Supporting Statement EIB 84-01 updated 2017-02-22

Supporting Statement for Paperwork Reduction Act Submissions

Export-Import Bank and Small Business Administration

Form EIB-SBA 84-01

1. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
   
   Response:
   This is a joint application form for working capital loan guarantees provided by EXIM Bank and the Small Business Administration. EXIM Bank is the U.S. Government agency (created by the Export-Import Bank of 1945 as amended) that facilitates the export financing of U.S. goods and services. This collection of information is necessary under Sec. 635(a) (1) to determine eligibility of applicant for EXIM Bank assistance or participation.
   
   The Small Business Administration is the U.S. Government Agency (created by the Small Business Act, as amended) that aids and assists small businesses to increase their ability to compete in international markets by enhancing their ability to export. This collection of information is necessary under Section 7(a) (14) of the Small Business Act (15 U.S.C. 636 (a) (14) to determine eligibility of applicant for SBA assistance or participation.
   
   

2. Indicate how, by whom and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received form the current collection.
   
   Response:
   The application provides EXIM Bank and Small Business Administration staff with the information necessary to determine if the application and transaction are eligible for EXIM Bank and SBA assistance.
   
   

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submissions of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
   
   Response:
   EXIM Bank is currently working on developing a system that will include the on-line submission of applications. This system is expected to be deployed during the 1^st quarter of FY17.
   
   SBA currently allows Preferred Lender Program (PLP) Export Working Capital Program loan applications to be submitted to SBA electronically using SBA’s electronic origination system E-Tran.
   
   

4. Describe effort to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
   
   Response:
   All applications are independent of each other, i.e. no duplication. In circumstances when some information may already be on file at EXIM Bank, the application includes language allowing the application to indicate so.
   
   

5. If the collection of information impacts small businesses or other small entities describe any methods used to minimize burden.
   
   Response:
   As noted in question number 12, on average the Export-Import Bank received 475 applications per year (from both large and small businesses) and the Small Business Administration received 188(from small businesses). To minimize the burden on these small entities, the form is accessible on-line and the agencies have limited the information collected to that which is necessary for both agencies to make informed decisions about the loan application.
   
   

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
   
   Response:
   The consequence to the Federal program would be that EXIM Bank and SBA would not be able to determine if an application and transaction to be guaranteed is eligible, thereby making it impossible to operate the program.
   
   

7. Explain any special circumstances that would cause an information collection to be conducted in a manner”
   *requiring respondents to report information to the agency more often than quarterly;
   *requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
   *requiring respondents to submit more than an original and two copies of any document;
   *in connection with a statistical survey, that is not designed to produce valid or reliable results that can be generalized to the universe of study;
   *requiring the use of statistical data classification that has not been reviewed and approved by OMB;
   *that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
   *requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.
   
   Response:
   Collection of information is consistent with the guidelines in 5 CRF 1320.6.
   
   

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments.
   
   Response:
   A request for public comments was published in the Federal Register, Vol. 80 No. 102, pg 30457 on May 28, 2015. The comment period ended July 27, 2015. A comment was incorrectly posted to the Federal Register on July 16, 2015. EXIM Bank discovered the comment (still in a “pending_post” status) on December 17, 2015. EXIM Bank and SBA have reviewed and considered the comments and determined their disposition. Below is a description of the changes made to the form in response to the comments received. In addition, attached to this Supporting Statement (as Attachment A) is the complete disposition of the comments received.

A request for public comments was published in the Federal Register, Vol. 80 No. 236, pg 76487 on December 9, 2015. The comment period ended January 8, 2016. No comments were received.

The first change made was to items 8 and 10 on the application checklist. The comment made was that although the checklist requires financial information be “dated within 90 days of the application filing” in fact SBA will accept financial information within 180 days of the application filing. SBA notes that it’s SOP 50 10 5(H) states that SBA will accept financial information within 180 days of due date of application. EXIM Bank however requires financial information be dated within 180 days of the application filing. In response, items 8 and 10 were revised to include the clarification “(SBA applicants only: 180 days).”

The second change made was to item 11 on the application checklist. This item requested information on principal officer/owner compensation. The comment made was that SBA does not require this information. SBA notes that notes that it’s SOP 50 10 5(H) does not require this information. EXIM Bank also notes that this information is not required. Thus, in response to the comment, item 11 was removed from the checklist and the subsequent items re-numbered.

