Thread by @trevorloy, 1/ THREAD: Summary of @HouseSmallBiz cmte "virtual forum" earlier today on SBA [...]

1/ THREAD: Summary of @HouseSmallBiz cmte "virtual forum" earlier today on SBA #PPP lending.

These are my notes. See linked tweet below for URL of youtube archive to watch full hearing (stream starts at 6:45 min in). https://twitter.com/trevorloy/status/1260655391492370433

https://twitter.com/trevorloy/status/1260655391492370433

2/ Chair = @RepAndyKimNJ (NJ-03)

Opening remarks:
* CARES signed 3/27, creating PPP w/in existing SBA 7(a) prog, allocated ~$350B
* Goal = save as many SMB jobs as possible, as quickly as possible
* Thru May 8, NJ biz received ~124K loans, ~$18B, saving '000's of jobs in NJ

3/ Given size, scope & speed, implementation was "bound to be less than perfect". We appreciate hard work of everyone at SBA. Equally grateful to lending partners.

That said, now tasked with improving areas of program exposed during round 1...

4/For example, round 1 issues incl:
* Many "mom & pop" biz forced to sidelines while larger/better capitalized biz got loans
* Left with nothing but hope more $ would be allocated
* Congress added add'l $310B on 4/24, incl $60B set-aside for access by those underserved in rd 1

5/Round 2 PPP $ draw down not as fast as some expected, in part b/c of lack of clear guidance on forgiveness rules.

This hearing = find out what's worked, what hasn't & how Congress can further optimize PPP, + if Congress shld look outside PPP for add'l capital access solns.

6/Opening remarks by Ranking Member @repkevinhern (OK-01):

I'm a small biz for last 35 yrs, incl bank boards, McDonald's natl leadership, & others.

Have been connected to 100's of small biz people on recent calls.

When small biz & empls aren't at work, economy suffers.

7/Fighting back at fed level. POTUS signed CARES a little over 1 mo ago, creating PPP program of forgiveable small biz loans.

SBA & Treasury charged with setting up program at light speed. Timeline shortened from months to days. SBA did approx 15-20 yrs of work in 5-6 wks.

8/Unbelievable task; should give credit for speed & accuracy in short time.

Focus shifted to private lenders. Lenders met the challenge. Shld acknowledge their time & energy.

9/However, have been roadblocks & turbulence. SBA & Treas published late guidance on rolling basis & published rules changed halfway thru process. This caused great confusion for both lenders & SMBs. Even today, SBA & Treasury *still* have not published forgiveness guidance.

10/Complete & comprehensive rules = instrumental for SMBs to make decisions. Guidance just 1 of many items to be discussed today, along w/improvements Congress can make to PPP. Also want to learn what else Congress can do as have rolling re-opening of economy across USA.

11/ @repkevinhern will be sending letter to SBa/Treas asking for SMBs to be able to repay any unused/unforgiveable PPP $ sooner so can be recycled to other SMBs that haven't gotten PPP $.

12/ @RepAndyKimNJ acknowledges benefit of @repkevinhern's SMB experience & bipartisan nature of committee's work to help SMB, more important than ever.

Each panelist will have 5 min for statements, then each cmte member will have 5 min for statements+Q&A.

13/Panelists:
* Tony Wilkinson, Pres & CEO, Natl Assn of Govt Guaranteed Lenders (NAGGL) @naggl7a

* Dafina Williams, VP Public Policy, Opportunity Finance Network (OFN) @OppFinance

(continued...)

14/[Panelists continued]

* Brett Palmer, President, Small Business Investor Alliance (SBIA) @SmallBusinessPE

* Jay Hannah, VP Financial Services, BancFirst @BancFirstOK

15/Opening statement by Tony Wilkinson of @naggl7a:

* SBA lenders have stepped up. Over 4.3M PPP loans worth >$533B so far.

* Despite performance, have been major failures, such as...

16/PPP failures:

*Lack of clear implementation guidance. On same day as launch, SBA IG issued white paper emphasizing importance of clear guidance. SBA & Treasury did not heed that warning.

