Comment on FR Doc # 2026-11765

580 Strategies LLC respectfully submits the attached comments in response to Proposed Rule RIN 3245-AI75, Docket No. SBA-2026-0133 (91 Fed. Reg. 35433, June 11, 2026). 580 Strategies is a small business and a pending 8(a) applicant that delivers cloud platform and CRM systems, digital transformation services, and agile software development expertise to federal, state, local, and tribal government clients. We write both as an affected small business with a direct stake in the outcome and as former SBA public servants who believe in this program and want to see it administered lawfully. Our full comments are provided in the attached PDF. In summary, we ask SBA to withdraw or substantially revise the Proposed Rule, and at minimum to: publish a proper Regulatory Flexibility Act analysis rather than a bare certification of no impact; resume processing all applications frozen since August 2025; retain the race-neutral personal narrative pathway that survived Ultima; define "cultural group" by reference to established antidiscrimination law; restore the recognized bases of disadvantage the new test drops, including gender; specify the certification standard and required nexus of harm; recognize the reliance interests of current participants; and explain the statutory basis for the new test under Loper Bright. Consistent with SBA's obligation to respond to significant comments, we ask that each concern raised in the attached document be addressed on the record in any final rule. Please see the attached PDF for the complete comments.