In addition to posting to the Federal Register for comments, EXIM Bank and SBA regularly discuss their programs and documentation with potential users. The application form and revisions thereto were discussed with potential users and staff to determine necessity, practicality and acceptability.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
   
   Response:
   Delegated Authority Lenders, as approved by EXIM Bank, are entitled to retain a certain portion of the facility fee paid by the Exporter. Delegated Authority Lenders serve as one of the means by which the program is made available to the public. SBA lenders are also authorized to retain a portion of certain processing and servicing fees; however neither SBA nor EXIM Bank will provide payments or gifts to respondents as incentive to respond to this information collection.
   
   

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
    
    Response:
    EXIM Bank, SBA, and their officers and employees are subject to the Trade Secret Act, 18 U.S.C. Sec. 1905, which requires them to protect confidential information from disclosure, to the extent permitted by law. In addition, EXIM Bank’s regulations at 12 CRF 404.1 provides that, except as required by law EXIM Bank will not disclose information provided in confidence without the submitter’s consent. SBA has similar regulations at 13 CFR 102.7 that are intended to protect confidential business information from disclosure without consent or waiver from the entity that submitted the information.
    
    

11. Provide additional justification for any question of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered provides. This justification should include the reasons why the agency considered the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
    
    Response:
    EXIM’s answer: No sensitive questions are involved as that term is described by OMB. This information collection does contain questions concerning an applicant’s criminal background in order to make sound determinations concerning an application’s character.

Further, though an individual’s SSN is requested on the application, that particular information is used to order a personal credit report and then is redacted from the document. The individual’s SSN is not stored or retained by EXIM Bank.

SBA’s answer: Submission of Social Security Number (Privacy Act notice) - Under the Privacy Act, the applicant is not required to provide social security number information, and failure to provide social security number may not affect any right, benefit, or privilege to which applicant is entitled. Disclosures of name and other personal identifiers are required for a benefit, however, and SBA requires an applicant seeking financial assistance to provide sufficient information to allow SBA to make a character and credit determination concerning individuals that are borrowers, principals, and guarantors. In determining whether an individual is of good character, SBA considers the person’s integrity, candor, and disposition toward criminal actions. In making loans pursuant to section 7(a) of the SB Act (15 U.S. C. 636(a)(6)), SBA is required to have reasonable assurance that the loan is of sound value and will be repaid, or that it is in the best interest of the Government to grant the financial assistance requested. Additionally, SBA is specifically authorized to verify the applicant’s criminal history, or lack thereof, pursuant to Section 7(a)(1) of the SB Act (15 U.S.C. 636(a)(1)(B)). Further, for all forms of assistance, SBA is authorized to make all investigations necessary to ensure that a person has not engaged in acts that violate or will violate the SB Act or the Small Business Investment Act (15 U.S.C. 634 and 687b(a)). For these purposes, applicant is asked to voluntarily provide social security numbers to assist SBA in making character determinations and to distinguish the individuals listed in this application from other individuals with the same or similar name or other personal identifier.

12. Provide estimates of the hour burden of the collection of information. The statement should include: the number of respondents; frequency of response; annual hour burden; an explanation of how the burden was estimated; and the hour cost burden.

Response:

Based on the average number of loans received over the past three years since this information collection was last submitted for review, the estimated annual burden information for this collection is as follows:

EXIM Bank SBA

Annual Number of Respondents:  475 188

Estimated Time per Respondent:  2.5 hours 2.5 hours

Annual Burden Hours:  1,188 hours 470 hours

Frequency of Reporting of Use:  Annually Annually

Total Burden Hours is the sum of the EXIM Bank and SBA Annual Burden Hours, 1,188 + 470, which equals 1,658 hours annually.

13. Provide an estimate for the total annual cost burden to respondents or records keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in items 12 and 14).
    
    

EXIM Bank Response:

There are no additional costs, such as capital or startup costs associated with this information collection.

SBA Response:
There are no additional costs, such as capital or start up costs associated with this information collection.

14. Provide estimates of annualized costs to the Federal government.

Response:

EXIM Bank SBA
Reviewing time in hours 2 2
Responses per year 475 188
Review time per year 950 376
Average wages per hour $42.5 $35.00
Average cost per year $40,375 $13,160
Benefits and Overhead 20% 100%
Total Government Cost $46,170 $26,320

The annual cost to the Government would be $74,770

15. Explain reasons for and program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

Response: EXIM Bank

The average number of responses has declined over the past three years as the private sector has become more comfortable with the credit risk of larger borrowers and the volume of revenue generated by those customers. Therefore, the burden information reported has been adjusted to reflect the decrease in responses.

