EXPORT-IMPORT BANK

Status of GAO 

Recommendations on 

Risk Management, 

Exposure Forecasting, 

and Workload Issues 

Statement of Mathew J. Scirè, Director, 

Financial Markets and Community Investment

Testimony 

Before the Committee on 

Financial Services,

House of Representatives

For Release on Delivery 

Expected at 10 a.m. ET

Wednesday, June 25, 2014

GAO-14-708T

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-708T, a testimony 

before the Committee on Financial Services, 

House of Representatives 

June 25, 2014

EXPORT-IMPORT BANK

Status of GAO Recommendations on Risk 

Management, Exposure Forecasting, and Workload 

Issues

Why GAO Did This Study

Ex-Im helps U.S. firms export goods 

and services by providing a range of 

financial products. The Export-Import 

Bank Reauthorization Act of 2012 

increased the statutory ceiling on the 

agency’s total exposure to $140 billion 

in 2014. As a condition of raising the 

exposure limit, the act required Ex-Im 

to prepare a report with a Business 

Plan and analyses of key operational 

elements. The act also mandated GAO 

to evaluate the effectiveness of Ex-Im’s 

risk management and analyze its 

Business Plan. GAO reported on these 

issues in March and May 2013, 

respectively (see GAO-13-303 and 

GAO-13-620). In the reports, GAO 

made a total of eight 

recommendations—to which Ex-Im 

agreed.

This testimony is based on GAO’s 

March and May 2013 reports. It 

discusses actions Ex-Im has taken in 

response to GAO recommendations on 

(1) estimating losses, managing 

financial risks, and forecasting 

exposure levels; and (2) managing and 

reporting on its workload. For the 2013 

reports, GAO analyzed Ex-Im’s 

financial data, policies and procedures, 

Business Plan, and processes for 

calculating program costs and loss 

reserves. GAO also interviewed Ex-Im 

officials and other entities involved in 

export financing. 

What GAO Found

The U.S. Export-Import Bank (Ex-Im) has addressed recommendations GAO 

made in two 2013 reports that related to processes for estimating losses, 

managing financial risks, and forecasting outstanding financial commitments 

(exposure). In these reports, GAO found weaknesses in the processes, including 

limitations in Ex-Im’s data and models. Based on accounting standards for 

federal credit agencies, federal banking regulator guidance, and federal internal 

control standards, GAO made six recommendations that Ex-Im subsequently 

implemented. For example, GAO recommended that Ex-Im

• assess whether it was using the best available data for adjusting loss 

estimates for long-term credit transactions to account for global economic 

risk. In November 2013, Ex-Im replaced a 1-year forecast of global economic 

conditions it used in its loss estimation model with a 5-year forecast.

• retain point-in-time data on credit performance to conduct analyses to 

compare the performance of newer and more seasoned business at 

comparable points. Ex-Im began retaining such data in fiscal year 2013.

• report to Congress on scenarios used for and results of stress tests on its 

portfolio. In September 2013, Ex-Im began including this information in 

quarterly reports to Congress on the bank’s default rates. 

• assess the sensitivity of its exposure forecast model to key assumptions and 

estimates and identify and report the range of forecasts these analyses

produced. In response, Ex-Im created additional statistical models to validate 

its forecasts and provided a range of estimates.

Ex-Im also has begun to address two recommendations in GAO’s 2013 reports 

concerning the bank’s workload. In a March report, GAO found Ex-Im faced 

potential operational risks because administrative budgets and staff levels had 

not kept pace with growth in its portfolio and Ex-Im had not formally determined 

the level of business it could properly manage. In a May report, GAO found the 

Business Plan provided limited analysis of the adequacy of Ex-Im’s resources 

and ability to meet congressional mandates for credit transactions supporting 

small business and renewable energy. Based in part on federal internal control 

standards, GAO recommended that Ex-Im develop benchmarks to monitor and 

manage workload levels and provide Congress with more information on 

resources associated with meeting the mandates. To help address the 

recommendations, Ex-Im hired a contractor to develop workload benchmarks 

and a workload modeling tool. As of June 2014, this effort was ongoing. As a 

result, the two recommendations remain open.

While Ex-Im has been responsive to GAO’s recommendations, it is important to 

note that GAO has ongoing work examining other aspects of Ex-Im operations. 

Furthermore, managing a large export financing portfolio and its associated risks 

is challenging. Therefore, it will be important for Ex-Im to sustain the 

improvements it has made, effectively implement future audit recommendations, 

and carefully manage emerging risks. 