(cont...)

17/SBA & Treasury have issued 9 IFR's & 46 FAQs on a rolling basis, and more still to come. This is not an appropriate way to run govt program with 100's of Billions of $.

18/ SBA & Treasury still haven't provided forgiveness guidance. Lenders & borrowers still uncertain, even tho borrowers have deadline tmrw to decide if cancel or repay PPP. This guidance also violates CARES act - has been 46 days despite CARES req'mt of 30 days.

19/ Second criticism=overly small % of loans >$2M. When CARES setup PPP with max $10M loan (2x normal 7(a) max), it was clear that intent was to include & support larger businesses with more employees. CARES explicitly incl'd more orgs than usual in "small biz" definition.

20/CARES explicitly elim reqm't of "can't get credit elsewhere". Only req'd borrower to certify *uncertainty* makes loan "necessary," but no def of "necessary" provided. Borrowers legit / good faith believed they qualified, right up until media hype led Treasury to issue FAQ 31.

21/FAQ31 imposed new tests. Req'd borrowers to consider current biz activity + ability to access other liquidity. Basically re-imposed "no credit elsewhere" test that CARES expicitly excluded.

22/News headlines focused on larger loans, but <0.8% of # loans are for >$2M. Vast majority <$50K.

Borrowers should not be shamed/threatened for doing what law invited.

23/Final criticism - still need fixes that lenders have been pleading for. Many technical fixes, and one serious error that combined PPP & "regular" 7(a) authorization cap. As written, if cap reached by June 30, "regular" 7(a) program will shut down. Need to reinstate reg 7(a).

24/PPP as implemented has setup lenders to fail. Despite this, lenders have risen to challenge & helping millions of SMBs.

25/Opening statement, Dafina Williams, SVP, Opportunity Finance Network @OppFinance

OFN= network of 300 CDFI's. Focus on lending & investing in low-inc & underserved communities.

We reach where other lenders do not. 85% low-income; 58% PoC; 48% women; 26% rural.

26/Started to hear from OFN lenders in mid-March that borrowers seeing a lot of economic stress.

Common challenges: smaller revenue size, limited relationships w/traditional finance, reliance on family & credit cards.

27/CDFIs responded by modifying loan terms, proposing flexible repaymt terms, doing "whatever it takes."

CDFIs excited to participate in PPP, but got off to rough start. Round 1 failed to address small, women, & minority-owned SMBs, b/c many lacked existing bank relationships.

28/CDFI path to becoming SBA lender for non-depository loan funds had high barrier to entry, esp if not already part of 7(a) or community advantage pilot program. PPP regs did not encourage CDFIs. $50M annual loan threshold = too high. Also locked out of Fed PPP facility.

29/SBA to be applauded for standing up program in such short amt of time, but have been challenges in communications from SBA & Treasury. Numerous rule changes, delayed guidance, confusion for both lenders & borrowers = lost critical time to help SMBs.

30/Still, CDFIs have made big impact. 302 CDFIs have made >50K loans ~$2.8B.

Survey of 35 OFN members: >$1.1B PPP loans in 6 weeks, despite all issues. Loan sizes $11k to $160K. Avg $53k loan & 7 empls.

Support for non-profits, food services, barberships, hair salons.

31/Could have been bigger if CDFIs had on-ramp as lenders - esp since already ptr w/fed govt in mult progs to reach underserved communities.

Round 2 much better, incl specific $30B carve-out for CDFIs & small lenders. Not just $; also signaled taking seriously underserved.

32/Our borrwers needed tech help w/ apps. Don't have lawyers, acctg. Also had trouble getting access to eTran amidst traffic. Special window for CDFIs/small lenders was helpful.

Also pleased by updated rules dropping min threshold from $50M to $10M for non-depository lenders.

33/Fed also finally opened to non-depository PPP lenders, which will help w/liquidity.