Response: SBA
The average number of responses has increased slightly over the past three years. The increase is partially due to the fact that small business’s interest in working capital loan guarantees has increased. Therefore, the burden information reported has been adjusted to reflect this increase.

16. For collection of information whose results will be published, outline plans for

tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

Response:
EXIM Bank response; not applicable. Information collected is not published. Any publishing of information collected is not related to the original purpose of the application.

SBA response; except for the inclusion of aggregated data in various OMB, Congressional or ad hoc reports, the information collected is not published.

17. If seeking approval to not display the expiration date for OMB approval of the

information collection, explain the reasons that display would be inappropriate.

Response:
Not applicable. We are not seeking approval not to display the expiration date.

18. Explain each exception to the certification statement in item 19.

Response:
There are no exceptions.

2. Collection of Information Employing Statistical Methods
   
   

The agency should be prepared to justify its decision not to use statistical methods in any case where such methods might reduce burden or improve accuracy of results.

Response:
Statistical methods are not used in this information collection.

Response to Comments on form EIB-SBA 84-1

As required, EXIM Bank and Small Business Administration (“SBA”) put forth a notice in the Federal Register regarding the form 84-1. There was one comment received from an individual.

The SBA and EXIM Bank have reconciled the comments and provided a disposition. In principal, the comments received were on topics for which SBA has primary responsibility. Unless otherwise noted, EXIM Bank accepts the disposition provided by SBA.

Comments received:

I am providing detailed comments on streamlining the 84-1 application form. I hope you will find these comments helpful.

1. SBA does not need the “C.I.D. No.” and “Intermediary” information listed in the upper left hand corner of page 3.

• It is recommended that these two items be removed.

SBA Response: The “C.I.D No.” and “Intermediary” information will be retained for SBA purposes.

2. The Mailing/Forwarding Instructions on page 15 are confusing and unnecessary. The blocked section at the bottom of the page “For SBA Use Only” is not actually used by SBA. In fact, both ExIm and SBA application submission instructions are subject to periodic changes, and it is not necessary for the form to include this information. Any lender proposing to make the loan will be working with either SBA or ExIm directly, so the guidance is unnecessary.

• Eliminate page 15.

SBA Response: The Mail/Forwarding Instructions are appropriate for submission of applications to the EWCP.

3. Page 9, question 2.h. asks that the applicant “provide alien registration #(s).” This is confusing, may or may not be appropriate, and is likely not entirely responsive. With the revision suggested in 1.k. above, the matter is adequately addressed.

• It is recommended that the statement “provide alien registration #(s)” be deleted.

SBA Response: This information is used by SBA and Ex-Im Bank. The field will remain.

4. The borrower and lender certifications that appear on pages 8-14 need to be reorganized. As presently stated, it is necessary for the lender to sign twice (on pages 8 and 11) and the borrower (and guarantors) to sign twice (on pages 8 and 10). This is confusing and can lead to the inadvertent failure to sign where needed.

• Reorganize the certifications so that there is a single consolidated lender certification and a single consolidated borrower/guarantor certification.

SBA Response: The borrower and lender certifications are separated and need to be signed as presented.

5. The checklist on page 2 should be revised as follows:

1. Item 1 “Brief resume of the principals and key employees; history of business; copy of business plan, if available; identify whether sole proprietorship, general partnership, limited liability company (LLC), corporation and/or subchapter S corporation” should be revised as follows:

• “Brief resume of the principals and key employees” should be a separate line item.

• “Copy of business plan, if available” should be a separate line item.

• “History of business” should not be a separate application item but rather should be addressed by the lender in their credit memo (i.e., item #15)

• “Identify whether sole proprietorship, general partnership, limited liability company (LLC), corporation and/or subchapter S corporation” should not be a separate application item but rather should be added as a series of check-box options in Part A.1 on page 3 (the first section of the application form); alternatively, it could be an item to be addressed by the lender in their credit memo (i.e., item #15)

SBA Response: The stated information needs to be collected per the procedures and regulations of the EWCP and in accordance with 7(a). This information can be addressed in a credit memo but must be listed per procedures and regulations.

2. Item 2 “Explanation of use of proceeds and benefits of the loan guarantee, including details of the underlying transaction(s) for which the loan is needed, including country(s) where the buyers are located.

• This should not be a separate application item but rather should be addressed by the lender in their credit memo (i.e., item #15)

SBA Response: The stated information needs to be collected per the procedures and regulations of the EWCP and in accordance with 7(a). This information can be addressed in a credit memo but must be listed per procedures and regulations.