View GAO-14-708T. For more information, 

contact Mathew J. Scirè at (202) 512-8678 or 

sciremj@gao.gov.
Page 1 GAO-14-708T 

Chairman Hensarling, Ranking Member Waters, and Members of the 

Committee:

I am pleased to be here today to discuss our prior work on the U.S. 

Export-Import Bank (Ex-Im), which serves as the official export credit 

agency of the United States. Ex-Im helps U.S. firms export goods and 

services by providing financial products, including direct loans, loan 

guarantees, and insurance. Ex-Im’s business volume has grown 

dramatically in recent years. From fiscal years 2008 through 2013, ExIm’s exposure—that is, its total outstanding financial commitments—rose 

from $58.5 billion to $113.8 billion.1

My statement today draws on two reports we issued in March and May 

2013, which were mandated in the Export-Import Bank Reauthorization 

Act of 2012 (2012 Reauthorization Act).

Factors associated with this growth 

included the reduced availability of private-sector financing following the 

2007-2009 financial crisis. This rapid growth has challenged Ex-Im’s 

ability to plan for and manage its portfolio.

2

For the March and May 2013 reports, we analyzed Ex-Im’s financial data, 

policies and procedures, and processes. We also reviewed Ex-Im’s

Business Plan, related analyses, and other reports. We examined the 

models Ex-Im used to forecast exposure levels and estimate credit 

losses, including the data and assumptions underlying the models. In 

addition, we reviewed Congressional Budget Justifications, annual 

reports, and other reports for information on Ex-Im’s administrative 

budgets and the size of its workforce. We reviewed various sources of 

Specifically, the act mandated 

us to assess aspects of Ex-Im’s risk management and 2012 Business 

Plan in the context of the agency’s growth. The act also increased the 

statutory ceiling on the agency’s total exposure (exposure limit). I will 

discuss actions Ex-Im has taken to address recommendations in our 

2013 reports regarding (1) estimating losses, managing financial risks, 

and forecasting exposure levels; and (2) managing and reporting on the 

bank’s workload.

 1

All years in this statement are federal fiscal years unless otherwise indicated. 

2

Pub. L. No. 112-122 § 4 and 5, 126 Stat. 350, 352 (2012). See GAO, Export-Import 

Bank: Recent Growth Underscores Need for Continued Improvements in Risk 

Management, GAO-13-303 ((Washington, D.C.: Mar. 28, 2013); and Export-Import Bank: 

Additional Analysis and Information Could Better Inform Congress on Exposure, Risk, and 

Resources, GAO-13-620 (Washington, D.C.: May 30, 2013).
Page 2 GAO-14-708T 

guidance on risk management and cost estimation, including federal 

internal control standards, Office of Management and Budget (OMB) 

guidance, and federal banking regulator guidance. Additionally, we 

interviewed Ex-Im officials and other entities involved in export financing. 

Our prior reports each include a detailed description of our scope and 

methodology. For this statement, we also updated information on Ex-Im’s 

overall exposure and authorizations as of the end of 2013 and updated 

the status of the recommendations we made in the 2013 reports.3 We 

conducted the work on which this testimony is based 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 objectives. We believe that the evidence obtained provides 

a reasonable basis for our findings and conclusions based on our audit 

objectives.

Ex-Im is an independent agency operating under the Export-Import Bank 

Act of 1945, as amended. Its mission is to support the export of U.S. 

goods and services, thereby supporting U.S. jobs. Ex-Im’s charter states 

that it should not compete with the private sector. Rather, Ex-Im’s role is 

to assume the credit and country risks that the private sector is unable or 

unwilling to accept, while still maintaining a reasonable assurance of 

repayment. Ex-Im’s authorizations increased from $14.4 billion in 2008 to 

$35.8 billion in 2012, but declined to $27.3 billion in 2013.

While demand for its services generally drives Ex-Im’s business, 

Congress also mandated that Ex-Im support specific objectives. For 

example, since the 1980s, Congress has required that Ex-Im make 

available a percentage of its total export financing each year for small 

business. In 2002, this requirement increased from 10 percent to 20 

percent. Congress further instructed that Ex-Im promote the expansion of 

its financial commitments in sub-Saharan Africa. Finally, in 2012 

Congress directed that “not less than 10 percent of the aggregate loan, 

guarantee, and insurance authority available to [Ex-Im]...should be used 

for renewable energy technologies or end-use energy efficiency 

technologies”—to which we refer as the renewable energy mandate.

 3

An authorization is an export financing transaction for which Ex-Im has granted credit 

approval. 

