Comment on FR Doc # 2026-11765
Anonymous AnonymousSupportIndividual
Summary: The commenter, representing "interested members of the public," supports the SBA's move to remove the rebuttable presumption of social disadvantage but argues that the final rule must require some verification of an applicant's own material harm rather than relying solely on self-certification. They also provide several recommendations regarding eligibility verification, phasing in the new standard, and measuring the program's long-term success.
We respectfully submit the attached statement as a comment on the proposed rule (RIN 3245-AI75; Docket No. SBA-2026-0133). We generally support the rule's central objective of removing the rebuttable presumption of social disadvantage and replacing it with a constitutionally sound standard. We do not believe, however, that the proposed test should be finalized as written: as the attached statement explains, it should require some verification of an applicant's own material harm, and should address the related statutory, administrative-law, and administrability concerns identified there. We respectfully request that SBA enter the attached statement into the administrative record and consider its recommendations before issuing any final rule.