C15.4.1. General. During the implementation phase of a BPC case the pseudo LOA document is Accepted by the IA, funds are placed on the case in the FMS Trust Fund by the Defense Finance and Accounting Service - Indianapolis (DFAS-IN), the case is Implemented, and obligation authority is granted to the IA. If the funds expiration date is imminent, the IA, DSCA (Business Operations Directorate) and DFAS-IN may initiate emergency implementation procedures. See Chapter 9.

C15.4.2. Acceptance. The IA is responsible for entering the Accepted milestone in DSAMS after the pseudo LOA document is Offered. An authorized representative of the IA will sign at the “U.S. Signature” block on the LOA. This is the only physical signature applied to the pseudo LOA document, as the DSCA counter signature data is updated by DSAMS. Neither the Benefitting Country nor the Funding Authority sign the pseudo LOA; the “Purchaser Signature” block is left blank.

C15.4.3. Funding. Before proceeding to implementation, DFAS-IN must confirm that BPC program funds have been collected into the FMS Trust Fund.

C15.4.3.1. DoD Appropriations. DSCA (Business Operations Directorate) sends a funding memo to DFAS-IN with instructions to collect DoD appropriated funds for the BPC case. BPC program funds will either be authorized for release by the Office of the Under Secretary of Defense (Comptroller) (OUSD(C)) or issued on a Military Interdepartmental Purchase Request (MIPR) (DD Form 448) by the Funding Authority. Funds from one fiscal year appropriation or type of appropriation cannot be combined with another fiscal year appropriation or type of appropriation to fund a BPC case.

C15.4.3.2. Foreign Assistance Act (FAA) Section 632(b). FAA, Section 632(b) Memorandum of Agreement (MOA) funds are obligated for the Funding Authority upon the last signature on the FAA, Section 632(b) MOA. DSCA (Business Operations Directorate) sends a copy of the signed FAA, Section 632(b) MOA to DFAS-IN along with instructions to collect the funds from the Funding Authority and to establish a separate account within the FMS Trust Fund associated with the BPC program. Transfer of funds into the FMS Trust Fund may take place prior to case development, but a completed Memorandum of Request (MOR) should be included with the MOA that is transmitted. Multiple BPC cases may be funded from a single FAA, Section 632(b) MOA. Additionally, an FAA, Section 632(b) MOA can be amended to add funds or change scope. Responsibility for funding cost overruns in excess of the funded amount should be clearly stated in the interagency agreement between parties and should be the responsibility of the Purchaser Agency.

C15.4.4. Implementation. The BPC case is Implemented when DFAS-IN notifies DSAMS of successful cash collection (or funds availability) in the FMS Trust Fund and obligation authority has been approved by the IA.

C15.4.5. Notification to the SCO. Immediately after a BPC case has been Implemented, the IA will notify the Security Cooperation Organization (SCO) and provide a copy of the Implemented case. The SCO may begin preparations for receipt of the materiel and services, as needed. The SCO will make no guarantee to the Benefitting Country that it will receive assistance, however, until the final delivery of the materiel or services.