Background
Page 3 GAO-14-708T 

Our March and May 2013 reports found that Ex-Im had been developing 

a more comprehensive risk-management framework and had provided 

exposure forecasts to Congress, but could take additional steps to 

improve these processes. More specifically, Ex-Im had started to address 

recommendations by its Inspector General (IG) about portfolio stress 

testing, thresholds for managing portfolio concentrations, and risk 

governance. We concluded that the IG’s recommendations represented 

promising techniques that merited continued attention and recommended 

further steps to help improve Ex-Im’s risk-management practices.

First, our March 2013 report found that Ex-Im could further improve its 

risk modeling. Ex-Im calculates credit subsidy costs and loss reserves 

and allowances with a loss estimation model that uses historical data and 

takes credit, political, and other risks into account.4 Consistent with 

industry practices, Ex-Im added qualitative factors to the model in 2012 to 

adjust for circumstances that may cause estimated credit losses to differ 

from historical experience. For example, Ex-Im incorporated a 1-year 

forecast of certain bond defaults to predict possible changes in loss 

estimates from changed global economic conditions. However, we 

concluded that a short-term forecast might not be appropriate for 

adjusting estimated defaults for longer-term products and could lead to 

underestimation of credit subsidy costs and loss reserves and 

allowances.5

 4

Ex-Im uses the model to build the agency’s credit subsidy estimates in the President’s

budget and for calculating loss reserves and allowances reported in its annual financial 

statements. Credit risk is the risk that an obligor—an entity contractually obligated to make 

payments to satisfy the terms of an Ex-Im export credit product—may not have sufficient 

funds to service its debt or be willing to service its debt. Political risk is the risk that 

expropriation of the obligor’s property, war, or inconvertibility of the obligor’s currency into 

U.S. dollars may result in nonrepayment.

Thus, we recommended that Ex-Im assess whether it was 

using the best available data for adjusting the loss estimates. Ex-Im 

agreed with our recommendation and identified a 5-year forecast of the 

global economy to adjust loss estimates. In November 2013, Ex-Im 

incorporated this longer-term forecast of global economic change into its 

5

We based our recommendation on guidance from the Federal Accounting Standards 

Advisory Board for federal credit agencies, which states that agencies should develop 

cash flow projections for their transactions based upon the best available data. See 

Federal Accounting Standards Advisory Board, Federal Financial Accounting and Auditing 

Technical Release 6: Preparing Estimates for Direct Loan and Loan Guarantee Subsidies 

under the Federal Credit Reform Act (January 2004).

Ex-Im Has 

Addressed GAO’s 

Recommendations 

Related to Risk 

Management and 

Loss and Exposure 

Estimation
Page 4 GAO-14-708T 

loss estimation model. As a result, we consider this recommendation 

implemented and closed.

Second, our March 2013 report found that Ex-Im could improve its 

analysis of the financial performance of its portfolio. Ex-Im’s default rate 

declined steadily from about 1.6 percent as of September 30, 2006, to

0.29 percent as of September 30, 2012, and, more recently, Ex-Im 

reported a further decline to 0.21 percent as of March 30, 2014.6

However, as we concluded in our report, this downward trend should be 

viewed with caution because Ex-Im’s portfolio contains a large volume of 

recent transactions that have not reached their peak default periods. 

Additionally, we found that Ex-Im was not maintaining the data it needed 

to compare the performance of newer books of business with more 

seasoned books at comparable points in time, a type of analysis 

recommended by federal banking regulators.7

Third, our May 2013 report found weaknesses in the methodology Ex-Im 

used to forecast future exposure levels. The 2012 Reauthorization Act 

increased Ex-Im’s exposure limit to $120 billion in 2012, with provisions 

for additional increases to $130 billion in 2013 and $140 billion in 2014. 

Although Ex-Im’s forecast model is sensitive to key assumptions, Ex-Im 

had not reassessed these assumptions to reflect changing conditions or 

conducted sensitivity analyses to assess and report the range of potential

We concluded that the lack 

of point-in-time data showing when defaults occur could reduce the 

precision of Ex-Im’s loss estimation model. We recommended that Ex-Im 

retain point-in-time performance data to compare the performance of 

newer and older business and enhance loss modeling. Ex-Im agreed and 

began retaining such data in 2013. We therefore consider this 

recommendation implemented and closed. Ex-Im said it plans to use 

these data to conduct an annual analysis that will compare the 

performance of newer books of business with older books and that the 

results will further enhance its loss estimation model.

