Re: Comments on Proposed Rule Regarding Advisory Small Business Size Decisions RIN: 3245-AG59, Docket Number: SBA-2014-7 -
Dear Mr. Koppel:
We are writing to submit comments regarding the U.S. Small Business Administration's ("SBA") proposed rule of June 25, 2014, regarding the implementation of a statutory mandate for the provision of small business status advisory opinions ("Advisory Opinion"). See Advisory Small Business Size Decisions, 79 Fed. Reg. 35963 (June 25, 2014). The proposed rule is designed to implement section 1681 of the National Defense Authorization Act ("NDAA") of 2013, which establishes a "safe harbor" from fraud penalties for individuals or firms that misrepresent business concerns as being small for purposes of Federal procurement opportunities if they acted in good faith reliance upon an Advisory Opinion received from a Small Business Development Center ("SBDC") or a Procurement Technical Assistance Center ("PTAC").
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