving the use of performance 
information developed in our previous work.[Footnote 1] For all three 
objectives, we interviewed cognizant Ex-Im officials. We also 
interviewed officials from the Department of Commerce (Commerce) and 
the Small Business Administration (SBA). We determined that the data in 
this report are sufficiently reliable for its uses. We conducted our 
work from November 2007 through July 2008 in accordance with generally 
accepted government auditing standards. Those standards require that we 
plan and perform the audit to obtain sufficient, appropriate evidence 
to provide a reasonable basis for our findings and conclusions based on 
our audit objectives. We believe that the evidence obtained provides a 
reasonable basis for our findings and conclusions based on our audit 
objectives. See appendix I for a more detailed description of our scope 
and methodology.

Results in Brief:

Ex-Im's performance standards for small business address most, but not 
all, of the functions found in the legislative provisions referred to 
in the 2006 Reauthorization Act. Ex-Im developed 28 performance 
standards[Footnote 2] for its assistance to small businesses, ranging 
from providing excellent customer service to increasing outreach to 
small business exporters. We found that while Ex-Im has performance 
standards relevant to most of the legislative functions, the standards 
do not directly address some functions. For example, none of the 
standards directly addresses the functions calling for increased 
outreach to businesses employing fewer than 100 employees, or for 
providing assistance to small and rural companies that have not 
previously participated in Ex-Im programs. In addition, although Ex-Im 
collaborates with SBA on its assistance to small businesses, none of Ex-
Im's standards specifically pertains to promoting small business 
exports in cooperation with SBA, as called for in the 2006 
Reauthorization Act. Finally, the standards address only some aspects 
of several functions.

Ex-Im has developed measures to assess its assistance to small 
businesses, but 11 out of the 27 measures lack measurable targets and 
time frames to fully evaluate progress toward meeting the performance 
standards. We found that Ex-Im's measures address most of the key 
attributes of successful performance measures, such as clarity and 
linkage to goals. An Ex-Im measure with targets and time frames is 
"maintain level of not less than 200 small business exporter outreach 
events annually." In contrast, the measure "the number of Ex-Im Bank 
sponsored training events, attendees, and revenue generated" does not 
specify a level of performance or time period within which it is 
expected to occur. Targets and time frames help decision-makers judge 
where improvements are necessary. In addition, Ex-Im has no measures to 
assess progress toward some performance standards. For example, Ex-Im 
has no performance measures for monitoring progress toward its 
performance standard for financing small businesses owned by socially 
and economically disadvantaged individuals and by women. Ex-Im 
officials explained that developing measures for financing for these 
businesses is particularly challenging largely because it is difficult 
to obtain reliable data. Specifically, they stated that Ex-Im cannot 
require small businesses to report this type of ownership status 
information on their applications and available data sources are not 
adequately reliable for this use.

Ex-Im officials stated that they are in the early stages of compiling 
and using much of Ex-Im's small business performance information. As an 
example of using this information to improve small business operations, 
Ex-Im officials cited raising limits on financing amounts for Letters 
of Credit, guarantees of payment by banks for foreign buyers, when 
performance data indicated an issue in that area. However, we found 
such examples are limited. Agencies can apply several practices to 
enhance the use of performance information in management decisions, 
including improving its usefulness and developing agency capacity to 
use it, on which we have previously reported. To date, Ex-Im has 
instituted few such practices to ensure that small business performance 
information is used effectively. For example, to improve the usefulness 
of performance information, Ex-Im recently centralized its data 
analysis functions and is in the process of implementing a new data 
reporting system; however, to date Ex-Im has no processes in place for 
systematically collecting, analyzing, and disseminating small business 
performance data. Ex-Im officials told us that they have not provided 
training to develop staff capacity in setting small business 
performance standards and analyzing performance data.

To more fully address the functions referred to in the 2006 
Reauthorization Act regarding performance standards for assistance to 
small businesses, we recommend that Ex-Im establish performance 
standards to address the functions not directly addressed by its 
current performance standards. In addition, to improve Ex-Im's ability 
to obtain information on how well it is achieving its small business 
performance standards, we recommend that Ex-Im revise performance 
measures that lack measurable targets and time frames to provide those 
attributes, in the context of available information, including its 
standard for increasing financing for small businesses owned by 
socially and economically disadvantaged individuals and by women. For 
that standard, we also recommend that Ex-Im take steps such as (1) 
establishing a measure based on the estimated data it currently 
reports, and (2) identifying ways to improve the reliability of its 
data in this area.

We provided a draft of this report to the Export-Import Bank of the 
United States. We received written comments from the Chairman and 
President of Ex-Im Bank, which are reprinted in appendix V. The 
Chairman and President reiterated our message that Ex-Im has standards 
for most of the functions referred to in the 2006 Reauthorization Act 
and stated that Ex-Im found the information in the report useful for 
the bank's planning efforts. He stated that Ex-Im concurred with our 
recommendations and identified steps the bank will take to implement 
them.

Background:

Ex-Im's mission is to help U.S companies create and maintain American 
jobs by financing exports of goods and services and filling gaps in the 
availability of commercial financing for credit-worthy export 
transactions. Ex-Im also helps American exporters meet government- 
supported financing competition from other countries so that American 
exporters can compete for overseas business on the basis of price, 
performance, and service. Its authorizing legislation directs Ex-Im to 
not compete with commercial lenders. To accomplish its mission, Ex-Im 
offers a variety of financing instruments, including loan guarantees 
and some direct loans for buyer financing; export credit insurance; 
[Footnote 3] and working capital guarantees for pre-export financing. 
Under its loan guarantee program, Ex-Im agrees to guarantee loans made 
by other lenders to help buyers in other countries obtain financing to 
purchase U.S. exports.[Footnote 4]

In fiscal year 2007, Ex-Im authorized more than $12 billion in loans, 
guarantees, and insurance. Of this amount, Ex-Im reported that about 
$3.4 billion (about 27 percent) directly supported U.S. small business. 
[Footnote 5] Ex-Im has primarily used insurance and working capital 
guarantees for small business transactions. Ex-Im works with a variety 
of outside entities or distribution channels--which it refers to as 
"multipliers"--to promote its products, identify and attract customers, 
and carry out its services. For example, it works with small businesses 
through a network of about 60 state and local organizations that 
provide information on and assistance on the bank's financing. Ex-Im 
also works with about 120 delegated authority lenders in 28 states that 
can directly commit Ex-Im's guarantee on working capital loans under 
its Community Delegated Authority Lender Program. Qualifying community 
bank lenders may commit Ex-Im's working capital guarantee without prior 
Ex-Im approval on individual transactions of up to $1 million, and for 
a total of up to $10 million per institution. Ex-Im has also recently 
implemented a delegated authority program for its medium-term guarantee 
and insurance programs. In addition, insurance brokers in each state 
can assist with Ex-Im's export credit insurance applications.

Congress has demonstrated a long-standing interest in Ex-Im's 
supporting small business by, among other things, requiring that Ex-Im 
make available a specified portion of its financing for small business. 
[Footnote 6] In 1983, Congress required Ex-Im to make available for 
fiscal year 1986 and thereafter not less than 10 percent of its 
aggregate loan, guarantee, and insurance authority for financing 
exports by small businesses. In 2002, Congress increased the percentage 
to 20 percent. Ex-Im is also required by Congress to report annually on 
(1) the number of its transactions that directly benefit small business 
and (2) an estimate of the number of small businesses Ex-Im indirectly 
supports as suppliers to companies receiving Ex-Im financing.

Most recently, the Export-Import Bank Reauthorization Act of 2006 
called for Ex-Im to develop a set of performance standards for its 
assistance to small businesses, especially those owned by socially and 
economically disadvantaged individuals and by women. The 2006 act calls 
for Ex-Im to develop performance standards for determining the extent 
to which Ex-Im has carried out successfully a wide range of functions 
related to small businesses that are described in various provisions of 
the basic Export-Import Bank Act. We identified about 30 functions as 
subject to the mandate (see table 2 in app. II for a list of the 
relevant functions).[Footnote 7] For example, some of these functions 
call for Ex-Im to promote small business exports and small business 
export financing programs in cooperation with Commerce, establish a 
Small Business Division to implement and oversee small business 
activities, and establish a Small Business Committee to coordinate 
small business initiatives and policies. Other functions relate to Ex- 
Im product improvement, maintaining liaisons with SBA and other 
departments and agencies in matters affecting small business concerns, 
and overseeing the development, implementation, and operation of 
technology improvements to strengthen small business outreach.

