Comment on FR Doc # 2011-26208

The SBA website describes the size standards are to ensure a “level playing field” for small business. The SBA has not kept up with current business practices, which in my opinion have made the size standards nearly irrelevant. Here are a few key problems: 1) Problem – Today businesses are not solely involved in one area. They span several NAICS codes – usually 2-3 as a manufacturer, 2 as a wholesaler, 3 as retailer and 2 services provider. They are limited by the # of employees in Mfg, however when 50% of business is as a wholesaler of items manufactured overseas, there is no problem avoiding the standard. Solution – provide both employee # and a total revenue limitation. 2) Problem - The largest of all small businesses are 1000, with a few under the 1500 exception. The largest revenue for a small business is $35.5 million. There are ‘small businesses’ in manufacturing with 1000 or 1500 employees and several hundred million in annual revenue. How can even a $100 million manufacturer be considered small business? Solution – provide both an employee number and a total revenue limitation. 3) Problem – Publicly traded small business. In today’s complex financial landscape there are publicly traded ‘small businesses.’ These small business have access to capital and other resources that not possible for a normal small business. Typically, these are managed by people formerly from large business. With these types of resources, how can you have ‘level playing field.’ Solution – Provide a 50-75% size penalty for publicly traded businesses limiting both their size and revenue to be considered small. 4) Problem - Acquisition & Merger activity without regular review of size standards. M&A’s are happening on a regular basis. The size standards determination calculations need to be simple enough for anyone to re-calculate and comment to SBA. Solution – Web based information for individuals to review size standards.