Electronic Compliance Program
Credit Administration staff developed the Medium-Term
Electronic Compliance Program (ECP) to greatly improve
the efficiency and turnaround time in approving medium-term
The ECP is
a web-based certification system for Ex-Im Bank approval
of disbursements. The guaranteed lender is responsible
for collecting and reviewing all required disbursement
documentation and inputting key information obtained from
its review on a secure web-site checklist. The checklist
is transmitted via the Internet to Ex-Im Bank, where it
will be reviewed for completeness and compliance by Credit
Administration staff. Once the request has been approved,
Ex-Im Bank issues an electronic approval on a secure website.
Credit Administration no longer collects or reviews medium-term
disbursement documents, issues a Guarantee Certificate,
or endorses medium-term promissory notes with Ex-Im Bank's
under the Medium-Term Master Guarantee Agreement (MGA-M)
are required to use the ECP.
The following questions and answers should respond to
most of your questions about the ECP.
can participate in the ECP?
All guaranteed lenders that apply for a Medium-Term Guarantee
must use the ECP. Ex-Im Bank will not approve a Medium
Term transaction unless the guaranteed lender has a signed,
effective Master Guarantee Agreement (Medium Term Credits
- Electronic Compliance Program).
What programs are covered under
All medium-term guarantees and select long-term transactions
between $10 and $20 million are eligible to be processed
under the ECP.
What disbursement documents are
needed to complete the checklist?
Disbursement documents needed are an invoice, Exporter's
Certificate, evidence of payment, and shipping documents.s
How is the Exposure Fee paid under
Under the ECP, only wire transfers are acceptable.
How is data on the checklist transmitted via Internet
Ex-Im Bank uses state of the art encryption and application
security similar to that used by financial institutions
and stock brokerage firms which provide products and services
over the Internet.
What happens if the guaranteed
lender makes an inadvertent error on the checklist?
If a lender fails to comply with any of its obligations
under the Medium-Term MGA (including accurate completion
of the checklist), Ex-Im Bank may suspend the guaranteed
lender from further participation under the Medium Term
guarantee program. As with the prior guarantee program,
Ex-Im Bank also has a right of indemnification from a
guaranteed lender if Ex-Im Bank is harmed by such guaranteed
Who retains the disbursement
The guaranteed lender must retain all disbursement
documents for the transaction for a period of ten years
after the last repayment date. Ex-Im Bank reserves the
right to request the disbursement documents from the guaranteed
lender at any time.
What documents are needed
in the event of a claim?
Ex-Im Bank's claim procedures have not changed as a result
of the ECP. We will not require the disbursement documents
to process claim payment. However, as noted above, Ex-Im
Bank reserves the right to request the disbursement documents
from the guaranteed lender at any time.
How are audits conducted?
Ex-Im Bank will conduct random audits of the disbursement
documents and compliance with ECP procedures either by
requesting that the disbursement documents be sent to
Ex-Im Bank or by on-site visits to the guaranteed lenders.
Does the ECP change Ex-Im Bank's
No. As under the prior Medium-Term guarantee program,
once a disbursement is approved, the disbursement is guaranteed
by Ex-Im Bank.
Whom should I contact if I have
If you have questions with respect to transactions that
are not yet operative, contact the loan officer assigned
to the transaction. Once the credit is operative, all
disbursement questions should be addressed to the assigned
Credit Administration officer. Questions concerning amendments
to an operative transaction (i.e. increase/decrease, change
of final disbursement date, etc.) should be directed to
the Portfolio Monitoring and Control Group.
Can I use Private Export Funding Corporation under ECP?
Yes. Please contact Vincent Herman at PEFCO at 212-916-0327
or visit PEFCO's website for more information at www.pefco.com.