Comment on FR Doc # 2011-03470

I am very glad to see that the Gov. has expanded the eligibility for refinancing with the 504 program. However this does not help to restrict the policy to onlly balloons. The refinancing change to the 504 program needs to mirror the 7a program. The small businesses needing help and restructure is an option need to be able to use the 504 program with today's low fixed rates! This is a tool that can help them survive the economic downturn. The 504 program is a great way to partner private industry (banks) with CDC's and the Gov. It is a win win for everyone including small business. It reminds me of the old 75/25 IP program in the 70's where you had bank private funds and Gov funds assisting small businesses with a combo of variable and fixed rate financing. In our bank we don't have real estate loans with balloons so if we restructure debt on a small business we could only and we do use the 7a program. I want the same criteria as the 7a refinancing rules for the 504 program so I can use that program to benefit the small business with a low fixed rate. In the end you should get a lot of comments this way from lenders so we can successfully use a program that I assume SBA would want us to utilize. Thank you!