In its May 4 response to AFGE's information request, EXIM said it engaged in no modeling of the New York closure, that no analytical report addressed the requested operational or mission effects, and that travel costs were not a factor in the decision. The July 1 Warren-Schumer letter later quoted those agency responses. Those responses do not show that exporters will lose service. They show that the Bank has not published a way to measure continuity.
For affected customers, the immediate question is simple. Who will own the next inquiry, referral, lender call, and application across the ten-state territory?
A ten-state service test
EXIM need not preserve a physical office to preserve service. The evidence below would allow Congress, management, and customers to determine whether consolidation protects access to inquiries, referrals, counseling, lender calls, and open applications.
| Service function | Baseline before the change | Handoff evidence after the change | What it tests |
|---|
| New inquiries | State owner and elapsed time from receipt to first response | Successor owner and the same elapsed-time measure | Tests whether access remains usable |
| Exporter counseling | Consultations completed and next actions recorded | Open appointments transferred without reset | Shows whether relationship work survives |
| Partner referrals | Referring organizations and accepted referrals by territory | Written routing and acceptance confirmation | Shows whether local outreach reaches an EXIM specialist |
| Lender and broker handoffs | Active contacts, product questions, and scheduled follow-ups | Assigned staff and escalation path for each open matter | Shows whether financing channels keep an accountable owner |
| Applications in motion | Stage, pending document, deadline, and responsible officer | Transfer record with the next action unchanged | Shows whether consolidation interrupts transaction work |
The public record supports no universal response-time target or conversion rate. EXIM can establish a baseline from its own case and customer systems, disclose the method, and compare the same functions during the transition. Without that comparison, lower facility costs and steady national output would not establish that the regional service path survived.
What EXIM should publish by August 5
Gillibrand's July 28 letter asks EXIM to provide records supporting the decision, describe stakeholder consultation, assess costs and mission effects, identify alternatives, and explain how it will mitigate employee and operational disruption. The requested response is due August 5.
A useful answer would identify the intended coverage model for all ten states and its effective date. It would name the staff responsible for new inquiries, pending consultations, partner referrals, lender and broker questions, and applications already under review. It would state which baseline EXIM will use and when the Bank will publish a comparison.
EXIM's current directory makes that exercise concrete. The page assigns New Jersey, Delaware, and Pennsylvania to one New York official. It assigns the other seven states to another and directs all new inquiries to a coordinator. A replacement plan can map each public responsibility to a successor. If those functions remain with the same people working from a different duty station, the Bank can say so. If responsibility moves, affected customers need the new route before the old one disappears.
No completed replacement plan appears in the public record. EXIM's August response is the next scheduled opportunity to provide one.
What exporters should record before the move
Companies in the ten-state territory do not need to predict the final office decision. They can reduce transition risk by recording the current EXIM contact, product under discussion, referral source, application stage, next promised action, and any time-sensitive buyer or lender condition. The useful document is a short operating record, not a position paper on the closure.
Lenders and brokers should identify the EXIM official who owns each pending question and obtain a written escalation route. REPP members, Small Business Development Centers, and chambers should ask who will accept new referrals from their territory, how acceptance will be confirmed, and which specialist will report the next action to the referring organization.
These records also improve public oversight. If EXIM later reports that national consultations or authorizations held steady, the regional file can show whether open matters changed owners, appointments were repeated, or referrals lacked an accountable recipient. If service continues without interruption, the same record will show that the handoff worked.
National reach is not regional continuity
EXIM publishes substantial evidence that it reaches small businesses. Its 2025 Annual Report sections on small-business support and outreach say agency representatives participated in more than 750 events. Digital outreach reached 2.1 million inboxes and generated more than 2,200 requests for consultation. Small businesses received 1,168 authorizations, approximately 87.7 percent of the year's authorizations by count.
Those figures describe national activity and product use. They do not show whether a referral made through a regional relationship still reaches the right specialist after the office changes.
Service continuity begins earlier than authorization. A first-time exporter may need help identifying an eligible product. A lender may need a regional official to translate an incomplete inquiry into an insurable transaction. A trade association or Small Business Development Center may need a known contact willing to take a referral. An open application may depend on a scheduled follow-up whose owner is obvious inside the Bank but invisible to the customer.
