Comment on FR Doc # 2011-03470

Dear SBA, We are a CDC in Lancaster, Pennsylvania. To this point we have not processed an SBA 504 refinance project, but we have talked to dozens of interested companies and bankers. The changes that have been made to the refinance program to date have all been positive, but it just takes time for new initiates to get rolling sometimes and that is what we are seeing now with the SBA 504 refinance program. Companies and bankers in our local area now finally are understanding how it will work, so I anticipate the deal flow will soon happen. In our area, appraisers are very, very backlogged, sometimes up to 60 days until an appraisal is delivered. Since we cannot structure a reifnance project until we have an appraisal, we are waiting to even start on some of our first refinance deals. The 50% participation requirement of the bank has been a little restrictive at times. I know the goal is to not take all the deal away form the bank, but we actually have seen some good deals we had to pass on because they have decent loan to value. I feel the banks actually would have not minded being less than 50% LTV in those cases because they are OK giving up some loan if it means the company will be in a stronger position in the long run with a long term fixed interest rate, etc. Having to prove the "History" or original use of proceeds is a little cumbersome in some cases, but I can understand why we need to do it. Other than that, we just need time to get things rolling and time to get the appraisals ordered and in. My biggest concern is that we have now used up most of the time on the first year's $7.5 billion allocation. I think an extension will be of help in 2012 - 2013 when the 504 refinance program has been marketed and understood and things are full speed ahead. It would also be helpful to not have the 50% Loan to Value limitation or let the bank sign a waiver so a 504 debenture can do more so we can get stronger deals in the portfolio. Thanks, Lyle