On the recordFebruary 5, 2015
This amendment proposes to strike section 10 from the bill, which gives the Small Business Administration's Chief Counsel for Advocacy authority to approve small business size standards for the purposes of any act other than the Small Business Act and the Small Business Investment Act of 1958. That includes, of course, authority to approve size standards for the purposes of the RFA. This makes sense, since the Chief Counsel for Advocacy, not the Small Business administrator, is charged with overseeing agency compliance with the RFA; and the Chief Counsel exercises that authority independently from the SBA administrator. The theory of the amendment is that, under section 10, a new size standards office, duplicative of the SBA administrator's own size standards office, will be created. But that is just not the case. The SBA administrator will retain the authority to set size standards under the Small Business Act and the Small Business Investment Act of 1958. But alternative size standards for the purposes of RFA compliance are a different matter, and under existing law, agencies must consult with the Chief Counsel for Advocacy with regard to those alternative size standards. To authorize the Chief Counsel for Advocacy to actually approve size standards about which it already must be consulted is simply to formalize an existing reality, not to create a duplicative function or a duplicative office.…