The 2006 Reauthorization Act places particular emphasis on Ex-Im's 
assistance to small businesses owned by socially and economically 
disadvantaged individuals and those owned by women. Specifically, the 
Export-Import Bank Act provisions referred to in the 2006 legislation:

* call for Ex-Im to continue and enhance outreach to these businesses,

* state that a goal of Ex-Im shall be to increase the amount made 
available to finance exports by these businesses, and:

* call for the establishment of an office within Ex-Im's Small Business 
Division focusing on outreach and increasing the total amounts of 
loans, guarantees, and insurance provided by Ex-Im to support exports 
by these businesses.

Figure 1 shows the relationship between the major sections of this 
report, which follow.

Figure 1: Ex-Im's Performance Standards and the Major Sections of This 
Report:

[See PDF for image] 

This figure is an illustration of Ex-Im's Performance Standards and the 
Major Sections of This Report, as follows: 

2006 Export-Import Bank Reauthorization Act: 
Develop performance standards for: 
Functions: 
Export-Import Bank: 
* Performance standards; 
* Performance measures; 
* Performance information. 

GAO report sections: 

Do Ex-Imï¿½s measures gauge its progress in achieving the standards? 

Is Ex-Im using the information to improve operations and results? 

Do Ex-Imï¿½s standards address the functions? 

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

[End of figure] 

Ex-Im's Performance Standards Generally Address Most, but Not All, 
Functions Referred to in the 2006 Reauthorization Act:

Ex-Im's small business performance standards generally address the 
majority of the 30 functions referred to in the 2006 Reauthorization 
Act, but some legislative functions are not directly addressed by any 
of Ex-Im's standards. Ex-Im has 28 performance standards for its 
assistance to small business exporters, ranging from providing 
excellent customer service, to increasing outreach, to expanding the 
use of Ex-Im's products. Ex-Im has standards relevant to most of the 
legislative functions; however, its standards address only some aspects 
of some functions and do not directly address some other functions.

Ex-Im Has Developed Performance Standards for Its Assistance to Small 
Businesses:

We identified 28 performance standards for small business assistance in 
Ex-Im's 2008 Small Business Plan, released in May 2008 (see table 2, 
app. II for a list of the performance standards). According to Ex-Im 
officials, Ex-Im first developed its Small Business Plan and standards 
in 2006, around the same time that Ex-Im's Small Business Division was 
established to carry out and oversee the bank's efforts directed at 
small business exporters. Ex-Im completed an update to the plan in May 
2008 that included some revised planned activities and targets, 
although most of the performance standards did not change.[Footnote 8] 
The performance standards in the Small Business Plan fall into nine 
subject areas:

* overarching standards; 
* Small Business Committee; [Footnote 9]
* customer service; 
* distribution channels; 
* outreach and marketing; 
* Ex-Im's on-line application system; 
* Working Capital Guarantee Program; 
* Short-Term Export Credit Insurance, and: 
* other Ex-Im small business products (including Medium and Long-Term 
Export Credit Insurance and Loan Guarantee Programs).

Ex-Im's 28 performance standards range from broad to specific, with 
some standards tied directly to identified statutory functions. For 
example, a standard reflecting statutory language in Ex-Im's 
authorizing legislation since 2002 calls for Ex-Im "to make available, 
from the aggregate loan, guarantee, and insurance authority 
availableï¿½not less than 20 percent of such authority for each fiscal 
year to directly support exports by small businesses." A broad, 
overarching standard related to "responsiveness" calls for small 
businesses to "receive answers about the availability of financing in a 
timely manner." Another broad standard for the Small Business Committee 
is to "provide a Bank-wide focus on small business." Other, more 
focused performance standards include a standard for Ex-Im's on-line 
system to "reduce cycle time of applications and policies processing" 
and another for the Working Capital Guarantee Program "to increase 
small business final commitment authorizations to $1.12 billion in 3 
years."

Ex-Im's initial Small Business Plan developed in 2006 did not include 
any standards specific to small businesses owned by socially and 
economically disadvantaged individuals and those owned by women, but in 
response to the 2006 Reauthorization Act mandate, the May 2008 update 
to the plan added two overarching performance standards that 
specifically refer to increasing export financing for these businesses:

1. "To continue to grow the dollar amount of Ex-Im authorizations for 
small businesses and for minority-owned businesses or women-owned 
businesses,"[Footnote 10] and:

2. "To continue to grow the number of export transactions involving 
small businesses and minority-owned businesses or women-owned 
businesses, supported by Ex-Im."

Ex-Im's Performance Standards Generally Address Most Functions Referred 
to in the 2006 Reauthorization Act, but Some Functions Are Not 
Addressed:

Ex-Im has small business performance standards related to most, but not 
all, of the 30 legislative functions we identified as subject to the 
2006 Reauthorization Act's requirement for performance standards. 
However, the standards address only some aspects of some legislative 
functions and do not directly address some other functions. (See fig. 2 
in app. III for a detailed analysis of how the performance standards 
address the legislative functions.)

Specifically, Ex-Im's small business performance standards:

* generally address 18 of the legislative functions;
* address some aspects of 5 of the legislative functions;[Footnote 11]
* do not directly address 5 of the legislative functions; and:
* are not applicable to 2 of the legislative functions. [Footnote 12]

Legislative functions that are not directly addressed by any of Ex-Im's 
standards include the function related to outreach to small and rural 
companies that have not previously participated in its programs. 
According to Ex-Im officials, Ex-Im does not generally track assistance 
to rural versus urban small businesses.[Footnote 13] The standards also 
do not directly address the function calling for conducting outreach 
and increasing loans to businesses employing fewer than 100 employees. 
Ex-Im follows SBA's definition for a small business, which generally 
includes businesses employing fewer than 500 employees--although that 
number varies across industries--and does not separately track all of 
its assistance to businesses with fewer than 100 employees.[Footnote 
14] Further, although Ex-Im collaborates extensively with SBA on its 
assistance to small business exporters and recently extended a co- 
guarantee agreement with SBA for the Working Capital Guarantee Program, 
its standards do not directly address the two functions related to 
promoting small business exports and maintaining liaison with SBA in 
matters affecting small business.

Finally, Ex-Im's standards address some, but not all aspects of certain 
functions. For example, Ex-Im's performance standards address some 
aspects of the function calling for Ex-Im to promote small business 
exports in cooperation with Commerce. The standards state that "for 
financial institutions, brokers, city/state partners, and Commerce's 
U.S. Export Assistance Centers (USEACs)," Ex-Im should 1) "expand use 
of all programs through active channels to directly support small 
business;" 2) "engage new channels specifically to support small 
business;" and 3) "add new distribution partners." However, the 
standards are general and do not clearly relate to coordination. Also, 
although they refer to Commerce's USEACs, many of which are staffed 
with representatives from Ex-Im, they do not refer to other 
collaboration efforts, such as collaboration with Commerce's Commercial 
Service to promote Ex-Im's products overseas.[Footnote 15]

Absence of Measurable Targets and Time Frames May Reduce the Value of 
Performance Measures and Make It More Difficult to Gauge Progress in 
Meeting Standards:

Ex-Im has developed performance measures to assess its assistance to 
small businesses, but some of these lack specific targets and time 
frames to fully evaluate progress toward performance standards. We 
found that Ex-Im's performance measures have most of the key attributes 
of successful performance measures, including clarity, linkage to 
goals, core program activities, limited overlap, and governmentwide 
priorities. However, 11 out of the 27 performance measures lack 
measurable targets and time frames. In addition, Ex-Im has no 
performance measures for monitoring progress toward its performance 
standard for financing small businesses owned by socially and 
economically disadvantaged individuals and by women.

Ex-Im's Performance Measures Have Most Attributes of Successful 
Performance Measures, but 11 Out of 27 Measures Lack Targets and Time 
Frames:

Ex-Im has developed 27 performance measures to assess whether it is 
achieving the 28 performance standards listed in its 2008 Small 
Business Plan. We analyzed these performance measures to determine if 
they had eight key attributes of effective performance measures. We 
have previously identified several key attributes of successful 
performance measures. Performance measures that have these attributes 
provide decision makers useful information to measure results and 
improve effectiveness.[Footnote 16] Successful performance measure 
attributes include the following.

1. Clarity: Measure is clearly stated and measure's name and 
definitions are consistent with the methodology used to calculate it.

2. Linkage: Measure has a clear relationship to one or more of the 
agency's goals (performance standards).

3. Core program activities: Measure covers the activities that an 
entity is expected to perform to support the intent of the program. 
There should be enough performance measures to ensure that managers 
have the information needed about performance in all the core program 
activities.

4. Observable: Measure translates goals (performance standards) into 
observable conditions that determine what data to collect in order to 
show whether progress was made toward achieving goals.

