Comments Sought: Proposed Rule To Establish Government-Wide Mentor-Protégé Program

February 11, 2015

By Sean Milani-Nia

On February 5, 2015, the Small Business Administration (SBA) issued a new proposed rule that would establish a Government-wide mentor-protégé program for all small businesses.

Under the current framework, entities that enter into joint venture agreements to perform federal contracts are, in most instances, considered “affiliates.”  In determining a company’s eligibility to compete for set-aside procurements, the SBA combines the offeror’s size with the size of its affiliated entities. Thus, an otherwise eligible small business may be deemed large due to its affiliation with another entity.

An exception to this general rule exists for participants in the SBA’s 8(a) mentor-protégé program.  Under the 8(a) mentor-protégé program, an 8(a) protégé can joint venture with an approved large business mentor without being deemed affiliated.

The SBA’s proposed rule seeks to extend the mentor-protégé program to all small businesses. The intent is to create parallel program for non-8(a) small businesses, including participants in the HUBZone, Women-Owned Small Business, and Service-Disabled Veteran Owned Small Business programs, that is identical to the 8(a) mentor-protégé program. Under the proposed rule, any small business would be able to enter into an SBA approved mentor-protégé relationship and joint venture with its approved mentor without being considered affiliated.

Expanded Protégé Definition

Note that the proposed rule would allow more businesses to qualify as protégés under both the 8(a) mentor-protégé program and the proposed small business mentor-protégé program. Currently, in order to qualify as a protégé under the current 8(a) mentor-protégé program, an 8(a) contractor must (1) have a size that is less than half the size standard corresponding to its primary NAICS code; (2) be in the developmental stage of its 8(a) program participation; or (3) have not received an 8(a) contract.

The proposed rule provides that any firm that qualifies as a small business for the size standard corresponding to its primary NAICS code would qualify as a protégé under either the small business mentor-protégé program or the 8(a) mentor protégé program. SBA proposes to remove the requirement that the small business protégé have a size less than half the size standard corresponding to its primary NAICS code.

Ownership Interest

Similar to the 8(a) mentor-protégé program, the proposed rule provides that a mentor may own an equity interest of up to 40% in the protégé. This could be a significant opportunity for small businesses that are looking to increase working capital.

If finalized in the current form, the proposed rule would create significant opportunities for the participants in the new mentor-protégé program, but could place those small contractors that do not participate at a competitive disadvantage. Contractors who are interested in participating should begin evaluating potential partners and even structuring their agreements. The SBA has recognized that once the proposed rule is finalized, the number of firms seeking SBA approval of their mentor protégé agreements may become “unwieldy.” SBA states that it may institute certain open and closed periods for receipt of mentor-protégé applications. SBA would only accept mentor-protégé applications in open periods. Contractors should be prepared to submit their applications as soon as possible to avoid missing the first open period.

Comments on the proposed rule are due on April 6, 2015.  Send your comments prior to April 6 to Federal Allies Institute 571-217-0823.

Federal Allies News March 2014

March 17, 2014

Letter from the Executive Director

SBA’s New Emerging Leaders Program: StreetWise Steps™ to Small Business Growth

U.S. Small Business Administration’s Emerging Leaders initiative has asked Federal Allies to publicize the agency’s search for CEOs of established small businesses to enroll in a free evening program to help grow revenues and jobs.  Twice monthly, 13 sessions, 40 classroom hours currently planned for 27 cities.

Requirements include three years in business, two or more employees, annual revenue $400,000 to $10 million, and DBEs or lower income census track.

Module 1: Business and Strategy Assessment. Module 2: Financials. Module 3: Marketing and Sales. Module 4: Resources- People, Accessing Capital and Government Contracting.  Module 5: Putting it all together – Strategic Growth Plan Presentations.

Contact your local district office.  More information is available online at or you may e-mail

A Brief History of Federal Allies and SBA

Federal Allies Institute was launched during National Small Business Week 2008, the U.S.A.’s top small business recognition program and organized by the U.S. Small Business Administration.

The mutually beneficial relationship between Federal Allies and SBA has quantifiably helped small businesses.  For example one project included SBA’s request for a free biotechnology grant application seminar, organized by Federal Allies that helped enable 26 research firms to each receive one or more grants of $244,000.  In addition to SBA, the grant process included the U.S. Department of the Treasury, U.S. Department of Health and Human Services, and U.S. Food and Drug Administration.

