Comment on FR Doc # 2011-03470

The new SBA 504 Refinance rule focuses on loans maturing by Dec 2012. However, most borrowers have multiple loans, say 1st and 2nd position loans. In cases the first is maturing, the lender is more than willing to refinance only that 1st position loan and have the 2nd remain in its position. In cases 2nd is maturing and 1st is not, we cannot find any lender in this market to finance just the 2nd loan. Please note that in this case, due to 504 regulations, the first position loan is not qualified for a refinance. The goal of the program was to focus on small businesses with risk exposure due to the loan maturity until 2012 but ignored the fact that a business with first position loan expiring after 2012 but 2nd expiring before can well be at risk if the 2nd position lender is not extending the loan and is calling the loan at maturity time. This is an urgent issue. The SBA has to urgently change the program regulations to cover such scenarios. We hope this change can be done before May 18th, 2011. Regards, Ramin Mostaan Principal Scientific Capital Group, Inc.