OFN rec's for add'l improvement:
1. Set-aside for CDFIs, MDIs, microlenders
2. Set-aside for very small biz + non-profits
3. Greater clarity on loan forgiveness
4. Longer time than 8 wks

34/[OFN rec's continued]

5. Flexibilty from 75/25% rules
6. Better/more complete data on borrower demographics

Also need add'l help beyond PPP for longer-term...

35/CDFIs will need add'l capital to meet borrower needs. Non-profit loan funds need equity capital for longer-term recovery. Most imp source = earned revenue + grants from @USTreasury CDFI fund. Requesting $1B appropriation, which is included in HEROES draft.

36/Opening statement: Brett Palmer, Pres, Small Business Investor Alliance ( @SmallBusinessPE).

Rural IC's, SBICs, small VC funds, growth funds across country. both commonly-served & underserved.

Need more collaborative, bipartisan, practical solutions to support SMBs.

37/Will discuss PPP problems, but first note successes. 10's of millions have jobs + health insurance who otherwise wouldn't. Many SMBs will survive who otherwise wouldn't. Enables reinvigoration of economy once covid crisis is over.

38/2 biggest PPP problems:
1. Demand outstripped supply...sign that SMBs agree that lifeline was/is needed.

2. Agree with problems already ID'd by Tony.

This is not a bailout like prior econ crises; this is a SMB survival mission more like evacuation of Dunkirk.

39/PPP as written in CARES works. However, can still snatch defeat from jaws of victory:
* lack of regulatory clarity
* SMBs scared away from accessing PPP, esp from undefined/unclear "liquidity elsewhere" test that is nowhere in the statute. Needs to be addressed immediately.

40/Many SMBs took PPP to use $ to keep people employed, but got scared & gave money back & chose layoffs instead. Others kept empls, paid payroll, then gave money back w/o layoffs, so now in worse position than were before.

Also: forgiveness rules = long overdue.

41/Many SMBs took PPP but can't afford more long-term debt, so need forgiveness, but unclear what allowed to use $ for. Now frozen. We need to unfreeze economy & these SMBs.

42/Worth considering:
At start of PPP didn't know severity of crisis. Many weeks later, now know more. Many PPP borrowers can give some PPP $ back - don't need all. Suggest ability to repay portion, not all-or-nothing. Then can recycle to other borrowers.

43/ Pls keep operating nonpartisan, practical solns, make PPP work, AND start looking NOW at longer-term infrastructure & tools needed 3-6-9 months from now. Need to fully fund SBA, hire quality empls, improve SBA IT infrastructure, provide tools to SMBs, more equity capital.

44/Coming out of crisis, SMBs will need more patient capital. Will be overloaded w/debt, unbankable, need to rebuild workforce, not sure about accts receivable, biz & personal credit in shambles. Many will heal & grow w/patient capital, i.e. equity/equity-like capital.

45/Opening statement of Jay Hannah, EVP, BancFirst Oklahoma @BancFirstOK

BancFirst=FDIC community bank. $8.6B assets, 100% in OK. 200K cust incl 40K businesses. 65% in non-metropolitan markets beyond Tulsa/OKC. 89% <20 empls. Preferred 7(a) lender, highest in OK for 27 yrs.

46/In round 1, processed 7k loans, $829M, avg size $150k. Equals 20% of all PPP loans in OK.

Round 2: 2,700 loans, $85M. Avg size <$32k.

47/PPP mandate for rapid deployment req'd expediency.

Governed at first by IFR issued 4/3, same day as launch. Very general guidance. Safe harbor to rely on cust certifications.

Add'l refinements in 9 IFRs & 12 FAQs = mostly after the fact. Sone clarity, more confusion.

48/Customers esp confused about eligibility & forebearance. Led to delays in applications & funding. Reliance on SBA standard operating procedures was difficult.

Cumulative impact of IFRs/FAQs diminshed lender confidence in reliance on initial IFR safe harbors.