5. Measurable targets: Measure has a target that is quantifiable or 
measurable in that it specifies a particular level of performance to be 
attained, either as an absolute value such as "20,000 small businesses 
served" or a level of improvement, such as "a 10 percent increase."

6. Time frames: Measure specifies a time frame within which the 
performance is expected - i.e., annual, multiyear, or long-term.

7. Limited overlap: Measure provides new information beyond that 
provided by other measures.

8. Governmentwide priorities: Measure covers a priority such as 
productivity, quality, timeliness, customer satisfaction, outreach, 
coordination, cost of service, efficiency, and outcome.

We found that Ex-Im's performance measures generally have most of the 
attributes: they are clearly stated, address Ex-Im's core activities, 
provide new information beyond that provided by other measures, and 
cover governmentwide priorities. They also have the attribute of 
linkage in that, although Ex-Im's 2008 Small Business Plan does not 
specifically indicate which performance measures apply to which 
performance standards, our analysis showed that each measure links, or 
is relevant to, at least one performance standard. All but three 
performance measures translate goals into observable conditions to show 
progress.

However, as shown in table 3 (see app. IV), 11 out of the 27 
performance measures do not have measurable targets or time frames. 
Without measurable targets and time frames, performance measures may 
not provide Ex-Im adequate baseline data to identify strengths and 
weaknesses and make timely adjustments and improvements.

For example, the performance measure, "financial institutions: tracking 
of actual activity by products, transactions, and dollar volumes 
(authorizations)," lacks a target that is quantifiable or measurable to 
facilitate comparison between expected performance and actual results, 
such as increasing activity per institution by a specific percentage or 
dollar amount in authorizations. While an exact percentage may not be 
necessary, performance measures should at least specify a desired 
direction.

Some of Ex-Im's performance measures indicate that Ex-Im is still in 
the process of developing and integrating measurable targets and time 
frames, and also that performance measures with measurable targets tend 
to specify time frames. For example, the performance measure, "Ex-Im 
Bank will utilize the results of the customer service focus groups to 
establish the baseline for future improvements and appropriate metrics 
for on-going assessments," mentions baselines and thus appears to be 
collecting data for use in developing first-time targets. In addition, 
Ex-Im has measurable targets for the performance measures, "Regional 
Domestic Development officers will be measured against their individual 
targeted goals - based on need within their region...," and "monitor 
number of outreach events (speaking engagement, trade shows, 
conferences) undertaken by staff," but Ex-Im has not yet incorporated 
the targets into its 2008 Small Business Plan. Finally, the fact that 
all 11 performance measures that do not have measurable targets also 
lack specified time frames indicates that targets and time frames are 
closely related and that one generally supports the other.

Three performance measures do not translate goals into observable 
conditions to show progress toward the performance standard. One 
measure, "Ex-Im Bank will utilize the results of the customer service 
focus groups to establish the baseline for future improvements and 
appropriate metrics for on-going assessments" does not specify what to 
observe or what data the focus groups will collect in order to show 
progress toward a goal or standard. In a second measure, "work with 
Short Term Trade Finance to identify exporters needing both Working 
Capital Guarantee Program loans and credit insurance," what can be 
observed are those exporters identified as needing both Working Capital 
Guarantee Program loans and credit insurance. However, it is not clear 
how this information would indicate progress toward the standard, which 
is to increase small business Working Capital Guarantee Program 
authorizations. In a third measure, "degree of success in getting 
incremental U.S. government involvement with Ex-Im in terms of new 
activity with small business exporters using Ex-Im products," it is not 
clear what to observe because "U.S. government" involvement and "new 
activities" are not explained, making it unclear what data to collect 
to show progress.

Ex-Im Has No Performance Measures for Performance Standards on 
Financing Small Businesses Owned by Socially and Economically 
Disadvantaged Individuals and Women, Citing Challenges:

Ex-Im has no performance measures for its two performance standards 
focused on providing financing to small businesses owned by socially 
and economically disadvantaged individuals and those owned by women. 
The standards are to continue to grow the dollar amount of Ex-Im 
authorizations for small businesses and for minority-owned businesses 
and women-owned businesses, and to continue to grow the number of 
export transactions involving small businesses and minority-owned 
businesses or women-owned businesses supported by Ex-Im.

Ex-Im officials cited two challenges to establishing specific 
performance measures, and in particular measurable targets, for 
financing these businesses, including poor data and difficulty in 
predicting increases in applications. With regard to data, the 
officials said Ex-Im cannot require applicants to identify themselves 
as minority or women-owned and generally get a low response rate to 
this question. Ex-Im officials told us that they use data from Dunn & 
Bradstreet, a commercial information vendor, to corroborate the 
applicant information and identify minority and women-owned businesses 
that may have chosen not to identify themselves as such but that they 
believe Dunn & Bradstreet faces similar challenges as Ex-Im in this 
area.

However, Ex-Im officials said that they take steps to collect data and 
estimate their assistance to these businesses, and have begun reporting 
information from these estimates. Ex-Im includes optional questions on 
its product applications for businesses to self-identify as minority or 
women-owned. On the basis of these estimates, in 2007, Ex-Im reported 
separate authorization amounts for these businesses for the first time, 
reporting in its Annual Report that it authorized $524.6 million in 
working capital guarantees and export-credit insurance to support 
exports by businesses identified as minority-owned and women-owned, of 
which $409 million represented small businesses.

Ex-Im's Working Capital Guarantee Program application requests more 
detailed identifying information about minority and women-owned 
businesses than its Short Term Export Credit Insurance application. An 
Ex-Im official explained that 98 percent of the Working Capital 
Guarantee Program transactions are completed by delegated authority 
lenders, who have more intimate knowledge of the applicants. He said 
that the delegated authority lenders are able to assist applicants in 
completing the relevant questions on the application, and in cases 
where a business does not self-identify, the lender may have knowledge 
about the status of the business that would enable the lender to add 
the additional details. Finally, Ex-Im officials said that they do not 
cross-check this information with SBA databases because SBA's database 
is primarily for procurement (for example, businesses interested in 
contracting with the federal government to provide computer services) 
and would not likely include exporters.

A second difficulty of establishing specific performance measures for 
financing businesses owned by women and minorities, according to Ex-Im 
officials, is the long lead time between outreach efforts and receipt 
of applications for assistance from these businesses and the 
unpredictability of increased authorizations. Ex-Im's Office of 
Minority and Women-owned Businesses, created in 1999 with one business 
development officer and currently staffed with two officers for 
outreach and one that also does broker relations, focuses primarily on 
outreach to these businesses. According to Ex-Im officials, the office 
attempts to track the number of applications for Ex-Im assistance 
resulting from these outreach events. However, the officials stated 
that it may take several years from when these businesses initially 
attend an Ex-Im outreach event to when they are ready to apply for 
assistance.[Footnote 17]

Ex-Im Has No Performance Measures for Several Other Performance 
Standards:

Several other small business performance standards lack performance 
measures. These include standards relating to Ex-Im's Small Business 
Committee, improving communication with insurance brokers as part of 
outreach and marketing, and improving its short-term export credit 
insurance products. The Small Business Committee performance standards 
in Ex-Im's 2008 Small Business Plan are to provide a bank-wide focus on 
small business, report and evaluate each unit's small business 
performance, identify opportunities for cross-selling and expanding the 
use of bank programs for small business, measure progress toward 
meeting the plan/objectives and adjust actions, and serve as a vetting 
forum for new small business initiatives. While Ex-Im officials told us 
they discussed issues related to some of these performance standards, 
the 2008 Plan has no performance measures specifically focused on 
tracking the efforts of the committee (the next section discusses the 
activities of the Small Business Committee).

Ex-Im Is in the Early Stages of Using Small Business-Related 
Performance Information:

Ex-Im is just beginning to use performance information gained from its 
performance measures to enhance its assistance to small business and 
most of its efforts are still in the planning stages. Ex-Im officials 
told us that in some cases they have used preliminary data from their 
performance measures to identify problems and take corrective action. 
However, such examples are limited and Ex-Im has implemented few 
practices to date to ensure that small business performance information 
is used effectively. We previously reported that agencies can employ 
certain practices[Footnote 18] to facilitate the use of performance 
information in decision making, including improving the usefulness of 
performance information and developing agency capacity to use it. 
Related to improving the usefulness of performance information, Ex-Im 
recently centralized its data analysis functions, but it has not 
established systems or processes to systematically compile, analyze, 
and disseminate small business performance data. Officials stated that 
they are in the beginning stages of implementing a new data reporting 
system that will include improved data compilation and performance 
review capabilities. Further, Ex-Im has not provided training to 
develop staff capacity in setting small business performance standards 
and analyzing data from its measures.

