Comment on A063-Advanced Notice of Proposed Rulemaking-Waters, Michael K.

Look at big picture organization of the SDVOSB, not nitpick the Company Agreement for things like "what if the CEO isn't present at the meeting?" which would not happen! Community property states should not be a consideration. It's silly to say my housewife owns half my shares, so she "could" try to take control of my company to its detriment. Review the whole Company Agreement once, and tell the applicant everything that needs fixing in one letter back. Stop picking at one little thing every six months. Look for how you CAN approve, not how you can avoid approval. Timeliness. If you can't find enough to deny in six months, then approval should be automatic. I spent three years fixing minor nitpicks, and I'm STILL not approved, yet I met the intent of the Programs the first day! Govt has no clue what personal investment it takes keeping the company in existence while waiting (insurance, licenses, fees, infrastructure, etc.). Control: the whole idea that a former employer can't be a minority partner to an SDV is wrong. They don't "control" the new company just because they're willing to help and mentor. Be aware outside employment may be required pending approval. I started an IT company, but can't bid on SDVOSB contracts, nor allow larger teams to get credit for using me, until I get approved. Am I supposed to have zero income three years waiting for VA to find another nitpick in my Company Agreement? CVE seems to only want to approve pre-existing businesses that are just seeking SDVOSB status. If an SDV forms a business in order to team or bid as an SDVOSB, then the contracts/work won't come until after approval. This is different from an SDV who already owns a business and just wants to get certified.