Comment on FR Doc # E9-24025

1) Maintain the intent of Congress by restoring the balance between the funding for loan capital and funding for training and technical assistance: In direct contradiction to the law, the proposed rule eliminates all grants to micorenteprise programs to provide business training to existing and prospective microentrepreneurs. In addition, the legislation caps technical assistance grants to organizations at $100,000, despite clear legislative language allowing such grants up to 25% of outstanding loans. By eliminating the training funds and capping technical assistance funds, the proposed rule will make it difficult for organizations to fund the staff needed to work with borrowers and other clients. Good business planing, skills in marketing, management and accounting are essential to business success. 2) Recognize an organization's desire to serve rural microentrepreneurs, not just its past experience serving rural microentrepreneurs: The proposed rule awards a higher score to microenterprise development organizations with past experience and to organizations currently operating in rural areas. The proposed rule disadvantatges rural organizations who want to add microentrprise services and disadvantages urban microenterprise organizations that want to expand into rural areas. Given how few microenterprise programs serve rural areas, the program must not send a signal that discourages development of new providers or expansion of existing programs into rural area. 3) Reflect the reality of how lending to microentrepreneurs actually works: The proposed rule is inflexible and will unnecessarily increases expenses for microenterprise service providers. For example, programs must identify prospective borrowers before they can receive loan funds from USDA. The result is that more time must be spent completing paperwork, leaving less time to serve microentrepreneurs. These rules ignore the flexibility needed to help microentrepreneurs be successful.