49/Some cust say 8 wk measurement will make forgiveness impossible, esp b/c city & state regs requiring closure + reticence of customers to return. Residual loan balances owed by borrowers will far exceed original intentions of PPP authors.

50/Reasonable to expect SMB failures will exceed historical rates.Need to deal w/inability to repay.Will create litigation costs/headaches.We encourage SBA to incr confidence in guaranty; add flex use of PPP proceeds; extend 8 wks; extend 2 yr term for unforgiven PPP balance.

51/Start of Q&A. First up = Chair, @RepAndyKimNJ.

For T. Wilkinson: More detail abt lack of forgiveness clarity. What are specific problems SMBS facing? What rec's for Congress to address?

52/Ans: We hear SMBs are fearful. Don't know forgiveness process/rules. Even smallest are returning loans b/c of fear, not b/c ineligible.

Also, emphasize: many directing criticism at SBA, but this program is being directly managed by @USTreasury. They call all the shots.

53/Need final guidance soon. Already past req'd statute date. As of now, still not issued.

@RepAndyKimNJ: I'm hearing this as 1st thing out of mouth of every SMB owner I talk to.

54/ @RepAndyKimNJ Q for D. Williams: How are set-asides impactful to reach underserved borrowers?

A: Set-aside was key for time. B/c round 1 demand, really hard for CDFIs to spend time to help borrowers develop applications & also actually get into system/approved.

55/Set-aside was key b/c knew CDFIs would have resources available.

However, CDFI set-aside also incl other credit unions & small lenders, so still competing with others.

56/ @RepAndyKimNJ Q to D. Williams: What abt proposals for set-asides based on size of borrower?

A: I think that would be helpful. We know we serve those smallest biz w/<10 empls. Another way to get $ to those biz. Or do set-aside just for CDFIs/MDIs who serve those borrowers.

57/Ranking Mbr @repkevinhern Q for J. Hannah: From lender perspective, how have OK SMBs reacted to fed govt response to crisis?

A: Response viewed as good. We had over 8K applications for PPP at start. Processed >$915M loans. Key dilemmas = mechanical. SBA eTran issues.

58/In avg year, we do 115 SBA loans for $45M. We have pushed thru $900M+ thru system with 5 licenses for SBA eTran. Very painful. Was very manual - no automation using APIs or flat files. We worked 24 hr shifts, 7 days/wk. Unending pace.

59/ @repkevinhern Q for B. Palmer: What improvements for Congress as we debate future of PPP?

A: Part of story = success of community banks. Extraordinary job. Some big banks too, but community banks/regional banks critical. Important to support them.

Other things:

60/1. Important that borrowers know that once they get PPP $, they can use it. Need clarity of guidance.

2. Need clarity on meaning of "liquidity elsewhere" test. Terrifies people. Afraid to even tell anyone their story b/c worried will have to layoff instead of use PPP $.

61/ 3. Affiliation rules also a problem. Biz that actually *have* SBIC $ able to access PPP $. Instead should broaden to make eligible any business that would *qualify* for SBIC $, whether or not it actually has taken such capital already.

62/ 4. Borrowers now know more about what they need/don't need. At beginning was harder to know. Should make it possible to refund partial loans, rightsize & recycle $ to other borrowers.

63/ @repkevinhern : seems like it would also be helpful to extend 8 week period, extend working capital usage beyond 75/25 rule, extend runway beyond june 30, etc.

B. Palmer: Absolutely. Lots of seasonal biz, also, have issue w/8 weeks. Letting them more flexible = helpful.

64/ @RepGolden (ME) Q for T. Wilkinson: Concerns about 7(a) being limited by combined cap w/PPP. In HEROES draft, I believe there is language to separate caps. Have you seen/can confirm would address your concerns?

65/T. Wilkinson answer: A: Yes, have seen; yes it is the intent; have some concerns about precise language & have sent in our comments. We are hopeful to bifurcate PPP & regular 7(a) programs & ensure no risk of stopping regular program if PPP reaches cap.

