Should be allowed to pool all eligible 1st REM loans even if same institution debt is being refinanced.
Loans that mature beyond 12/31/2012 should be eligible to be refinanced.
Expansion funds should be allowed to be included in a refinance package.
The bank portion of the project funding should be 50% or greater of the eligible project amount.
Comment on FR Doc # 2011-03470
This is comment on Rule
Small Business Jobs Act: 504 Loan Program Debt Refinancing
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