It's all speculation at this point based on what we've seen posted previously about timelines. My 90 days is at least 90 days, but who knows?! I wish I could find the original flow chart, but even the iHub post I responded to months ago with someone asking what step we were thought to be at in the process has been deleted. I suspect (I do not know) this public request for information about the industry and specific responses from those involved in it means the application crossed another internal processing hurdle? Regarding deadlines, apparently, they can still accept comments after the deadline if time permits, and then they have to compile and assess the responses they receive (presumably more time). I would think the public comment on the specific loan would be after all of this other info has been received and digested. That's how I arrived at more than 90 days.
This is from 2019. The Make more in America Initiative was in 2021, so unknown if they changed timing or requirements on the domestic projects.
Sec. 3(c)(10) Notice and comment requirements.— Sec. 3(c)(10)(A) In general.—Before any meeting of the Board for final consideration of a long-term transaction the value of which exceeds $100,000,000, and concurrent with any statement required to be submitted under section 2(b)(3) with respect to the transaction, the Bank shall provide a notice and comment period.
Sec. 3(c)(10)(C) Specific requirements.— Sec. 3(c)(10)(C)(i) In general.—The Bank shall— (I) publish in the Federal Register a notice of the application proposing the transaction; (II) provide a period of not less than 25 days for the submission to the Bank of comments on the application; and (III) notify the Committee on Banking, Housing, and Urban Affairs of the Senate, and the Committee on Financial Services of the House of Representatives of the application, and seek comments on the application from the Department of Commerce and the Office of Management and Budget.
Sec. 3(c)(10)(C)(ii) Content of notice.—The notice published under clause (i)(I) with respect to an application for a loan or financial guarantee shall include appropriate information about— (I) a brief non-proprietary description of the purposes of the transaction and the anticipated use of any item being exported, including, to the extent the Bank is reasonably aware, whether the item may be used to produce exports or provide services in competition with the exportation of goods or the provision of services by a United States industry; (II) the identities of the obligor, principal supplier, and guarantor; and (III) a description, such as type or model number, of any item with respect to which Bank financing is being sought, but only to the extent the description does not disclose any information that is confidential or proprietary business information, that would violate the Trade Secrets Act, or that would jeopardize jobs in the United States by supplying information which competitors could use to compete with companies in the United States.
Thinking out loud, maybe that last tranche of financing was the money for the independent auditors, and now that it's in the bank, the auditors have been assigned and these questions are coming from the auditors. Let's hope so! Makes sense to me, anyway, so I'm going with it!
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