66/ @RepGolden Q for T. Wilkinson: Concerns from lenders abt what will happen later in year, prolonged recession. Once temp assistance runs out (e.g. SBA deferrals, 6 month payments), concern abt what happens next. What are your thoughts?

67/ T. Wilkinson Ans: Agreed all you mentioned. Specifically pleased about section 11-12. Big benefit for 7a and 504 borrowers. Conventional credit box is closing if not already. Will be difficult to access credit. We view 7a, 504, SBIC will be front & center again.

68/We are hopeful Congress will consider items incl in Recovery Act: higher guarantee %s, fee waivers etc. These items are in draft of HEROES.

69/ @RepGolden : As we are waiting to hear forgiveness clarity - do u think it makes sense for us to formalize tiered approach to PPP documentation & auditing based on size of loan?

70/B. Palmer A: You will have to prioritize - cant go thru all 4.3m loans. Bigger loans first. More important is clarity on *what* will be audited - what documentation needed, what type of injury, how they used $ - doesn't matter as much who/how they audit.

71/B.Palmer cont: On prev Q, make sure loan forgiveness is not taxable. Not just PPP but any other loan forgiveness, shoudl modify tax code to avoid that becoming taxable income.

72/ @RepChabotCMUNC Q for B Palmer: SBIC biz have elig in PPP. How have they navigated? Signs of success? What modifications?

B Palmer: SBIC-backed biz = hi growth. Seed corn for recovery. Ability to access PPP = very helpful for those in need. Not all need & haven't taken.

73/B Palmer cont: Saving lots of jobs. If allowed, shld allow PPP access for businesses that would be eligible for SBIC investment (rgrdless of if already have one), but inelig b/c of affiliation rules. Lots of hi growth co's need PPP whether SBICs invested or not.

74/ @RepChabotCMUNC Q for T. Wilkinson: From lender POV, what guidance still prefer to have clarified?

T. Wilkinson: Wld have loved guidance on day 1. Typically get program guide.Could have been done while CARES being negotiated. Example templates. Blanket authorization T&C's.

75/T. Wilkinson cont: Instead, managed by rolling FAQs, updated nightly, sometimes multiple times a day. In fact new FAQ just this morning. Very difficult way to manage loan program. Never know what rules are, what is coming next?

76/D. Williams: For CDFIs, confusion from beginning. Didn't understand if even eligible. Long timeline to guidlines on qualifications. Now concerns have shifted to borrowers for forgiveness, etc. Echo it's been a moving target; scrambling to respond to changes 8-9pm at night.

77/ @RepChabotCMUNC Q for J. Hannah: Are you prepared to help borrowers thru forgiveness process?

J. Hannah: Yes, view as responsibility under PPP. Imperative that we have clarity to describe to our cust. Mechanically, need reqmt's for submission to SBA. eTran limits = problem.

78/J. Hannah continued: If forgiveness takes on a burdensome approach like before (24 hr shifts), will be problem. We need clarity but also simplicity.

79/ @RepDavids Q for D. Williams abt lack of clear guidance - in beginning and now around forgiveness. Add'l comments? Also, for all, what has it been like to try to give feedback to SBA or Treasury? Need govt people able / willing to listen.

80/D. Williams answer: Borrowers are SCARED. Afraid will be on hook when thought it would be forgiveable. Already distressed. Smaller, less revenue, no access to other capital.Another layer of debt- even tho terms favorable (1% over 2 yrs)- worried they'll not be able to repay.

81/OFN has been sending letters/feedback to SBA & Treasury all the time. Sometimes a brick wall; other occasionas with Dep Asst Sec Treasury receptive. But takes too long to get answers. Waiting 2-3 wks is unacceptable.

82/ B. Palmer: Can't emphasize enough the FEAR. Not just about forgiveness, but also, being threatened with jail - that these are crimes if there was credit available elsewhere. Burying yourself in debt + criminal liability just to pay empls while no rev- not many people will do.

83/ B. Palmer cont: This is a program DESIGNED to subsidize non-economic behavior of keeping people employed that are low & moderate wage employees. Difficult to get people that are scared to hold on and use the money....

