The Export-Import Bank of the United States, known as EXIM Bank, published a notice in the Federal Register on November 18, 2025, announcing the submission of an information collection renewal to the Office of Management and Budget. This involves form EIB 15-04, titled the Exporter's Certificate for Co-Financed Guarantee and Medium-Term Insurance Programs. The action invites public comments by December 18, 2025, as part of efforts to comply with the Paperwork Reduction Act of 1995, which requires federal agencies to minimize paperwork burdens on the public. This development underscores EXIM Bank's ongoing role in facilitating U.S. exports through financial tools while adhering to regulatory oversight. By renewing this form, the bank ensures continued verification of export eligibility in co-financed deals, potentially affecting exporters, lenders, and insurers involved in international trade.
Background on EXIM Bank and the Paperwork Reduction Act
EXIM Bank serves as the official export credit agency of the United States, providing financing such as loans, guarantees, and insurance to support American exports. Established by Congress in 1934, it operates under a charter that mandates periodic reauthorization, with its current authority extended through 2026 following legislative action in 2019. The bank's programs help U.S. companies compete globally, particularly in sectors where private financing is limited due to risk.
The Paperwork Reduction Act of 1995, or PRA, governs how federal agencies collect information from the public. It requires agencies to justify the need for data collection, estimate burdens, and seek approval from the Office of Management and Budget every three years for renewals. EXIM Bank's submission aligns with this framework, as the notice states the bank is 'as part of its continuing effort to reduce paperwork and respondent burden.' This is not the first renewal for form EIB 15-04, which carries OMB number 3048-0052 and has been in use for co-financed transactions, where EXIM partners with other export credit agencies or financial institutions to share risks.
Key players include EXIM Bank officials, such as Records Officer Andrew Smith, who signed the notice, and the Office of Management and Budget, which will review the submission. Public stakeholders, including exporters and financial institutions, are invited to comment, reflecting the PRA's emphasis on transparency.
Details of Form EIB 15-04 and Its Purpose
Form EIB 15-04 requires U.S. exporters to certify the eligibility of their exports for EXIM Bank support in co-financed deals. As described in the notice, exporters provide details on the transaction, content sourcing, and their eligibility under U.S. government programs. This certification is submitted at the time of disbursement for direct loans and guarantees, or held by financial institutions for medium-term insurance policies, only to be filed with EXIM in case of a claim.
The form's primary function is to verify the 'value and legitimacy' of financing support, ensuring compliance with export regulations. For instance, it checks for U.S. content requirements, which mandate that a certain percentage of the exported goods or services originate in the United States to qualify for EXIM backing. The notice explains that this provides financial institutions with 'a check on the export transaction's eligibility at the time it is fulfilling a financing request.' Without such certification, co-financed programs could face risks of non-compliance, potentially leading to denied claims or legal challenges.
EXIM estimates the form affects about 30 respondents annually, with each taking around 30 minutes to complete, resulting in a total burden of 15 hours per year. This low burden reflects the form's targeted use in specific high-value export deals, rather than broad application.
Legal and Policy Context
The renewal occurs against a backdrop of evolving U.S. trade policy. EXIM Bank's co-financing arrangements often involve partnerships with agencies like those in the European Union or Asia, aligning with broader goals of promoting fair trade. Legal precedents, such as the bank's reauthorization debates in Congress, highlight tensions between supporters who view EXIM as essential for job creation and critics who argue it represents corporate welfare. For example, the 2015 reauthorization through the Fixing America's Surface Transportation Act came after a lapse in authority, underscoring the political forces at play.
From a regulatory perspective, the PRA has been invoked in cases like the Supreme Court's decision in Department of Commerce v. New York (2019), which addressed census data collection and emphasized the need for accurate burden assessments. While not directly related, this illustrates the judiciary's role in overseeing information collections. Different perspectives emerge: Pro-business groups may welcome the renewal for streamlining exports, while taxpayer advocates might scrutinize the 15-hour burden as minimal but part of larger federal paperwork costs.
Implications for Stakeholders
For exporters, the form ensures access to co-financed guarantees, which can cover up to 100% of the financed amount in some cases, reducing risks in volatile markets. Financial institutions benefit from the certification as a due diligence tool, potentially lowering default rates. However, the renewal process could invite comments on improvements, such as digital submission options, given the notice's reference to electronic comments via regulations.gov.
Short-term implications include the comment period, which allows input on the form's clarity or necessity. Long-term, successful renewal could enhance EXIM's efficiency in supporting exports amid global challenges like supply chain disruptions. Perspectives vary: Supporters see it as vital for economic competitiveness, while skeptics question the need for government intervention in private markets.
In conclusion, this Federal Register notice represents a routine yet critical step in maintaining EXIM Bank's operational framework. Key takeaways include the low administrative burden and the form's role in safeguarding export financing integrity. Potential next steps involve OMB's review post-comment period, which could lead to approval without changes or modifications based on feedback. Ongoing debates may focus on balancing regulatory compliance with export promotion, especially as trade policies evolve. Challenges could arise if comments reveal burdens not captured in EXIM's estimates, prompting revisions to better serve stakeholders.