COUNTIFS - Referencing two columns

Hi -

I keep getting an UNPARSEABLE error with my COUNTIFS formula. My intention is to have a summary of how many documents are pending approval from another department -

I need to return a count for how many rows have a date included in the "Date Submitted to OMB" column, but are missing a date in the "Date Returned from OMB" column.

Any help is appreciated. Thank you.

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