Comment on FR Doc # 2012-02519

I was a contract bond underwriter at CBIC (www.cbic.com) from 1991 to 2007 having authority to approve bonds up to $500,000 without review by a second underwriter. Over 70% of my accounts were below $500,000. CBIC started a streamlined Performance Bond program, first, in Arizona at $75,000 in the late '80's and then started the $100,000 program in Washington State in 1991 under my supervision. This limit went to $200,000 in the late '90's when the loss experience justified it. Many other sureties found this to be a very profitable niche and developed many programs with advertised limits of $250,000 and one program to $500,000 based solely on the personal credit of the; however, it must be pointed out that this Surety (Travelers) was a very large Insurance Company with many of the insurance agents having been former Travelers Underwriters. There was a close bond and deep financial interest between Travelers and their agents to assure no bad credit got through. I'm puzzled. What is the SBA doing entering the "Streamlined" performance bond program so late in the game . . . two (2) decades from the begging of CBIC's program in Washington State? I am deeply disappointed that it has taken "THE GREAT RECESSION" to move the S.B.A. in this direction. I would encourage you to adopt this program and evaluate the results after a year. If the results are favorable, move to higher limits . . . $300,000 . . . $350,000 . . . $400,000, etc.. Reach out to the NASBP and Surety Association of America for disclosure of the programs their members offer their Insurance Agents. If this is not transparent, go to the internet and search for what is offered and what underwriting principals are followed. But, you must make greater efforts in with the streamlined approach. S.B.A. is decades behind the industry on this. And, this is the very niche you must provide an easier approach to. Good luck! Eric