1. Case Identifier. DSCA (Strategy Directorate) will assign a case identifier composed of country code (e.g., "G4" for Pakistan Counterinsurgency Capability Fund (PCCF) as transferred into Pakistan Counterinsurgency Funds (PCF)) and Implementing Agency code of the DoD Component providing the support. Implementing Agencies may request unique designators to meet their requirements as identified in SAMM Figure C5.F5.

2. Nickname Field. The country/organization receiving the support and the Pseudo case authority and the text "(Non-FMS)" (e.g., PCF, P.L. 111-32, (Non-FMS)) are identified in the "nickname" field on the Pseudo LOA. Since Pakistan has three internal customers, Defense Security Force (DSF), Frontier Corps (FC), and Related Activities (RA), PCCF cases should be identified as PCF/DSF, PCF/FC, or PCF/RA, P.L. 111-32 (Non-FMS).

3. Purchaser's Reference Field. Include the following statement below in the Purchaser's Reference Field of the Customer Request:
"Based on funds provided and the request of Program Originator [insert Program Originator's name (e.g., ODRP, Combatant Commands, etc.) and LOR/MOR reference number] to the Defense Security Cooperation Agency, dated [insert date of written request]. The legal authority is P.L. 111-32, Supplemental Appropriations Act, 2009. See Note [insert LOA note number] for additional information."

4. Terms of Sale Field. The Term of Sale for PCF Pseudo LOAs is Cash with Acceptance, Public Law 111-32.

5. Authority Field. Insert "PCCF Supp Act, PL111-32" (in DSAMS only).

6. Authority Fiscal Year. Insert "FY 2009" (in DSAMS only).

7. Purchaser Signature Field (Customer Signatory Name on Distribution Tab of Case Detail). Insert the authority and the statement that no purchaser signature is required (e.g., P.L. 111-32 (Non-FMS - No Purchaser Signature Required)).

8. Purchaser Mailing Address. Insert "Department of Defense".

9. MASL. Use valid existing MASLs for items being transferred or contact DSCA to approve new MASLs, if required.

10. Delivery Term Code. For Supplemental Appropriations Act, 2009 (P.L. 111-32) Pseudo LOAs, use the Delivery Term Code (DTC) for Defense Transportation System that will provide shipment all the way into recipient country. This is generally accomplished through DTC 7, unless DTC 9 suffices.

11. Offer Expiration Date. The Offer Expiration Date on the LOA should be no later than the last date the funds are required to ensure they are obligated prior to the funds expiring.

12. Benefitting Country. Pakistan (PK)

Authority for Sale - P.L. 111-32 Programs

Mandatory for all P.L. 111-32 Pseudo LOAs.

"This sale is made under the authority of P.L. 111-32 and the Arms Export Control Act (AECA). Any reference in this Letter of Offer and Acceptance to the United States Arms Export Control Act, to defense articles, and to defense services shall be construed instead to be a reference to P.L. 111-32 and the United States AECA. Any reference in this LOA to "purchaser" shall be construed as a reference to the Department of Defense."

Case Closure - P.L. 111-32 Programs

Mandatory for all P.L. 111-32 Pseudo LOAs.

"This case must be fully reconciled and closed by 31 July 2016."

Funds, Purpose, Availability and Amount P.L. 111-32 Programs

Mandatory for all P.L. 111-32 Pseudo LOAs.

"The funds financing this Pseudo Letter of Offer and Acceptance (LOA) are expiring funds and are subject to all the requirements and restrictions under the heading of P.L. 111-32. The Supplemental funds provided carry the same time, purpose, and availability restrictions associated with fund source 21 9/11 2095.

1. Failure to obligate the funds during the period of availability ending on 30 September 2011 will render them unavailable for new obligations after that date.
2. All funds must be expended on or before 31 July 2016.
3. Total funds available for expenditure against this Pseudo LOA are limited to the value of [insert dollar value].
4. Amendments or Modifications to this Pseudo LOA are only authorized with DSCA written approval."

Nonrecurring Costs - USG Appropriation

Mandatory for LOAs when an NC charge has been established, but the case is financed by a USG appropriation.
Mandatory for Amendments or Modifications when the case is financed by a USG appropriation and (1) lines items are added and the NC charge applies to the new lines; or (2) quantities are increased on line items for which NC charges have been established.
See Chapter 9, C9.4.5.

"Nonrecurring Costs (NC) have been established for line item(s) [insert line item numbers] of this case. These charges are not included on this case because the case is financed with a USG appropriation."

Title and Custody Transfer - P.L. 111-32 Programs

Mandatory for all P.L. 111-32 Pseudo LOAs for FY 2009

"The U.S. Government will retain title to and custody of the defense articles to be transferred under the authority of P.L. 111-32 until delivery to the recipient country. A designated U.S. Government representative will confirm and document delivery of the P.L. 111-32 program materiel to an authorized recipient country representative or agent. This U.S. Government representative will keep documentation showing when, where, and to whom delivery was made and will provide a copy of this documentation to the [insert U.S Army Security Assistance Command, U.S. Army Corps of Engineers, Navy International Programs Office, Deputy Under Secretary of the Air Force/ International Affairs, or Air Force Center for Engineering and the Environment]."