Several top biotechnology associations, including BIO, were recruited to serve on panels of the Federal Allies event.

Welcome New Members


Welcome Distinctive Home & Health Care! The Distinctive Home & Health Care 1st Annual Heart Disease Awareness Networking Event held at Distinctive Home & Health Care’s Corporate Office. (L to R) Deborah Guynn, President, Jim Guynn, Vice President, Regina L. Singletary, Executive Assistant, DHA Acquisition Management & Support, and Chante Davis, Director of Operations. Guests enjoyed delicious appetizers with wine provided by Kathy Gaines. A fundraiser for research, guests received copies of USDA 10 Tips to Be Active Adults  and Affordable Care Act Sign Up Locations for Residents of Montgomery and Prince George’s Counties, in Maryland.

Federal Allies Institute Corporate Ethics Certification Program Underway

The Winter Sessions of Federal Allies Institute’s Corporate Ethics Certification are being held during February and March.  A second program planned for the Spring is currently seeking enrollees.  The fee for members is $1,000 and non-members $1,500.  The Federal Allies Institute Scholarship Program offers a limited number of partial scholarships.  The Federal Allies Institute Board of Overseers for the program seeks to expand.  Recent meetings to publicize the program have been held including with U.S. Senators Mark R. Warner and Tim Kaine, both of Virginia, the home state of the Federal Allies Institute.


David T. Boddie

Executive Director, Federal Allies Institute

Federal Allies News April 2013

April 1, 2013

The March 27-28 Region 6 Roundtable produced by Mid America Industry Government Coalition in collaboration with Federal Allies Institute Oklahoma Chapter was an informative, successful and fully-subscribed event.  With FAI’s input the Roundtable set into motion a grassroots gathering of comments on Mentor Protégé to be followed up upon at Federal Allies Institute’s Washington Days Conference May 6-7, 2013 in Washington, D.C.  The beneficiaries of our collective comments are the U.S. Small Business Administration and other areas of the Federal government.  Regulators will accept the comments, consider and respond to them before making final decisions.


As the readership of Federal Allies News knows, the National Defense Authorization Act contains many small business issues, including Mentor Protégé that the Federal Allies Institute has tracked and promoted dating from the 111th Congress unto today.


We note the government’s move online has not produced a fundamental shift in the nature of notice-and-comment rulemaking. A decade into e-Rulemaking, and four years since the Open Government Memorandum – that promised to incorporate rulemaking within a Social Media setting – it has not achieved the gains in efficiency and democratic legitimacy that were anticipated.  It is simply not used to any great extent, but we certainly appreciate the effort and look forward to the day that e-Rulemaking may be the norm.  For now our engaged and informed members still use the traditional methods of notice-and-comment.


As you attend Washington Days Conference to find your next contract and to establish new relationships, should you have comments for rulemaking we encourage you to voice your comments at Washington Days in person.


David T. Boddie

Executive Director

Government Connections Network: Washington Days Conference, May 6-7, 2013 in D.C.

March 24, 2013

Government Connections & Network

How to sell to the federal government, large and small businesses nationwide.

 May 6-7, 2013 Holiday Inn Capitol, 550 C Street, S.W., Washington, D.C. 20024


The 4th National Small Business Conference known as Washington Days Conference is for Federal agencies, DoD, Corporations, Small Businesses.

Government, Corporations, Small Businesses & Mentor Protégé Programs

Featuring Federal Agencies Matchmaking, Mentor-Protégé, National Defense Authorization Act, and Vetted SME Expertise.
For all Small Businesses including 8(a), HUBZone, SDVOB, SDB, WOSB, DBE, & MBE.

U.S. Department Homeland Security, National Geospatial Intelligence Agency, U.S. Small Business Administration, Social Security Administration, U.S. Agency for International Development, Defense Logistics Agency, U.S. Environmental Protection Agency, Lockheed Martin MST Undersea Systems, and more.

