Comment on FR Doc # 2026-11765

Lynette T. Stevenson, Founder DALS Credit Solutions Co. Thank you for allowing public comment on this proposed rule. I submit that this section addresses what appears to be a repackaging of reform in a way that removes the rebuttable presumption for individually owned 8(a) firms while expressly leaving entity-owned firms untouched. That distinction deserves more than a passing statement. It requires a full legal, statutory, procurement, and competitive-impact explanation. The proposed rule places additional evidentiary weight on non-entity-owned firms while preserving the existing treatment of entity-owned firms. This raises serious questions about fairness and program integrity. Individually owned firms already face extensive certification requirements, ownership-and-control reviews, economic disadvantage reviews, continuing eligibility obligations, limitations on subcontracting, past-performance barriers, bonding constraints, access-to-capital barriers, and agency-level gatekeeping. SBA should not increase the burden on those firms while declining to examine whether entity-owned firms receive structural advantages unavailable to non-entity-owned participants. SBA should directly address whether entity-owned firms receive advantages that individually owned 8(a) firms cannot realistically access. These advantages may include ownership structures involving parent entities, repeated participation through subsidiary entities, separate treatment of economic disadvantage, expanded sole-source authority for certain entity-owned concerns, access to capital through parent or affiliated structures, and the ability to use procurement participation as part of a broader investment, acquisition, or portfolio strategy. If SBA contends that these advantages remain justified, non-entity-owned firms have a right to ask why, based on current data and not historical assumptions. This issue also raises a broader question about capital, investment, and procurement influence. SBA should examine whether investment structures, including SBIC-related capital relationships, affiliated financing, parent-entity backing, or other private-capital strategies, indirectly strengthen entity-owned firms in ways that affect award access and market distribution. I am not asserting that SBIC licensing itself directly controls 8(a) award distribution. I am asking SBA to examine whether capital access, affiliated investment, parent-entity resources, and statutory procurement preferences collectively create a protected market position for entity-owned firms that individually owned 8(a) firms cannot match. This is not merely a question of statutory protection. It is a question of whether statutory protection has been converted into market insulation. Congress may have created separate statutory pathways for certain entity-owned firms, but statutory recognition does not excuse SBA from reviewing competitive impact, award concentration, control, affiliation, pass-through risk, mentor-protégé leverage, joint-venture structure, task-order access, and whether actual contract dollars reach the disadvantaged firms the program was designed to develop. If entity-owned firms receive a dominant share of 8(a) awards, SBA must examine whether the 8(a) program still advances the Small Business Act’s purpose for individually owned firms. The Small Business Act exists to aid, counsel, assist, and protect small business concerns; preserve free, competitive enterprise; and ensure that a fair portion of federal contracts are placed with small businesses. That goal is not satisfied if individually owned firms carry the burden of reform while entity-owned structures retain the economic benefits of program access without comparable scrutiny. SBA must provide the legal authority, current data, competitive-impact analysis, award-concentration analysis, and program-integrity findings supporting its decision to leave entity-owned firms unaffected by this proposed rule. If SBA believes the statutory framework protects entity-owned firms from this reform, SBA should say so plainly and explain how that position complies with the Small Business Act, FAR Part 19, FAR 16.505, 8(a) program-integrity requirements, and the government’s obligation to preserve meaningful access for all eligible small business concerns. Respectfully, Lynette T. Stevenson Founder, DALS Credit Solutions Co. Please see the attachment