 6

Ex-Im calculates the default rate as the sum of net claims paid to date on loan 

guarantees and insurance transactions and unpaid past due installments to date on direct 

loans divided by disbursements. Ex-Im developed this calculation of the default rate in 

response to a provision in the Export-Import Bank Reauthorization Act of 2012, which 

requires Ex-Im to report default rates to Congress at least quarterly. (Pub. L. No. 122-122, 

§ 6, 126 Stat. 350, 353 (2012)).

7

Ex-Im is not bound by federal banking regulator guidance, but faces risk-management

challenges similar to those of regulated private financial institutions.
Page 5 GAO-14-708T 

outcomes.8

Finally, in both our March and May 2013 reports, we recommended that 

Ex-Im report certain risk information to Congress. Our March report found 

that Ex-Im had begun to implement the IG’s recommendation to develop 

a systematic approach to stress testing its portfolio. We concurred with 

the IG’s recommendation and concluded that Ex-Im’s reporting of testing 

scenarios and results would aid congressional oversight and be 

consistent with federal internal control standards for effective external 

communication.

Because Ex-Im had not taken these steps, we concluded that 

the reliability of its forecasts was diminished. Based on GAO cost 

estimation guidance, we recommended that Ex-Im (1) compare previous 

forecasts and key assumptions to actual results and adjust its forecast 

models to incorporate previous experience and (2) assess the sensitivity 

of the exposure forecast model to key assumptions and estimates and 

identify and report the range of forecasts based on this analysis. Ex-Im 

agreed and put in place new methodologies for its 2015 budget 

estimates. Specifically, Ex-Im compared the results of its existing 

authorization forecast method with actual results and enhanced its 

calculation of expected repayments and authorizations by incorporating 

historical experience into the methodology. Additionally, Ex-Im created 

statistical models to validate its forecasts and provide a range of 

estimates. Therefore, we consider these recommendations implemented 

and closed.

9

 8

GAO, GAO Cost Estimating and Assessment Guide: Best Practices for Developing and 

Managing Capital Program Costs, 

Thus, we recommended that Ex-Im report this 

information to Congress. Ex-Im agreed and began reporting its stress test 

scenarios and results in quarterly reports to Congress on default rates, 

beginning with the report for the fourth quarter of 2013. In that report, ExIm described the stress test scenarios and provided some information 

about results. The scenarios included an across-the-board increase in the 

riskiness of obligors and an assumption of zero recoveries on defaulted 

credit transactions. Ex-Im plans to annually update the stress testing 

GAO-09-3SP (Washington, D.C.: March 2009). Among 

other things, this cost guidance calls for agencies’ assumptions and forecasts to be 

supported by historical data and experience, and a sensitivity analysis that can assess the 

effect of changes in assumptions.

9

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999) and Internal Control Management and Evaluation 

Tool, GAO-01-1008G (Washington, D.C.: August 2001). These standards indicate that 

agency communications with external parties, including Congress, should provide 

information that helps the parties better understand the risks facing the agency.
Page 6 GAO-14-708T 

information in fourth-quarter default reports. Additionally, our May 2013 

report found that Ex-Im had not routinely reported the performance or risk 

ratings of its subportfolios for the congressional mandates on small 

business, sub-Saharan Africa, and renewable energy.10 We concluded 

that Ex-Im could analyze additional information about its subportfolios 

related to the three mandates. Citing guidance from OMB and federal 

banking regulators, we recommended that Ex-Im routinely report the 

financial performance of subportfolios supporting congressional 

mandates.11 Ex-Im concurred with our recommendation and began 

reporting this information in its default rate report to Congress for the 

quarter ending June 30, 2013. As a result, we consider both 

recommendations as implemented and closed.

In both our March and May 2013 reports, we found that Ex-Im faced 

potential operational risks because administrative budgets and staff levels 

had not kept pace with the growth in its portfolio.12

Our March report found that while Ex-Im determined that it needed more 

staff, it had not formally determined the level of business it could properly 

manage with its current resources.

Ex-Im reported in its 

2012 Business Plan that its resource levels could not sustain the bank’s 

current level of activity or meet expected demand in coming years.

13

 10Ex-Im reviews each credit transaction and assigns a numerical risk rating based on 

assessments of credit, political, and market risks. In our May 2013 report, we found that 

the performance of the small business, sub-Saharan Africa, and renewable energy 

subportfolios differed from the performance of Ex-Im’s overall portfolio. For instance, the 

higher risk ratings of the subportfolios suggested these transactions generally were more 

risky than Ex-Im’s overall portfolio.