3. Item 7 “Business financial statements (Balance Sheet, Income Statement, statement of Cash Flows) for the last three years, if applicable, supported by the most recent Federal income tax return for the business. SBA applicants only: Also submit the last three years of signed Federal income tax returns for the business.”

• This misstates the SBA applicant requirement. SBA does not require both 3 years of financial statements and 3 years of tax returns. Rather, SBA may accept tax return in lien of financial statements. Thus, it should read: “SBA applicants only: If not available, submit the last three years of signed Federal income tax returns for the business.”

SBA Response: The stated information needs to be collected per the procedures and regulations of the EWCP and in accordance with 7(a). This information can be addressed in a credit memo but must be listed per procedures and regulations.

4. Item 8 “Current financial statement (interim) dated within 90 days of the date of the application filing.”

• This misstates the SBA applicant requirement. SBA may accept financial statements dated within 180 days of the date of the application filing. Thus, it should read: “Current financial statement (interim) dated within 90 days (SBA applicants only: 180 days) of the date of the application filing.”

SBA response: Per SOP 50 10 5(H), SBA will accept current financial statements within 180 days of due date of application. This section will be changed to reflect the 180 day requirement.

EXIM response: EXIM Bank requires current financial statements within 90 days of the date of application filing. EXIM will continue to indicate that financial statements must be within 90 days of application filing.

5. Item 10 “All Affiliated Companies – Business Financial Statements (Balance Sheet, Income Statement, Aging of Accounts Receivable and Accounts Payable) for the last completed fiscal year end, as well as current statements no older than 90 days from the date of application filing. In addition, submit signed Federal income tax returns for the last fiscal year end or an extension form if not filed after the due date. Important Requirement – Submit a combined or consolidated financial statement for the current period as well as the last fiscal year end (combining all affiliated companies), eliminating any inter-company transactions (sales, receivables, payables, etc.).”

• This misstates the SBA applicant requirement. SBA may accept financial statements dated within 180 days of the date of the application filing. Thus, it should read: “… current statements no older than 90 days (SBA applicants only: 180 days) from the date of application filing…”

• This misstates the SBA applicant requirement. SBA does not require tax returns or an extension form in addition to financial statements. Rather, SBA may accept a tax return in lien of financial statements. Thus, it should read: “(SBA applicants only: If financial statements are not available for the last completed fiscal year, submit the last year signed Federal income tax returns for the business.)” And, it should also read: “… (ExIm applicants only: In addition, submit signed Federal income tax returns for the last fiscal year end or an extension form if not filed after the due date.)”

• Altogether, the recommended re-wording should be like this: “All Affiliated Companies – Business Financial Statements (Balance Sheet, Income Statement, Aging of Accounts Receivable and Accounts Payable) for the last completed fiscal year end, as well as current statements no older than 90 days (SBA applicants only: 180 days) from the date of application filing. (SBA applicants only: If financial statements are not available for the last completed fiscal year, submit the last year signed Federal income tax returns for the business.) (ExIm applicants only: In addition, submit signed Federal income tax returns for the last fiscal year end or an extension form if not filed after the due date.) Important Requirement – Submit a combined or consolidated financial statement for the current period as well as the last fiscal year end (combining all affiliated companies), eliminating any inter-company transactions (sales, receivables, payables, etc.).”

SBA response: Per SOP 50 10 5(H), SBA will accept current financial statements within 180 days of due date of application. This section will be changed to reflect the 180 day requirement.

EXIM response: EXIM Bank requires current financial statements within 90 days of the date of application filing. EXIM will continue to indicate that financial statements must be within 90 days of application filing.

6. Item 11 “Schedule of all principal officer/owner’s compensation for the past three years, and current year to date [if none, please indicate].”

• SBA does not require this. Thus, it should read: “ExIm applicants only: Schedule of all principal officer/owner’s compensation for the past three years, and current year to date [if none, please indicate].”

SBA Response: Per SOP 50 10 5(H), SBA does not require this information. This item will be removed.

EXIM response: EXIM Bank does not require this information. This item will be removed.

7. Item 12 “Signed joint personal financial statement(s) of each major shareholder(s)/partner(s), owner(s), of the company (with 20% or greater ownership, including assets and liabilities of both spouses) and their most recent Federal income tax return (not required for venture capital partners). ”

• This misstates the SBA applicant requirement. SBA does not require tax returns in addition to personal financial statement(s), and SBA does not exempt venture capital partners. Thus, it should read: “Signed joint personal financial statement(s) of each major shareholder(s)/partner(s), owner(s), of the company (with 20% or greater ownership, including assets and liabilities of both spouses). (ExIm applicants only: Also provide their most recent Federal income tax return. Also note that ExIm does not require financials for venture capital partners).”