The closure record does not provide a baseline for those functions. It does not publish inquiry response time by region, accepted referrals, first consultations completed, handoffs to product staff, or the disposition of cases already in motion. EXIM may track some of that information internally. The available record does not show how management used it to design the New York transition.
This management issue predates the current plan. In the 2023 Regional Office Concerns Identified management advisory, OIG reported that a majority of regional-office employees described concerns about strategic management. Two employees specifically said EXIM should examine the geographic placement of its offices to ensure that business needs were met. The advisory did not evaluate the New York closure or recommend keeping any office open. It shows that regional-office strategy and office placement had already drawn employee concern.
The financing total cannot do this work
The Warren-Schumer letter cites a March 12 AFGE memorandum that says it relied on EXIM internal data. The memorandum reports $4,307,653,320 in supported financing across the two regional directors' ten-state territories from fiscal 2022 through fiscal 2026 to date. That stakeholder-derived figure establishes the scale of activity attributed to the territory. It is not a causal estimate of what the New York office created, and it is not a forecast of what would be lost after consolidation.
Treating the full amount as office productivity would overstate the case. EXIM product officers, lenders, brokers, exporters, headquarters staff, and regional personnel can all contribute to the same transaction. The opposite inference is no better. The fact that a financing product can be issued from Washington does not establish that discovery, referral, counseling, and follow-up will occur at the same rate without the present field structure.
What is missing is a case-level handoff record. It should show who first received each matter, who moved it forward, where it stalled, and who would take the next action after the move. A territory-wide dollar total cannot supply that record.
REPP extends reach but does not own every case
EXIM already operates a partner network through the Regional Export Promotion Program. State and local development organizations bring market knowledge and personal access to businesses, while EXIM contributes finance products and specialists. The page says the Bank has limited regional staff and travel budget.
REPP members are expected to hold events, make referrals, and connect exporters with EXIM trade-finance specialists. REPP extends local outreach, but it does not identify who accepts each referral, counsels the exporter, resolves the lender question, or owns the next action.
That boundary becomes more important under S. 4820 as introduced. The Regional Export Promotion Act would codify REPP, expand partners in regions with high small-business concentrations, and require annual reporting on new partners and products used as a direct result of referrals. It does not require a New York office, assign a regional staff floor, or set a service-continuity standard when EXIM changes its own field structure.
Congress could strengthen those reporting provisions without requiring EXIM to keep a particular office. It could require the Bank to connect partner referrals to accepted consultations, responsible staff, and application outcomes by region. That record would show whether a referred exporter reached a named specialist and received a next step.
Current law leaves the delivery question open
Current 12 U.S.C. 635 directs EXIM to encourage small-business participation and make available not less than 30 percent of its aggregate authority to finance exports directly by small businesses. It also requires promotion of small-business exports in cooperation with state agencies, chambers of commerce, banking organizations, and other private-sector organizations. A full-text review of the current section does not find a requirement to maintain a New York office or a minimum number of regional finance centers.
One introduced extension bill, S. 3772, would change EXIM's termination year from 2026 to 2036, extend the statutory schedule for its aggregate loan, guarantee, and insurance authority through 2037, and extend the China and Transformational Exports Program through 2036. As introduced, it does not address regional offices or standards for closing one.
Traverse's analysis of S. 3772 and the quorum backstop concerns whether the Bank can authorize Board-level deals. Its analysis of Make More in America and the year-end reauthorization concerns what EXIM may finance. Neither answers who will own a New York referral or open case after consolidation.
The decision should follow the test
The current EXIM statute reviewed here does not require the Bank to maintain a New York office. That statutory silence is not a conclusion about the legality of implementing this closure, and the available record does not establish that every regional function requires a local desk.
The unresolved problem is sequence. EXIM's May 4 response says the Bank did not model the closure and had no analytical report addressing the requested operational or mission effects. EXIM should define the replacement service, establish the baseline, transfer each open responsibility, and then test whether access survived.
Before the New York office disappears from EXIM's directory, the Bank should publish the replacement route and compare it with a regional baseline. That would let customers and Congress see whether the reorganization preserved service.