Comment on FR Doc # E8-29197

March 6, 2009 Mr. Bryan Hooper Director for Office of Credit Risk Management U.S. Small Business Administration 409 3rd Street, SW Washington, DC 20419 RIN No. 3245-AE14 Dear Mr. Hooper: This letter addresses the SBA’s Interim Final Rule on the Lender Oversight Program (13 C.F.R. 120). As an active SBA lender with Synovus Bank for 18 years I feel strongly that the Risk Rating System currently being used by the SBA is not necessarily the best and most effective method and there is too much reliance on this system in the over site process. I am not a proponent of heavy reliance on any credit scoring model and feel the flaws inherent in the models have contributed to today’s current financial crisis. I do believe, strongly, that SBA should over see all lenders actively involved in the program and all should be held accountable for their actions on an on going basis. However, the Risk Rating System (Loan /Lender Monitoring System) currently being used as part of this over site and being approved in this Final Rule has not been validated by an independent outside 3rd party and the banker’s who participate in the program have not been advised as to all that is involved with the scoring process. The Government Accountability Office (GAO) is currently undertaking a review of the system and it seems to me that it is prudent for the agency to defer finalizing the Rule until this study has been completed. Our Bank is becoming concerned that the SBA is moving towards an environment where I, as the lender, can no longer rely on being paid on our SBA guaranty even when I am following the rules and complying with the ever changing regulations. Our Bank will not be willing to lend to those small businesses unable to obtain the loan otherwise, unless we have full confidence the SBA stands behind us and the risks are mitigated. Is this not the spirit behind the Small Business Administration and its loan programs! Please suspend implementation of the Interim Final Rule. Thank you. Sincerely, Patrick Fenech Vice President/SBA Business Development Officer