SBA Response: Per SOP 50 10 5(H), the Lender is required to receive a 4506-T and compare with tax returns, which may require personal tax returns. The information will remain.

8. Item 13 “Estimate of monthly cash flow for the terms of the loan, highlighting the proposed export transaction.”

• For increased clarity this should read: “Month-by-month cash flow projection for the terms of the loan, highlighting the proposed export transaction(s).”

SBA Response: The information as presented will remain.

9. Item 14 “Description of type and value of proposed collateral to support the loan (company assets/export product, i.e., inventory, accounts receivable, other).”

• This should not be a separate application item but rather should be addressed by the lender in their credit memo (i.e., item #15)

SBA Response: The information as presented will remain.

10. Item 15 “Attach credit memorandum prepared by the Lender. SBA applicants only: Also attach D&B Report and Personal Credit Reports on Principals and Guarantors.”

• This misstates the SBA applicant requirement. SBA does not require a D&B Report and personal credit reports. So the “SBA applicants only” statement should be deleted.

• As noted elsewhere, the credit memo should contain certain information about the proposed loan. The credit memo is in many ways the most important part of the supporting application documents, so it should probably be promoted to item #1, and the required detail that the credit memo must address should be delineated here.

• Here is recommended wording: “Lender’s credit memorandum with a comprehensive credit analysis, including the following details: (a) organizational structure of business, (b) history of the business; (c) list and status of any outstanding US government guaranteed loans to the borrower or its affiliate(s) or subsidiary(s); (d) use of loan proceeds and benefits of the loan; (e) underlying export transaction(s) which the loan will finance – such as buyer name(s) and country(s), description of products/services to be exported, percentage foreign content (ExIm applicants only), projected sales amount; anticipated sales terms & currency, projected sales date(s), typical time required to complete an export transaction cycle from order to shipment to collection; (f) proposed export risk mitigation measures – such as letter of credit export credit insurance, documentary collection, partial prepayment, etc.; (g) A/R details – such as aging and turnover analysis, customer base analysis (makeup size range, concentrations, seasonality), assessment of borrower’s customary sales terms and credit policies and collection practices; (h) inventory details – such as inventory turnover analysis, makeup (raw materials, work-in-progress, finished goods) and location, costing method (LIFO, etc.), and reliability of valuations; (i) loan mechanics – such as proposed advance rates, borrowing base formula, control account, collateral exams and reviews; and (j) description of type and value of proposed collateral to support the loan including discussion of other liens affecting the collateral.

SBA Response: This information is used as part of the SBA underwriting process. The information as presented will remain.

11. Item 18 “SBA applicants only: If there is a “YES” response to Question e.2. or e.3. in Part C.2., submit a completed SBA Form 912 with details furnished on a separate sheet, including dates, location, fines, sentences, whether misdemeanor or felony, dates of parole/probation, unpaid fines or penalties, name(s) under which charged, and any other pertinent information. NOTE: If there is a “YES” response to Question e.1. in Part C.2., the loan request is ineligible for SBA assistance.”

• This refers to a rather unique circumstance and therefore would be better simplified.

• Another unique circumstance that may arise is if there is a “NO” to Question h in Part C.2.

• It is recommended that this item be revised to simply state: “SBA applicants only: If there is a “YES” response to Questions e.2. or e.3. or a “NO” response to Question h. in Part C.2., additional information will be required. Contact SBA for details.

SBA Response: The information as presented will remain.

12. Item 19 “SBA applicants only: If the borrower used (or intends to use) a packager, broker, accountant, lawyer, etc. to assist in (a) preparing the loan application or any related materials and/or (b) referring the loan to the lender, a SBA Form 159 7(a) will need to be completed by the borrower and the lender and submitted.”

• This refers to a rather unique circumstance and when SBA requires this, the Form 159 is submitted to SBA’s Fiscal Transfer Agent after the loan is closed. Therefore, this should be removed from the application checklist.

SBA Response: The information as presented will remain.

13. Additional application item. The application checklist currently does not mention the opportunity to use either SBA or ExIm assistance for indirect exporting. This should be addressed.

• It is recommended that an new application item be added to the checklist: “For indirect exporters only: A letter or other documentation from the borrower’s customer certifying that they will sell the goods/services purchased from the borrower to a foreign buyer.”