Ex-Im Is Just Beginning to Use Performance Information in Management 
Decisions:

Ex-Im is still in the preliminary stages of using information from its 
small business performance measures to improve programs and results. 
The full benefit of collecting performance information is realized only 
when managers use it to improve operations. Federal agencies can use 
performance information to identify problems in existing programs and 
their causes, and to develop corrective actions.

However, Ex-Im officials stated that they are just beginning to compile 
and use small business performance information in decision-making. They 
provided us with preliminary performance data for fiscal year 2007. 
Although the information was not organized by performance standard or 
performance measure, we found that at least some data were provided 
related to most of the performance measures. For example, information 
for an outreach measure on the "type, number, and volume of direct mail 
campaigns and the prospect leads generated" noted that two local direct 
mail campaigns (1,700 total pieces) had been conducted, though 
information was not included on actual prospect leads generated. 
Additionally, Ex-Im compiles quarterly and annual results of regional 
domestic business development officers' activities, including data on 
the number and amount of small business transactions approved, by 
program.

The officials indicated that, to date, they have used some of the 
preliminary performance information on an ad hoc basis to identify 
problems and take corrective action. In one example they provided, Ex- 
Im raised the amount that the agency will back in a Letter of Credit 
for a foreign buyer from $500,000 to $1 million when data for its 
customer service measure indicated an issue for Ex-Im's customers in 
that area. Ex-Im officials added that they have also made programmatic 
changes to address issues they became aware of through their day-to-day 
work. For example, the Small Business Committee voted to provide a 
discount to small businesses on Ex-Im's non-deductible multibuyer 
insurance product[Footnote 19] after Ex-Im staff became aware that the 
product's current pricing provided little advantage to small businesses.

Ex-Im Has Applied Few Practices to Facilitate Use of Small Business- 
Related Performance Information:

Ex-Im has taken some steps to ensure its small business-related 
performance information is used effectively but has not yet taken steps 
to implement certain key practices (see table 1). To use performance 
information in a meaningful way, agencies can institute five types of 
practices: demonstrating management commitment; aligning goals and 
measures; improving the usefulness of performance information to better 
meet management's needs; developing agency capacity to effectively use 
performance information; and frequently and effectively communicating 
performance information.[Footnote 20] However, Ex-Im officials noted 
plans to better institute several of these practices. For example, Ex- 
Im officials stated that they plan to establish a more formal 
performance review process as well as systems and procedures to 
systematically compile data related to Ex-Im's small business standards 
and measures. Ex-Im recently centralized its data analysis functions in 
one office, but officials said that Ex-Im's initial focus has been on 
systematically and frequently compiling the bank's high-level 
performance information. Ex-Im officials stated that they are in the 
beginning stages of putting into place a new data reporting system that 
will include improved capabilities for the compiling and management 
review of information related to its small business performance 
measures. In addition, though preliminary data provided to us for 
fiscal year 2007 had not been shared internally, Ex-Im officials said 
that they plan to report regularly on data from the May 2008 Small 
Business Plan's measures to relevant management and staff in the future.

Table 1: Status of Ex-Im's Efforts to Apply Practices to Facilitate Use 
of Small Business Performance Information:

Key practice: Demonstrating management commitment; 
Examples of practice: Agency managers can demonstrate commitment to 
results-oriented management through leading and involving staff from 
different levels in regular performance review meetings to discuss 
progress made toward achieving results; 
Ex-Im efforts to apply practice: 
* Small Business Committee meetings discuss some performance 
information on ad-hoc basis; 
* Ex-Im has not held small business performance review meetings. 

Key practice: Aligning goals and measures; 
Examples of practice: Agencies can encourage greater use of performance 
information by aligning program performance measures with goals and day-
to-day activities; 
Ex-Im efforts to apply practice: 
* Most small business performance standards clearly link to measures; 
* Some standards lack measures. 

Key practice: Improving the usefulness of performance information[A]; 
Examples of practice: To ensure performance information meets users' 
needs, agencies can implement practices such as using an assessment 
tool to document the intended use of a measure, assess the information 
and system in which data are kept, and identify any limitations in 
data; 
Ex-Im efforts to apply practice: 
* Some measures revised or clarified in May 2008 plan to be more useful 
and relevant; 
* No data systems or processes established to compile, analyze, and 
disseminate information from measures to date; 
* Ex-Im is beginning to implement a new data reporting system.

Key practice: Developing agency capacity; 
Examples of practice: Agencies can build analytical capacity to use 
performance information by providing training to staff on setting 
performance standards and measures, analyzing data, and using 
information to revise standards and measures; as well as by providing 
staff access to technical resources and evaluation support staff; 
Ex-Im efforts to apply practice: 
* Ex-Im has not provided institutional training to staff in this area; 
* Office responsible for data analysis has no designated technical or 
evaluation support staff. 

Key practice: Communicating performance information[B]; 
Examples of practice: To enhance communication among staff and 
stakeholders, agencies can provide performance updates through regular 
e-mail; distribute performance review meeting minutes; or use visual 
tools such as poster displays, performance score cards, or agency 
intranet sites to share performance information; 
Ex-Im efforts to apply practice: 
* Small Business Plan not widely disseminated within agency; 
* Information on some measures disseminated to staff via quarterly e-
mail updates and reports; 
* Preliminary results for some other measures compiled but not 
disseminated internally to date; 
* Officials plan to disseminate 2008 plan and to report data from the 
plan's measures internally. 

Source: GAO analysis.

[A] To be useful, performance information should ideally meet users' 
needs for completeness, accuracy, consistency, timeliness, relevance, 
accessibility, and ease of use.

[B] We previously reported that frequent, regular communication is key 
for managers to inform staff and other stakeholders of their commitment 
to achieve the agency's goals and to keep those goals in mind as they 
pursue day-to-day activities. 

[End of table] 

Conclusions:

While Congress has repeatedly directed Ex-Im to increase its efforts-- 
and its financing--for small businesses, in the 2006 Reauthorization 
Act it provided more detailed, wide-ranging guidance for a systematic 
approach to measure and assess Ex-Im's small business financing 
activities. That legislation calls for certain organizational changes, 
and for the development of a framework for setting goals and tracking 
progress. In response, Ex-Im has developed a small business plan that 
contains performance standards relevant to most, although not all, of 
the functions referred to in the act. In particular, Ex-Im has 
developed performance standards for improving customer service and 
outreach and for modernizing and streamlining its processes.

We found, however, there are ways in which Ex-Im can improve its 
performance standards. For example, for some functions referred to in 
the act, Ex-Im has not developed performance standards that directly 
apply. In addition, while the act calls for Ex-Im to determine how well 
it is achieving the functions through its performance standards, some 
of the performance measures Ex-Im has developed to do this lack 
measurable targets and time frames. In addition, with respect to small 
businesses owned by socially and economically disadvantaged individuals 
and by women, Ex-Im has recently introduced a performance standard for 
increasing financing. However, Ex-Im has not developed a specific 
performance measure to track this financing and has cited challenges 
with respect to doing so. While there is some validity to Ex-Im's 
concerns regarding the limited reliability of data for identifying 
these businesses, we noted that Ex-Im has reported estimated values for 
certain types of its financing in this area. Thus, despite the 
limitations Ex-Im faces, it has already taken steps to report on its 
performance with regard to these businesses.

Finally, while Ex-Im has produced performance standards and performance 
measures, it is in the early stages of incorporating the resulting 
performance information into its management practices and culture. For 
a number of aspects of its small business financing, Ex-Im is just 
starting to collect and assess information. It now faces an ongoing 
challenge of using this information effectively through practices such 
as widespread communication and relevant training.

Recommendations for Executive Action:

We make the following three recommendations:

1. To more fully address the mandate in the 2006 Reauthorization Act 
regarding performance standards related to assisting small businesses:

We recommend that Ex-Im establish standards specifically addressing 
those functions referred to in the 2006 act that are not directly 
addressed by its current performance standards.

2. To improve Ex-Im's ability to obtain critical information from its 
performance measures on how well it is achieving its performance 
standards to improve small business assistance:

We recommend that Ex-Im review those performance measures which lack 
measurable targets and time frames and revise the measures to provide 
those elements, in the context of available information.

3. With respect to its lack of performance measures for its standard of 
increasing financing for small businesses owned by socially and 
economically disadvantaged individuals and by women:

We recommend that Ex-Im take steps to establish performance measures, 
such as through establishing a measure based on the estimated data it 
currently reports and identifying ways to improve the reliability of 
its data in this area.