We concluded that without 

benchmarks to determine when workload levels have created too much 

11OMB guidance indicates that agencies should use comprehensive reports on the status 

of the credit financing portfolios to evaluate effectiveness and collect data for program 

performance measures such as default rates. Furthermore, federal banking regulator 

guidance suggests that banks should provide financial performance information by 

portfolio and specific product type to allow management to properly evaluate lending 

activities.

12Operational risk is the risk that loss may result from inadequate or failed internal 

processes, people, and systems, or from external events.

13Federal internal control standards state that agencies should develop a riskmanagement approach based on how much risk can be prudently accepted. See 

GAO/AIMD-00-21.3.1 and GAO-01-1008G.

Ex-Im Has Begun

to Address GAO’s 

Recommendations 

to Improve Workload 

Management and 

Reporting
Page 7 GAO-14-708T 

risk, Ex-Im’s ability to manage its increased business volume might be 

limited. Further, we concluded that monitoring workloads against such 

benchmarks would help Ex-Im determine when additional steps—such as 

tightening underwriting standards or increasing requirements for lender 

participation—might be needed to mitigate Ex-Im’s increased risk. 

Accordingly, we recommended that Ex-Im develop benchmarks to 

monitor and manage workload levels. Ex-Im agreed with this 

recommendation and hired a contractor in September 2013 to develop 

workload benchmarks and a workload modeling tool. As of June 2014, 

benchmarks had been established for certain activities in three Ex-Im 

divisions. According to Ex-Im, the agency plans to use the modeling tool 

to develop benchmarks for the remaining activities and divisions. 

Because Ex-Im’s actions to implement this recommendation are ongoing, 

this recommendation remains open.

Our May 2013 report found that Ex-Im expected that administrative 

resource constraints might prevent it from meeting its congressionally 

mandated target for small business export financing. The mandated 

target is fixed to a percentage of the dollar value of Ex-Im’s total 

authorizations. Although Ex-Im has dedicated resources to support the 

mandate, as Ex-Im authorizations have grown, the growth in the value of 

the mandated target has outpaced Ex-Im’s increasing support. According 

to Ex-Im officials, processing small business transactions and bringing in 

new small business customers is resource-intensive. Originating, 

underwriting, and servicing for small business deals requires more effort 

than other transactions because small businesses tend to have less 

exporting experience than larger businesses. We concluded that it was 

important for Ex-Im to communicate to Congress the effect of percentagebased mandates on its operations, as well as the potential impacts such 

mandates might have on the agency’s resources and ability to achieve its 

goals. Therefore, based on OMB guidance and federal internal control 

standards, we recommended that Ex-Im provide Congress with additional 

information on the resources associated with meeting its percentagebased mandates.14

 14OMB, Circular No. A–11 Revised, Preparation, Submission, and Execution of the 

Budget (August 2012). The guidance directs agency leaders to set ambitious, yet realistic 

goals that reflect careful analysis of associated challenges and the agency’s capacity and 

priorities. Communicating information about challenges and capacity that may significantly 

affect achievement of agency goals to external stakeholders, such as Congress, is also 

consistent with federal internal control standards.

Ex-Im agreed with this recommendation and told us
Page 8 GAO-14-708T 

that it plans to use the workload modeling tool noted previously to provide 

information in its next budget submission on resources associated with 

meeting such mandates. Because Ex-Im is in the process of addressing 

this recommendation, it remains open.

While Ex-Im has been responsive to the recommendations we made, it is 

important to note that we have ongoing work examining different aspects 

of Ex-Im’s operations. Furthermore, managing a large export financing 

portfolio and the wide variety of associated risks is challenging. 

Therefore, it will be important for Ex-Im to sustain the improvements it has 

made, effectively implement future audit recommendations, and carefully 

manage emerging risks. We look forward to continuing to assist the 

Committee in its oversight of Ex-Im.

Chairman Hensarling, Ranking Member Waters, and Members of the 

Committee, this concludes my statement. I would be pleased to respond 

to any questions you may have.

For further information about this statement, please contact me at 202-

512-8678 or sciremj@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this statement. Individuals making key contributions to this testimony 

include Lawrance L. Evans, Jr., Director; Juan Gobel, Assistant Director; 

Steve Westley, Assistant Director; Christine Houle, Analyst-in-Charge; 

Michael Simon, Analyst-in-Charge; Joshua Akery; Kathryn Bolduc; Marcia 

Carlsen; Anna Chung; Michael Hoffman; Melissa Kornblau; Risto Laboski; 

Felicia Lopez; Grace Lui; Colleen Moffatt Kimer; Barbara Roesmann; and 

Jessica Sandler.

Contacts and Staff 

Acknowledgments

(250790)
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