SBA Response: This information is not needed for application and can be addressed by the lender in its documentation.

In summary, it is recommended the application checklist on page 2 be revised and reorganized so that it looks like this:

CHECKLIST OF INFORMATION TO BE ATTACHED

BACKGROUND

1. Lender’s credit memorandum with a comprehensive credit analysis, including the following details: (a) organizational structure of business, (b) history of the business; (c) list and status of any outstanding US government guaranteed loans to the borrower or its affiliate(s) or subsidiary(s); (d) use of loan proceeds and benefits of the loan; (e) underlying export transaction(s) which the loan will finance – such as buyer name(s) and country(s), description of products/services to be exported, percentage foreign content (ExIm applicants only), projected sales amount; anticipated sales terms & currency, projected sales date(s), typical time required to complete an export transaction cycle from order to shipment to collection; (f) proposed export risk mitigation measures – such as letter of credit export credit insurance, documentary collection, partial prepayment, etc.; (g) A/R details – such as aging and turnover analysis, customer base analysis (makeup size range, concentrations, seasonality), assessment of borrower’s customary sales terms and credit policies and collection practices; (h) inventory details – such as inventory turnover analysis, makeup (raw materials, work-in-progress, finished goods) and location, costing method (LIFO, etc.), and reliability of valuations; (i) loan mechanics – such as proposed advance rates, borrowing base formula, control account, collateral exams and reviews; and (j) description of type and value of proposed collateral to support the loan including discussion of other liens affecting the collateral.

2. Brief resume of the principals and key employees.

3. Copy of business plan, if available.

TRANSACTION

4. Attach product literature. Ex-Im Bank applicants only: If applicable, attach description of items if they are nuclear, military, environmental, on the U.S. Munitions Control List, or require an export license.

5. Copy of letter of credit and/or copy of buyer’s order/contract, if available.

6. Export credit insurance-related material (policy, application, buyer credit limit), if applicable.

7. Copy of export license, if required.

8. For indirect exporters only: A letter or other documentation from the borrower’s customer certifying that they will sell the goods/services purchased from the borrower to a foreign buyer.

FINANCIAL INFORMATION

9. Business financial statements (Balance Sheet, Income Statement, statement of Cash Flows) for the last three years, if applicable, supported by the most recent Federal income tax return for the business. SBA applicants only: If not available, submit the last three years of signed Federal income tax returns for the business.

10. Current financial statement (interim) dated within 90 days (SBA applicants only: 180 days) of the date of the application filing.

11. All Affiliated Companies – Business Financial Statements (Balance Sheet, Income Statement, Aging of Accounts Receivable and Accounts Payable) for the last completed fiscal year end, as well as current statements no older than 90 days (SBA applicants only: 180 days) from the date of application filing. (SBA applicants only: If financial statements are not available for the last completed fiscal year, submit the last year signed Federal income tax returns for the business.) (ExIm applicants only: In addition, submit signed Federal income tax returns for the last fiscal year end or an extension form if not filed after the due date.) Important Requirement – Submit a combined or consolidated financial statement for the current period as well as the last fiscal year end (combining all affiliated companies), eliminating any inter-company transactions (sales, receivables, payables, etc.).

12. Signed joint personal financial statement(s) of each major shareholder(s)/partner(s), owner(s), of the company (with 20% or greater ownership, including assets and liabilities of both spouses). (ExIm applicants only: Also provide their most recent Federal income tax return. Also note that ExIm does not require financials for venture capital partners).

13. Month-by-month cash flow projection for the terms of the loan, highlighting the proposed export transaction(s).

OTHER INFORMATION – EX-IM APPLICANTS ONLY:

14. ExIm applicants only: Schedule of all principal officer/owner’s compensation for the past three years, and current year to date [if none, please indicate].

15. Ex-Im Bank applicants only: Nonrefundable $500 application fee for a Preliminary Commitment or nonrefundable $100 application fee for a Final Commitment, whichever is applicable, by check or money order made out to the Ex-Im Bank.

OTHER INFORMATION – SBA APPLICANTS ONLY:

14. SBA applicants only: Copy of IRS Form 4506-T (original to be submitted to IRS by the Lender).

15. SBA applicants only: If there is a “YES” response to Questions e.2. or e.3. or a “NO” response to Question h. in Part C.2., additional information is required. Contact SBA for details.

16. SBA applicants only: If the lender is processing this loan under its PLP-EWCP delegated authority, lender must submit SBA Form 1920.

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