20 Matchmaking Table Discussions

Many Federal Agencies & DoD


The National Defense Authorization Act & Mentor Protégé

Emily Murphy, Senior Counsel, U.S. House Small Business Committee                                        


U.S. Small Business Administration & Mentor Protégé Changes

Calvin Jenkins, Deputy Associate Administrator, Office of Government Contracting & Business Development, U.S. SBA


Lockheed Martin Mentor Protégé Program & Diversity Program

Robyn H. Snyder, Supplier Diversity Program Manager, Lockheed Martin MST Undersea Systems


Mentor Protégé Programs:  A Legal Perspective & Update

Ralph C. Thomas III, Barton Baker Thomas & Tolle, LLP


Federal Agency Mentor Protégé Programs Panel Discussion

Anthony “Tony” Eiland, Program Manager, U.S. General Services Administration Mentor Protégé Program

Kevin Boshears, Director, Office of Small and Disadvantaged Business Utilization, U.S. Department of Homeland Security

Federal Allies News February 2013

February 1, 2013

Impact Federal Mentor-Protégé Rulemaking – Come to Oklahoma!

Small Business recommendations are being sought on federal Mentor Protégé Rulemaking.  The Federal Allies Institute Oklahoma Chapter is collaborating with a number of entities such as Mid America Government Industry Coalition that will sponsor Region VI Roundtable on Mentor-Protégé Agreements conference March 26-28, 2013 at the Oklahoma City Marriott.  “Key to the Federal Allies Network and the basis of FAI as an organization is grassroots collaboration,” said Mickey Thompson, FAI Oklahoma Chapter Chairman.

Small business representatives from the federal government will review the current status of the mentor-protégé program and meet with small businesses to explain the benefits of the program. Plenary sessions will be conducted to discuss the upcoming rulemaking in order to get input on different approaches to expanding and strengthening the mentor-protégé programs. These recommendations are to be presented in concert with the FAI Oklahoma Chapter to the national Federal Allies Institute Board of Directors for consideration, prioritization and adoption by the entire FAI membership.

“We know that federal contracting has no borders and input is critical to impacting the upcoming rulemaking process for the Mentor-Protégé Program.  We intend to be heard before the rules are published,” said Kay Bills, President, Mid America Government Industry Coalition, Inc.

Mentor-Protégé issues are on the agenda of Washington Days Conference, May 6-7, 2013 in Washington, D.C. to be held near Capitol Hill and close to the headquarters of most federal agencies.  “In this instance, the Federal Allies Network is able to add value to the small business federal contracting community by convening and facilitating direct communications between business and government at the conference, but our Washington presence enables FAI to take it a step further by enabling continual communications and in-person interactions year round on behalf of our members” said, Frank Clay, Jr., Chairman of the Board, Federal Allies Institute.  For more information, visit

Use the National Defense Authorization Act of Fiscal Year 2013 to Succeed in Federal Contracting

Why tackle contracting alone?  Federal Allies invites Small Business entrepreneurs to take advantage of its special breakfast series on boot-strapping Small Business.   The February 5 NDAA breakfast seminar is made possible by FAI and U.S. House Small Business Committee and features presentations by Corey E. Cooke, Associate Counsel, U.S. House Small Business Committee and FAI Chairman Frank Clay, Jr.  It will be held in Vienna, Virginia at the Hilton Garden Inn – Tyson’s Corner.  In 2012 the FAI Board of Directors voted in favor of the NDAA and developed a three point outreach program to highlight the Act.  For more information on NDAA and to attend the event, visit

Meetings with Newly-Elected Members of the 113th U.S. Congress

In preparation for Washington Days Conference 2013, Federal Allies Government Relations Committee continues with introductory meetings on Capitol Hill started immediately following the last election.  Meetings in February will include newly-elected U.S. Representatives Jim Bridenstine, OK (D-1) and Markwayne Mullin, OK (D-2).

Federal Allies Asked to Join SBA Leadership Group

U.S. Small Business Administration Chief Counsel Dr. Winslow Sargeant has enlisted Federal Allies Institute to participate in SBA Office of Advocacy policy-related meetings to strengthen the voice of small business by leveraging FAI’s nationwide small business membership and the Federal Allies Network.   Dr. Winslow provided the key-note address to small business at Washington Days Conference 2012.

David T. Boddie

Executive Director

Federal Allies Institute

Advance Notice: Small Business Lending in the United States 2010-2011

July 19, 2012

Tomorrow, the SBA Office of Advocacy will release a new research study, “Small Business Lending in the United States, 2010-2011.”