Agency Comments and Our Evaluation:

We provided a draft of this report to the Export-Import Bank of the 
United States. We received written comments from the Chairman and 
President of Ex-Im Bank, which are reprinted in appendix V. The 
Chairman and President reiterated our message that Ex-Im has standards 
for most of the functions referred to in the 2006 Reauthorization Act 
and stated that Ex-Im found the information in the report useful for 
the bank's planning efforts. He stated that Ex-Im concurred with our 
recommendations and he identified steps the bank will take to implement 
them.

We will send copies of this report to the appropriate congressional 
committees and the Export-Import Bank of the United States. We also 
will make copies available to others upon request. 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) 512-4128 or [email protected]. 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: Scope and Methodology:

The Export-Import Bank Reauthorization Act of 2006 mandated that the 
Export-Import Bank (Ex-Im) develop--and GAO conduct a study of-- 
performance standards for determining the extent to which Ex-Im has 
successfully carried out its assistance to small businesses. The 
mandate places a special emphasis on Ex-Im's assistance to small 
businesses owned by socially and economically disadvantaged individuals 
and those owned by women. In response to the mandate, this report (1) 
evaluates the extent to which Ex-Im's performance standards address 
certain bank functions referred to in the 2006 Reauthorization Act 
related to small businesses, (2) evaluates how effectively Ex-Im is 
measuring the achievement of these performance standards related to 
small businesses, including those related to small businesses owned by 
socially and economically disadvantaged individuals and by women, and 
(3) evaluates how Ex-Im has used performance information in assisting 
small businesses and what steps Ex-Im has taken to facilitate and 
enhance that use.

To assess the extent to which Ex-Im's performance standards address the 
functions referred to in the 2006 Reauthorization Act, we reviewed 
section 19 of the Export-Import Bank Reauthorization Act of 2006 (P.L. 
109-438) to identify the functions contained in the statutory 
provisions referred to in the requirement for performance standards. 
With the assistance of our General Counsel's office, we identified and 
compiled a list of the relevant functions, which we provided to Ex-Im 
on March 31, 2008, for its review and comment as to completeness and 
accuracy.

We also compiled a list of Ex-Im's small business performance standards 
based on a review of Ex-Im's 2006 Small Business Plan and its updated 
2008 Small Business Plan. We identified 28 performance standards in 
that plan. Although the plan refers to "goals," "key goals," and "key 
performance standards," for the purposes of this review, based on our 
internal discussions and concurrence from Ex-Im officials, we 
determined that these concepts are equivalent to performance standards, 
or the level of performance to be achieved by a program or activity.

In addition, we reviewed the identified legislative functions and 
compared them to Ex-Im's performance standards to determine which, if 
any, of the standards were relevant to each function. In some cases, we 
found that multiple performance standards were relevant to a function, 
and some performance standards were relevant to more than one function. 
We determined that Ex-Im's performance standards were not applicable to 
2 of the 30 functions because the functions were specific to the 
creation of a position within the bank relevant to small business 
concerns. Finally, we analyzed the extent to which Ex-Im's performance 
standards address each function, to determine whether the standards 
generally address all aspects of the respective function, address some 
aspects of the function, or do not directly address the function. In 
conducting this analysis, two analysts independently analyzed the 
functions in comparison to the standards and subsequently discussed any 
areas where their analyses differed. Another analyst and a 
methodologist subsequently reviewed their work for consistency, 
accuracy and logic, and comprehensiveness.

To evaluate how effectively Ex-Im is measuring the achievement of its 
performance standards, we reviewed Ex-Im's 2006 Small Business Plan and 
its Small Business Performance Standards document. On May 19, 2008, Ex- 
Im provided us with its 2008 Small Business Plan (updated 2006 plan.) 
We identified 27 measures in the 2008 plan that Ex-Im was using to 
assess the extent to which it was achieving its goals in the plan. For 
the purposes of this review, we considered the 27 measures Ex-Im's 
performance measures. We assessed Ex-Im's performance measures using 
eight key attributes of successful performance measures developed in 
our previous work, including having clarity, linking to one or more 
goal (performance standard) in the Small Business Plan, addressing core 
program activities, being observable, having measurable targets, 
specifying time frames, constituting limited overlap, and covering one 
or more governmentwide priorities. We have used this methodology to 
assess and report on performance measures for the Internal Revenue 
Service's income tax filing season program,[Footnote 21] and for the 
Small Business Administration's 7(a) loan program.[Footnote 22] We also 
coordinated with several experts within GAO on performance-measure- 
related issues.

Two analysts conducted separate assessments of measures against the 
attributes. They reached agreement on the extent to which the measures 
fully addressed, partially addressed, or did not address the 
attributes. The coding worked as follows: "fully address" was when the 
measure contained all the elements of an attribute; "partially address" 
was when the measures contained at least one but not all the elements 
of an attribute; and "does not address" was when the measure did not 
contain any elements of an attribute. An assistant director reviewed 
the analysis and the three individuals came together to reach a final 
consensus. A senior methodologist reviewed the methodology and the 
matrix for completeness and balance.

To assess how Ex-Im has used performance information from its 
assistance to small businesses and what steps it has taken to 
facilitate and enhance that use, we interviewed Ex-Im officials and 
reviewed Ex-Im documents, including its annual reports and Small 
Business Plan. Our interviews with Ex-Im officials included discussions 
on how they have used performance information to manage and steps they 
have taken to implement key practices we have identified for 
facilitating the use of this information, including demonstrating 
management commitment, improving the usefulness of performance 
information to better meet management's needs, developing agency 
capacity, and frequently and effectively communicating performance 
information. We previously reported that agencies can apply these 
practices to enhance or facilitate the use of performance information. 
[Footnote 23] We also reviewed preliminary data Ex-Im provided to us on 
the results of its efforts to assist small businesses in fiscal year 
2007, as well as minutes of focus group meetings Ex-Im conducted with 
customers between September 2006 and June 2007, and minutes of Ex-Im's 
Small Business Committee Meetings held between March 2006 and March 
2008.

We determined that the data used in this report were sufficiently 
reliable for our purposes. Any Ex-Im financial data we reported were 
for background purposes only and have been audited by public auditors; 
any Ex-Im preliminary performance information we discussed was for 
illustrative purposes and its reliability was not within the scope of 
this report. We conducted this performance audit from November 2007 to 
July 2008, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives.

[End of section]

Appendix II: Ex-Im's Small Business Performance Standards:

We identified 28 performance standards for small business assistance in 
Ex-Im's 2008 Small Business Plan, released in May 2008. The performance 
standards, listed in table 2 below, fall into nine subject or product 
areas.

Table 2: Ex-Im's Performance Standards for Assisting Small Business 
Exporters:

Subject or Product Area: Overarching; 
No.: 1; 
Description: To make available, from the aggregate loan, guarantee, and 
insurance authority available to Ex-Im, not less than 20percent of such 
authority for each fiscal year to directly support exports by small 
businesses.

Subject or Product Area: Overarching; 
No.: 2; 
Description: To continue to grow the dollar amount of Ex-Im 
authorizations for small businesses and for minority-owned businesses 
or women-owned businesses.[A].

Subject or Product Area: Overarching; 
No.: 3; 
Description: To continue to grow the number of export transactions 
involving small businesses and minority-owned businesses or women-owned 
businesses, supported by Ex-Im. 

Subject or Product Area: Overarching; 
No.: 4; 
Description: Awareness--Information about the assistance Ex-Im can 
provide is readily available to small businesses, regardless of 
industry, ownership, geographic location, etc.

Subject or Product Area: Overarching; 
No.: 5; 
Description: Accessibility--Small businesses have fast and easy access 
to Ex-Im in order to learn about its product offerings and apply for 
financing support.

Subject or Product Area: Overarching; 
No.: 6; 
Description: Responsiveness--Small businesses receive answers about the 
availability of financing in a timely manner that facilitates business 
activity.

Subject or Product Area: Customer service; 
No.: 7; 
Description: Be recognized as providing excellent customer service to 
the small business exporting community.

Subject or Product Area: Distribution channels; 
No.: 8; 
Description: Expand use of all programs through active channels to 
directly support small business.

Subject or Product Area: Distribution channels; 
No.: 9; 
Description: Engage new channels specifically to support small 
business. 

Subject or Product Area: Distribution channels; 
No.: 10; 
Description: Add new distribution partners.

Subject or Product Area: Outreach and marketing; 
No.: 11; 
Description: Increase outreach to small business exporters and 
multipliers.

Subject or Product Area: Outreach and marketing; 
No.: 12; 
Description: Continue to train small business exporters and 
partners/multipliers with regard to Ex-Im products and processes.

Subject or Product Area: Outreach and marketing; 
No.: 13; 
Description: 
Expand the marketing channels utilized to reach small business 
exporters and multipliers.

