Re: RIN: 3245-AG58, Comments on Proposed Rule Small Business Government Contracting and National Defense Authorization Act of 2013 Amendments -

Dear Ms. Fernandez:

We are writing to submit comments regarding the U.S. Small Business Administration’s (“SBA”) proposed rule of December 29, 2014, regarding the implementation of a statutory mandate for the performance requirements applicable to small business and socioeconomic program set aside contracts and small business subcontracting. See Small Business Government Contracting and National Defense Authorization Act of 2013 Amendments, 79 Fed. Reg. 77955 (Dec. 29, 2014) (“Proposed Rule”). The Proposed Rule is designed to implement section 1651 of the National Defense Authorization Act (“NDAA”) of 2013, which changes the limitations on subcontracting for full or partial small business and socio-economic program set-aside contracts and small business subcontracting. Additionally, the Proposed Rule also contemplates changes to the SBA’s regulations governing the nonmanufacturer rule, affiliation rules, joint venture qualifications, and North American Industry Classification System (“NAICS”) code appeals.