Comment on FR Doc # E8-29151

1. I strongly recommend the proposed requirement that all lenders must apply to become approved lenders be amended to allow all regulated or supervised lenders that can certify they are in good standing with its regulator be automaticallty considered an eligible lender. The current regulations have operated this way for decades and there have been few problems with traditional, regulated lenders. The application process should only be required for the non-regulated, non- traditional lenders and for preferred lenders. Regulatory agencies such as the FDIC, OCC, OTS, FCA and NCUA are the qualified entities to evaluate lenders, not USDA staff. Furthermore, USDA staff do not have the resources to conduct the required biennial reviews required of all approved lenders. This represents a duplication of the lending regulatory agencies and a unnecessary burden to both USDA and lenders. In addition, this process threatens to significantly curtail the ability of these programs to maintain continuous operation when the new regulation becomes effective as all loan guarantees will halt until such time as there is a new "supply" of approved lenders. This is not appropriate customer service during the current economic downturn when the programs are most needed and when there is the possibility of additional funding authority in the Economic Stimulus Package. 2. There are a number of non-traditional community lenders who have been funded by CDFI (Community Development Financial Institution). There is a CDFI review process (believe it is called CARS). This should be considered as an acceptable examination to qualify these lenders for approved lender status.