Subject or Product Area: Outreach and marketing; 
No.: 14; 
Description: Improve communication with insurance broker and city/state 
partner multipliers.

Subject or Product Area: Ex-Im On-line system; 
No.: 15; 
Description: Enhance and improve features of the Ex-Im Online system in 
order to maximize the benefits and value provided to exporters, in 
particular small businesses, in electronic submission, processing and 
servicing, and policy management.

Subject or Product Area: Ex-Im On-line system; 
No.: 16; 
Description: Reduce cycle time of applications and policies processing. 

Subject or Product Area: Ex-Im On-line system; 
No.: 17; 
Description: Improve consistency and quality of data and services 
provided, particularly to small business.

Subject or Product Area: Ex-Im On-line system; 
No.: 18; 
Description: Reengineer business processes, particularly for products 
and programs used by small businesses, as well as those programs that 
provide significant indirect support for those businesses. 

Subject or Product Area: Working Capital Guarantee Program; 
No.: 19; 
Description: Growth target for the Working Capital Guarantee Program is 
to increase small business final commitment authorizations to $1.12 
billion in 3 years. 

Subject or Product Area: Short-Term Export Credit Insurance Programs; 
No.: 20; 
Description: Expand the use of (Short-Term Export Credit) insurance 
products by small business exporters.

Subject or Product Area: Short-Term Export Credit Insurance Programs; 
No.: 21; 
Description: Improve (Short-Term Export Credit Insurance) products so 
they are easier to understand, easier to use, and provide more value to 
small business exporters.

Subject or Product Area: Other Ex-Im Bank Small Business Products; 
No.: 22; 
Description: Expand use of medium and long-term products in direct 
support of small business. 

Subject or Product Area: Other Ex-Im Bank Small Business Products; 
No.: 23; 
Description: Expand indirect support of small businesses acting as 
suppliers and sub suppliers to large businesses that are beneficiaries 
of Ex-Im Bank financing. 

Subject or Product Area: Small Business Committee; 
No.: 24; 
Description: Provide a bank-wide focus on small business.

Subject or Product Area: Small Business Committee; 
No.: 25; 
Description: Report and evaluate each unit's small business 
performance. 

Subject or Product Area: Small Business Committee; 
No.: 26; 
Description: Identify opportunities for cross-selling and expanding the 
use of bank programs for small business.

Subject or Product Area: Small Business Committee; 
No.: 27; 
Description: Measure progress toward meeting the plan/objectives and 
adjust actions.

Subject or Product Area: Small Business Committee; 
No.: 28; 
Description: Serve as a vetting forum for new small business 
initiatives. 

Source: GAO analysis of Ex-Im's 2008 Small Business Plan.

[A] The Reauthorization Act refers to businesses owned by socially and 
economically disadvantaged individuals and those owned by women. Ex-Im 
refers to these businesses as minority and women-owned businesses.

[End of table]

[End of section]

Appendix III: Analysis of Ex-Im's Performance Standards Relative to 
Legislative Functions:

Figure 2: Extent to Which the Functions Referred to in the 2006 Export- 
Import Bank Reauthorization Act Are Addressed by Ex-Im's Performance 
Standards for its Assistance to Small Businesses:

[See PDF for image] 

Functions referred to in the 2006 Reauthorization Act: As a matter of 
policy, encourage the participation of small business in international 
commerce. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: Develop program 
which gives fair consideration to making loans and providing guarantees 
for the export of goods and services by small businesses. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: Aid, counsel, 
assist, and protect, insofar as is possible, the interests of small 
business concerns in order to preserve free competitive enterprise. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: Designate an 
officer responsible for all matters affecting small business concerns. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: N/A: personnel. 

Functions referred to in the 2006 Reauthorization Act: (Responsibility 
of the above officer) Advise small business concerns regarding 
opportunities in the functions of the Bank. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: (Responsibility 
of the above officer) Advise small businesses with particular emphasis 
on conducting outreach and increasing loans to socially and 
economically disadvantaged small businesses. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: (Responsibility 
of the above officer) Advise small businesses with particular emphasis 
on conducting outreach and increasing loans to small businesses owned 
by women. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: (Responsibility 
of the above officer) Advise small businesses with particular emphasis 
on conducting outreach and increasing loans to small businesses 
employing fewer than 100 employees. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [C]. 

Functions referred to in the 2006 Reauthorization Act: The Director 
appointed to represent the interests of small business shall ensure 
that the Bankï¿½s financial and other re-sources are (to the maximum 
extent possible) appropriately used for small business needs. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: Not less than 20 
percent of Bankï¿½s aggregate loan, guarantee, and insurance authority 
should be used to finance exports directly by small businesses. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: From the above 
amount made available, it shall be a goal of the Bank to increase the 
amount made available to finance exports directly by socially and 
economically disadvantaged small businesses and small businesses owned 
by women.[D] 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: Use amount set 
aside above (not less than 20 percent...) to offer financing for small 
business exports on terms which are fully competitive with regard to 
interest rates and without regard to a disapproval by any other federal 
agency. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: Utilize part of 
amount set aside to provide lines of credit or guarantees to consortia 
of small or medium size banks, export trading companies, State export 
finance agencies, export financing cooperatives, small business 
investment companies, or other financing institutions or entities in 
order to finance small business exports. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: For the above, 
financing shall only be made available where consortia or participating 
institutions agree to undertake processing, servicing, and credit 
evaluation functions in connection with such financing. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [B]. 

Functions referred to in the 2006 Reauthorization Act: To maximum 
extent possible, delegate authority to consortia/institutions/entities 
to approve financing referred to above. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [B]. 

Functions referred to in the 2006 Reauthorization Act: In administering 
consortia program (utilizing part of set aside), provide technical 
assistance to participating consortia. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [C]. 

Functions referred to in the 2006 Reauthorization Act: In administering 
program (utilizing part of set aside), the Bank may require such 
consortia periodically to furnish information
to the Bank regarding the number and amount of loans made and the 
creditworthiness of the borrowers. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [B]. 

Functions referred to in the 2006 Reauthorization Act: Promote small 
business exports and small business export financing programs in 
cooperation with Commerce. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [B] 

Functions referred to in the 2006 Reauthorization Act: Promote small 
business exports and small business export financing programs in 
cooperation with SBA/Office of International
Trade. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [C]. 

Functions referred to in the 2006 Reauthorization Act: Maintain liaison 
with SBA and other departments/agencies in matters affecting small 
businesses.
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [C]. 

Functions referred to in the 2006 Reauthorization Act: Promote small 
business exports and small business export financing programs in 
cooperation with the private sector, particularly small business 
organizations, State agencies, chambers of commerce, banking 
organizations, export management companies, export trading companies, 
and private industry. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: Provide, through 
creditworthy trade associations, export trading companies, State export 
finance companies, export finance cooperatives, and other multiple-
exporter organizations, medium term risk protection coverage for 
members and clients of such organizations. Coverage shall be made 
available under a single risk protection policy covering its members or 
clients. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [B]. 

Functions referred to in the 2006 Reauthorization Act: Implement 
technology improvements designed to improve small business outreach, 
including allowing use of Internet to apply for small business programs.
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: Undertake 
efforts to enhance the Bankï¿½s capacity to provide information about its 
programs to small and rural companies which have not previously 
participated in the programs. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [C]. 

Functions referred to in the 2006 Reauthorization Act: Small Business 
Division is established to carry out functions and activities relating 
to outreach, feedback, product improvement, and transaction advocacy 
for small business concerns. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: (Small Business 
Division) to advise and seek feedback from small business concerns on 
opportunities and benefits for small businesses in financing products 
offered by the Bank, with particular emphasis on conducting outreach, 
enhancing the tailoring of products to small business needs, and 
increasing loans to small businesses. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: (Small Business 
Division) to provide oversight of development, implementation, and 
operation of technology improvements to strengthen small business 
outreach, including statutorily required technology improvements. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: Ensure that each 
operating division within the Bank has staff that specializes in 
processing transactions that primarily benefit small businesses (Small 
Business Specialists). 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: N/A: personnel. 

Functions referred to in the 2006 Reauthorization Act: Establish a 
Small Business Committee to coordinate the Bankï¿½s initiatives and 
policies with respect to small business concerns, including: processing 
and underwriting of transactions involving direct exports by small 
businesses, and development and coordination of efforts to implement 
new or enhanced Bank products pertaining to small businesses. 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Functions referred to in the 2006 Reauthorization Act: Establish within 
the Small Business Division an office whose sole function shall be to 
continue/enhance outreach to, and increase the total amounts of loans, 
guarantees, and insurance provided by the Bank to support exports by, 
socially and economically disadvantaged small businesses and small 
businesses owned by women.[D] 
Extent to which legislative function is addressed by Ex-Imï¿½s 
performance standards: [A]. 

