Comment on FR Doc # E7-20932

We are a small rural CDC in South Dakota. Our general concerns mainly are with the additional costs and labor that would be involved to implement the proposed changes. Specifically our comments follow: 1.We are currently not subject to the Single Audit Act. I was not able to get a hold of our auditor at this time, however in my quick calculations, I?ve determined this to be upwards of $15,000. 2.Reducing the timeframe for the annual report would make the deadline extremely difficult for our CDC to meet to say the least. As I mentioned we are in a rural area and we are at the mercy of our auditors as to when they can get here. We don?t have a lot of choices for available auditors, nor would changing auditors make it easier to meet the deadline. At this time we usually see our audit by the beginning of Feb (we have a fiscal year end of Sept. 30), so even 120 days would be difficult. I would strongly advise that this time frame be left as is. 3.Our concerns for adopting an internal control policy revolve around costs and the level of control that will be considered standard. We certainly do not oppose and currently have internal controls in place. Depending on the level of controls that SBA will hold us to, it could mean significant costs and labor in preparing and implementation. 4.We have no concerns about the size standard being proposed. 5.We would support a proposed bureau of PCLP oversight. These CDCs have the most latitude and account for a large number of the SBA 504 deals that are being completed, therefore we feel they should have the most oversight.