Includes comments on:

  • SBA Should Delay Implementation and Work to Change the Law
  • SBA Certification Program
    • If SBA Adopts the Certification Requirement, SBA Should Be the Only Certifier
    • Streamlined Application Process
    • Concurrent Certification Through 8(a) Program
    • Term of SBA Certification
  • Third Party Certification
    • New Regulations & Procedures Are Needed if SBA Permits Third Party Certification in Addition to SBA Certification
    • All Certifiers Should Apply or Re-Apply
    • Term of Third Party Certification
    • No Repository Access for Third Party Certifiers
    • Mentor-Protégé Agreements and Joint Venture Agreements
    • SBA Should Clarify Applicability of the Certification Requirement to WOSB and EDWOSB Industries
  • Certification by States and Other Federal Agencies
    • State WOSB/EDWOSB Certification Authority
    • Acceptance of DBE Certifications in Determining Ownership and Control
    • State Entities’ Expertise
    • Other Federal Agency Certification, Including Contract-Specific Certification
    • WOSB/EDWOSB Protests of Firms Not Certified by SBA