Source: GAO analysis of Ex-Imï¿½s small business performance standards to 
the statutory provisions referred to in the requirement for
performance standards in section 19 of the 2006 Export-Import Bank 
Reauthorization Act. 

[A] Ex-Imï¿½s performance standards generally address all aspects of the 
function. 
 
[B] Ex-Imï¿½s performance standards address some aspects of the function. 

[C] None of the performance standards appear to directly address the 
function. 

[D] The Reauthorization Act refers to businesses owned by socially and 
economically disadvantaged individuals and those owned by women. Ex-Im 
refers to these businesses as minority and women-owned businesses.

N/A: personnel = Ex-Imï¿½s performance standards are not applicable to 
the function because the function is specific to the creation of a 
position within the bank relevant to small business concerns. 

[End of figure]

[End of section]

Appendix IV: Analysis of Targets and Time Frames in Ex-Im's Performance 
Measures:

Ex-Im developed 27 performance measures to assess whether the bank is 
achieving the 28 performance standards in its 2008 Small Business Plan. 
Table 3 shows the extent to which these performance measures have 
measurable targets and time frames.

Table 3: Extent to Which Ex-Im's 27 Performance Measures Have 
Measurable Targets and Time Frames:

No.: 1; 
Measure: Ex-Im Bank will utilize the results of the customer service 
focus groups to establish the baseline for future improvements and 
appropriate metrics for on-going assessments; 
Attributes: Measurable Target: [Empty]; 
Attributes: Time Frame: [Empty].

No.: 2; 
Measure: Financial institutions: tracking of actual activity by 
products, transactions, and dollar volumes (authorizations); 
Attributes: Measurable Target: [Empty]; 
Attributes: Time Frame: [Empty].

No.: 3; 
Measure: Insurance Brokers: tracking of actual activity by products, 
transactions, and dollar volumes (authorizations); 
Attributes: Measurable Target: [Empty]; 
Attributes: Time Frame: [Empty].

No.: 4; 
Measure: City/state partners: via voluntary reporting, track activity 
by products, transactions, and dollar volume (authorizations); 
Attributes: Measurable Target: [Empty]; 
Attributes: Time Frame: [Empty].

No.: 5[A]; 
Measure: Regional domestic development officers will be measured 
against their individual targeted goals - based on need within their 
region. Goals will include number of transactions, dollar value of 
transactions, new-to-Ex-Im transactions, new multipliers and outreach 
activity, including focus on minority and women-owned small business 
exporters; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 6; 
Measure: Trade associations: measurement will be made of the number of 
new member organizations that have collaborated with Ex-Im and to the 
extent that the collaboration provides access to the organization's 
small business exporters. Benchmarks will include success in 
establishing Web-links, member communication including e-newsletter, 
publications and surveys, speaking opportunities at association 
conferences and trade shows and access to association leadership; 
Attributes: 
Measurable Target: [Empty]; 
Attributes: Time Frame: [Empty].

No.: 7; 
Measure: Degree of success in getting incremental USG involvement with 
Ex-Im in terms of new activity with small business exporters using Ex-
Im products; 
Attributes: Measurable Target: [Empty]; 
Attributes: Time Frame: [Empty].

No.: 8; 
Measure: Increase the number of business partners by no less than 20 
per annum through fiscal year 2010; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 9[A]; 
Measure: Monitor number of outreach events (speaking engagement, trade 
shows, conferences) undertaken by staff; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 10; 
Measure: Growth of 5 percent per annum for minority and women-owned 
small business speaking engagements, conferences and training sessions 
through fiscal year 2010; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 11; 
Measure: Report the number of Ex-Im-Bank-sponsored training events, 
attendees and revenue generated; 
Attributes: Measurable Target: [Empty]; 
Attributes: Time Frame: [Empty].

No.: 12; 
Measure: Track the type, number, and volume of direct mail campaigns 
and the leads from each separate campaign; 
Attributes: Measurable Target: [Empty]; 
Attributes: Time Frame: [Empty].

No.: 13; 
Measure: Track the number of additional third-party Web links obtained 
by the regional staff, the minority and women-owned staff, and the 
association development staff; 
Attributes: Measurable Target: [Empty]; 
Attributes: Time Frame: [Empty].

No.: 14; 
Measure: Maintain a level of not less than 200 small business exporter 
outreach events annually; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 15; 
Measure: Improve cycle time and productivity by 15 percent a year 
(within 12 months of deployment); 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 16; 
Measure: Reduce policy cancellation rates attributable to customer 
dissatisfaction with administrative requirements and application 
processing times; 
Attributes: Measurable Target: [Empty]; 
Attributes: Time Frame: [Empty].

No.: 17; 
Measure: Increase the total dollar amount of Working Capital Guarantee 
Program authorizations over fiscal year 2007 among current and new 
lenders by approximately 13% in 3 years, to reach the target of $1.12 
billion; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 18; 
Measure: Achieve $400 million in Working Capital Guarantee Program 
authorizations (15 to 20 transactions) committed under Fast Track in 3 
years. In fiscal year 2007 Business Credit completed 9 Fast Track 
transactions totaling $173 million; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 19; 
Measure: Relationship managers to call on all major customers of the 
Working Capital Guarantee Program annually; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 20; 
Measure: Work with Short Term Trade Finance to identify exporters 
needing both Working Capital Guarantee Program loans and credit 
insurance; 
Attributes: Measurable Target: [Empty]; 
Attributes: Time Frame: [Empty].

No.: 21; 
Measure: Increased retention rate for small business multibuyer 
policies, from historical rate of 75 percent to 85 percent in 3 years. 
Although some turnover is natural as customers graduate from the Ex-Im 
insurance program and obtain private-sector coverage, other customers 
are unable to use the policies effectively. By implementing a retention 
program and working with these customers more closely, Ex-Im Bank plans 
to reach a retention rate of 85 percent within 3 years; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 22; 
Measure: Increased volume in terms of number of policies, amount of 
authorizations, and amount of shipments, under short-term exporter 
single and multibuyer policies. The growth target for these policies is 
to increase total small business authorizations to $1.3 billion; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 23; 
Measure: Improve average transaction cycle time for medium-term 
products by 20 percent over the next 3 years as measure in days from 
receipt to authorization; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 24; 
Measure: Achieve $1.2 billion per annum in direct small business 
support via all TFI products by 2010; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 25; 
Measure: Transaction processing times for short term exporter insurance 
products: 
* New multibuyer policy quotations: within 15 days of submission; 
* Multibuyer policy renewals: 75 percent renewed 30 days prior to 
expiry date; 95 percent renewed prior to expiry date; 
* Exporter single buyer policies: $300,000 to $1 million within 10 to 
15 days; 
* Special buyer credit limits (new and renewal): $300,001 to $1 million 
within 10-15 days; over $1 million in 15 to 30 calendar days; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 26; 
Measure: Transaction processing times for short-term working capital 
guarantee products: 
* Non-delegated authority transactions of $2.5 million or less within 
30 days of submission; 
* Nondelegated authority transactions of greater than $2.5 million and 
less than or equal to $5million - within 60 days of submission; 
* Non-delegated authority transactions of more than $5 million within 
90 days of submission; 
* Waiver requests within 10 days of submission; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

No.: 27; 
Measure: Transaction processing times for short-term bank-held 
insurance products, medium-term insurance and guarantees, and long-term 
sovereign guarantees: 
* Issuing bank credit limits (new and renewal): 80 percent completed 
within 15 days of submission; 
* New financial institution policies: 80 percent completed within 60 
days of submission; 
* Medium-term loans and guarantees: 5 percent completed within 60 days 
of submission; 
Attributes: Measurable Target: [Check]; 
Attributes: Time Frame: [Check].

Source: GAO analysis and Ex-Im 2008 Small Business Plan.

[A] We found that Ex-Im has targets and time frames for these measures 
but Ex-Im has not yet incorporated them into its 2008 Small Business 
Plan. 

[End of table] 

[End of section]

Appendix V: Comments from the Export-Import Bank:

Export-Import Bank Of The United States: 
James H. Lambright, Chairman And President: 
811 Vermont Avenue, N.W.
Washington, D.C. 20571: 
Phone: (202) 565-3500: 
Fax: (202) 565-3513: 
Email: [email protected]: 

July 8, 2008: 

Loren Yager: 
Director, International Affairs and Trade: 
U.S. Government Accountability Office: 
Washington, D.C. 20548: 

Dear Mr. Yager: 

Thank you for providing the Export-Import Bank of the United States 
("Ex-Im Bank") with the opportunity to comment on GAO's June 26, 2008 
draft report.