You will not be surprised to learn that overall lending to and borrowing by small businesses was weaker in 2011 than the previous year.

Small Business Lending in the United States, 2010-2011

By Victoria Williams, U.S. Small Business Administration, Office of Advocacy, Office of Economic Research, 2011.

The availability of credit is paramount to small business health, growth, and survival. Annually, the Office of Advocacy prepares the study of Small Business Lending in the United States that examines the lending environment of depository lending institutions. This report is intended to inform prospective lenders, policymakers, business owners, and lending institutions of developments in the small business loan markets.

The study relies on two types of data reported by depository institutions to their regulatory agencies and made available for analysis—The Call Report data and the Community Reinvestment Act (CRA) Reports. The lenders are ranked on their overall small business lending nationally and on a state-by-state basis.

The first section of Part One looks at the changes in the Call Report data; the second reviews developments based on the CRA database. Listings of the top small and micro business lenders in the 50 states, the District of Columbia, and some U.S. territories are found in Part Two of the report.

All small business lenders filing reports in the U.S. economy are examined. The data does not allow differentiation between SBA loans and all small business loans. This report includes cooperative banks in addition to savings banks, savings and loan associations, and commercial banks.

Overall Findings

Overall lending and borrowing by financial depository institutions and small businesses was weaker in 2011 than in the previous year, as borrowers and lenders continued to postpone new borrowing and lending in reaction to an uncertain economy.


• While business lending in amounts of more than $1 million turned upward, small business lending under $1 million remained restrained. Small busi-ness loans outstanding in June 2011 were valued at $606.9 billion, down 6.9 percent from $652.2 billion the previous year. The dollar volume of borrowing by large corporations in loan sizes over $1 million increased by 5.8 percent in 2011, compared with an 8.9 percent drop in 2010.• Borrowing declined for both types of small business loans—commercial real estate (CRE) and commercial and industrial (C&I) loans under $1 million—but at a slower rate for CRE. The value of the smallest C&I business loans or micro loans (less than $100,000) declined by 12.7 percent, from $137.2 billion in June 2010 to $119.8 billion in June 2011. CRE and C&I micro loans combined were valued at $139.5 billion in 2011.• Megabanks—those with $50 billion or more in assets—accounted for 38 percent of small busi-ness loans outstanding and for 51 percent of the total decline in small business loans.• The number of multi-billion-dollar lenders with assets over $10 billion was down from 94 in June 2010 to 92 in June 2011. Their share of total assets, however, grew from 76.7 percent to 77.3 percent during the same period.• The CRA data on small business lending mir-ror the results in the Call Report data. In 2010, 774 CRA-reporting institutions extended 4.3 million loans of less than $1 million, for a total of $178.8 billion in small business loans; this compares with a 2009 total of 6.2 million loans valued at $205.7 billion made by 799 depository lending institutions.

Scope and Methodology

The study uses two types of data to analyze the lending environment of depository financial institutions for the years 2010-2011. The Call Reports include information on the amount and number of outstanding loans as of June 2011, and the Community Reinvestment Act (CRA) data cover loans made in 2010. The reported data are available only by the size of the loan, not by the size of the business; thus, small business loans are defined as business loans under $1 million; macro business loans are defined as loans between $100,000 and $1 million; and micro business loans are defined as loans under $100,000. Several variables from the Call Reports are used to analyze developments in the lending activities of these institutions. Because of the changing number of lending institutions required to file CRA reports, year-to-year changes in these institutions’ activities are more difficult to interpret than they are for the Call Reports.

Depository lenders with total domestic assets of more than $10 billion are ranked and reported separately, on the assumption that they serve a national market. Lenders are ranked by state based on the designated headquarters of the reporting lending institution. Two ranking methods are used depending upon the availability of data. For lending institutions for which information on total assets and total business loans are available (those filing Call Reports), four criteria are used as the basis for a lender’s performance ranking.

For the analysis of state lending based on CRA data, lenders were listed in order of the dollar amount of small business loans made in each state in 2010 in descending order, so large institutions appear at the top. Simple rankings were used for multi-billion-dollar lending institutions because only a small number of lenders are involved.

This report was peer-reviewed consistent with Advocacy’s data quality guidelines. More information on this process can be obtained by contacting the director of economic research by email at or by phone at (202) 205-6533.



Washington Days Conference: Business Development

May 14, 2012