Since enactment of the 2006 Reauthorization Act ("Act"), Ex-Im Bank has 
developed 28 performance standards for its "assistance to small 
businesses, ranging from providing excellent customer service to 
increasing outreach." We are pleased that GAO has concluded that those 
28 performance standards address most of the functions referred to in 
the Act. 

Ex-Im Bank is committed to providing assistance to small businesses, 
including minority- and women-owned small businesses. We believe we 
demonstrated to your team that we have produced results for many of 
those functions regardless of whether or not we have performance 
standards for them. 

The following are Ex-Im Bank's responses to GAO's recommendations: 

1 & 2. "We recommend that Ex-lm establish standards specifically 
addressing those functions referred to in the 2006 act that are not 
directly addressed by it current performance standards." 

"We recommend that Ex-Im review performance measures which lack 
measurable targets and time frames and revise the measures to provide 
those elements, in the context of available information."

Ex-Im Bank agrees with both recommendations and will incorporate them 
into the 2009 Small Business Plan, which will be the focus of the 
Senior Vice President for Small Business and the Small Business 
committee in the next few months.

3. "With respect to its lack of performance measures for its standard 
of increasing financing for small businesses owned by socially and 
economically disadvantaged individuals and by women, we recommend that 
Ex-Im take steps to establish performance measures such as through 
establishing a measure based on the estimated data it currently reports 
and identifying ways to improve the reliability of its data in this 
area."

Ex-Im does attempt to collect data regarding its support for small 
businesses owned by socially and economically disadvantaged individuals 
and by women. However, Ex-Im faces several challenges in obtaining this 
data. Although some applicants provide this information, the response 
is quite tow and Ex-Im cannot require applicants to provide the 
information. Ex-Im also cross checks applicant names with data provided 
by Dun & Bradstreet (D&B) and uses the D&B indicators for women and 
minority owned businesses if it is available. However D&B has indicated 
that they also have difficulty gathering this data and cannot vouch for 
the accuracy of the data if it is available.

Although there are limitations in the accuracy and availability of data 
to identify small businesses owned by socially and economically 
disadvantaged individuals and by women, Ex-Im recognizes the importance 
of measuring its progress in increasing assistance in these areas. Ex-
lm will develop performance measures with measurable targets and time 
frames within the limitations of the data available and work to improve 
data collection and accuracy.

We very much appreciate GAO's cooperative and informative approach to 
the review of small business performance standards. Ex-Im Bank is new 
to developing performance standards that meet GAO's eight key 
attributes of effective performance measures and therefore found the 
information exchange between our two teams to be a productive and 
educational two-way street. This exchange will facilitate our 
continuous efforts to develop a performance plan that helps produce 
better and increased support for small business exporters. 

Sincerely, 

Signed by: 

James H. Lambright: 

[End of section]

Appendix VI: GAO Contact and Staff Acknowledgments:

GAO Contact:

Loren Yager, (202) 512-4128 or [email protected]:

Acknowledgments:

In addition to the person named above, the following staff made key 
contributions to this report: Celia Thomas, Assistant Director; Lisa 
Helmer; and Nina Pfeiffer. The following staff provided technical 
assistance: Karen Deans, David Dornisch, Etana Finkler, and Ernie 
Jackson. 

[End of section]

Footnotes: 

[1] GAO, Managing Results: Enhancing Agency Use of Performance 
Information for Management Decision Making, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-05-927] (Washington, D.C.: Sept. 
9, 2005).

[2] Although Ex-Im refers to "goals," "key goals," and "key performance 
standards" in its small business planning documents, for the purposes 
of this review, based on internal discussions and discussions with Ex- 
Im officials, we determined that these concepts are all equivalent to 
performance standards, or the level of performance to be achieved by a 
program or activity. 

[3] Ex-Im provides export credit insurance to protect U.S. exporters 
against nonpayment by their customers either directly to exporters or 
to banks that in turn finance U.S. exporters.

[4] One specific type of loan guarantee is a credit guarantee facility. 
Credit guarantee facilities are lines of credit between a guaranteed 
lender (i.e., a captive finance company or financial institution) and a 
foreign bank (or occasionally a large foreign buyer). Ex-Im guarantees 
the repayment of the foreign bank's obligations. The foreign bank then 
makes credit available to the end user of the U.S. exports and takes 
the repayment risk of that local company.

[5] See GAO, Export-Import Bank: Changes Would Improve the Reliability 
of Reporting on Small Business Financing, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-06-351] (Washington, D.C.: Mar. 
3, 2006); and Export Promotion: Export-Import Bank Has Met Target for 
Small Business Financing Share, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-08-419T] (Washington D.C.: Jan. 17, 2008).

[6] Ex-Im uses SBA's definition of a small business, which uses size 
standards to identify the largest a company can be and still qualify as 
a small business. SBA's size standards vary by industry, and reflect 
average annual receipts or average employment of a firm.

[7] The 2006 Reauthorization Act requires Ex-Im to develop performance 
standards for determining the extent to which it has carried out 
successfully subparagraphs 2(b)(1)(E) and (I) of the Export-Import Bank 
Act and "the functions described in" subsections 3(f)(1), (g)(1), 
(h)(1), and (i)(1) of that act. Subparagraph 2(b)(1)(E) requires Ex-Im 
to take various actions in furtherance of U.S. policies to encourage 
participation of small business in international commerce, and to aid, 
counsel, assist, and protect the interests of small business concerns. 
Subparagraph 2(b)(1)(I) requires Ex-Im to undertake efforts to enhance 
its capacity to provide information about its programs to small and 
rural companies which have not previously participated in the programs. 
We consider these required actions and efforts under subparagraphs 
2(b)(1)(E) and (I) also to be "functions" subject to the performance 
standards requirement.

[8] Six of the 28 performance standards included in the 2008 update to 
the Small Business Plan were new, overarching performance standards 
created in response to the 2006 Reauthorization Act.

[9] The Small Business Committee is responsible for coordinating Ex- 
Im's small business initiatives, among other efforts (12 USC 635a (h)).

[10] The 2006 Reauthorization Act refers to businesses owned by 
socially and economically disadvantaged individuals and those owned by 
women. Ex-Im refers to these businesses as minority and women-owned 
businesses. Ex-Im's characterization of the statutory terms in the act 
is generally consistent with the relevant definitions in the Small 
Business Act and its implementing regulations.

[11] While one or more of Ex-Im's performance standards are relevant to 
these legislative functions, the standards do not address all aspects 
of the functions.

[12] We determined that Ex-Im's performance standards are not 
applicable to two of the legislative functions because the functions 
are specific to the creation of a position within the bank relevant to 
small business concerns. 

[13] The officials stated that Ex-Im's outreach database has an 
indicator for whether a business is rural, although this data field 
often has missing values. Ex-Im does track assistance to small 
businesses that are new to its programs. 

[14] Ex-Im has some capability to track outreach to small businesses 
employing fewer than 100 employees within a database on outreach 
efforts, which they are refining.

[15] The U.S. Commercial Service is the trade promotion unit of 
Commerce's International Trade Administration and has trade staff 
located in more than 80 countries. 

[16] The key attributes of successful performance standards are not 
limited to the eight listed here. For example, as part of this review, 
we did not look at objectivity (measure is reasonably free from 
significant bias or manipulation) or reliability (measure produces the 
same result under similar conditions). See appendix I for a full 
explanation of our methodology.

[17] Events include minority and women-owned small business speaking 
engagements, conferences, and training sessions. 

[18] The concept of "practices" as used in this report includes 
administrative or management tools, systems, or processes that agencies 
can implement.

[19] Ex-Im's non-deductible multibuyer insurance product is available 
only to small businesses with less than $5 million in open-account 
sales and covers 95 percent on all foreign receivables.

[20] We previously reported that agencies can apply these practices to 
enhance or facilitate the use of performance information: see GAO, 
Managing for Results: Enhancing Agency Use of Performance Information 
for Management Decision Making, GAO-05-927 (Washington, D.C.: September 
2005). 

[21] GAO, Tax Administration: IRS Needs to Further Refine Its Tax 
Filing Season Performance Measures, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-03-143] (Washington D.C.: Nov. 22, 2002).

[22] GAO, Small Business Administration: Additional Measures Needed to 
Assess 7(a) Loan Program's Performance, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-07-769] (Washington D.C.: July 
13, 2007).

[23] GAO, Managing for Results: Enhancing Agency Use of Performance 
Information for Management Decision Making, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-05-927] (Washington, D.C.: 
September 2005). 

[End of section]

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