84/ B. Palmer cont: ...I get LA Lakers was obscene/indefensible, & reaction was also great politics. Overreaction. Need to have a unified voice between Treas & SBA that SMBs are *OK* to use $ for stated statutory purposes.

85/ T. Wilkinson: Avenues/channels of retail have evolved; we have seen here in OK both those that are fearful re: eligibility and those worried if adequate forgiveness. We have had 80 co's return $31M. These are SMBs not public co's.

86/ We have at all times been able to reach SBA district director, but she had as much info as we did. Very receptive, but lack of answers/clarity even after $ already out was simply not there.

87/ @RepAmata: [Long preamble abt PPP & status/impact in American Samoa; sorry I'm getting fatigued capturing every detail]

Q for all: What are diffs in rd 1 vs 2 for PPP re: underserved communities? Is level of loan demand being met for smaller/rural? What future ipmrovements?

88/T. Wilkinson: First, look at loan $ spread. Rd 1, 74% under $150k. No other data/breakout. In rd 2, loans under $150k = 91%; 73% of loans under $50k. Don't think smaller were excluded in rd 1, but set aside & special window in rd 2 helped.

89/T. Wilkinson cont: Improvements: Flexibility around 75/25 rule. was not in CARES Act as passed. One size fits all doesn't work; many SMBs can't make it thru crisis if have to pay >75% on payroll while closed.

90/D. Williams: Agree. Rd 2 def an improvement for smaller biz. Set aside helped - allowed for more time for smaller lenders not familiar with eTran. Time window for small lenders also helpful. Flex on 75/25 is key going forward.

91/ @RepJudyChu: Glad $60B set aside was improved; I think HEROES will improve more by:
* extending 8 wks to 24
* deadline from June 30 to Dec 31
* remove 75/25 rule
SBA finally provided official translations of guidance this week - 17 languages. Loan apps not yet translated.

92/ @RepJudyChu Q for D Williams: SBA IG found no guid to lenders from SBA abt demographics as was req'd in CARES. What are consequences?

D. Williams: Lack of guidance + demographic data = can't properly assess program. Have to patch together data for biz owned by PoC, etc.

93/ D. Williams cont: We collect our own data so we can understand our own borrowers, but can't assess impact of program systemwide.

@RepJudyChu: HEROEs requires this data.

94/ @RepJudyChu Q for T Wilkinson: Countless inquiries about update on PPP status. CARES requires 10 day disbursement. Many reports of delays. How long are your typical clients waiting? How do you update clients on status?

95/T Wilkinson: Couple answers. 1st, sheer magnitude of loan volume not seen before. 2nd, 10 day req'mt not put in place until well after program started. Many customers in long line to apply in rd 1, so need for speed & as many borrowers as possible. After rd 1, 10 day rule.

96/Now, lender has 10 days to get docs to borrower & another 10 days for borrower to sign, so 20 days max.

Now lenders have shifted HR resources to closing & funding. Most can now comply with 10 days.

97/ @RepPeteStauber: [Preamble abt import of SMBs & lenders in gen & in Minnesota = highest per capita volume without much guidance from SBA]

Q abt PPP origination fees: Some concerned about timing of fees. Also flexibility req'd of PPP for seasonal emplyrs. Lots in northern MN.

98/B Palmer: SBA has done excellent job in difficult situation, but require statuatory changes for seasonal emplyrs. Every SMB is diff, so max flexibility for use of PPP $ is helpful.

99/J. Hannah: Re: fees, we collect fees thru core processing system. Longtime system / interface w/SBA. Submitted our report as req'd in traditional SBA rules. 800 page report. Heard later that traditional 1502 report may not be accepted. Burning time on IT system issues.

100/ @RepPeteStauber : AGree, we need max flexibility and also redundant rules & regulations in lenders when overlap with SBA. Should push SBA as committee to ask them + PPP recipients to make access to capital easier.

101/ @RepSchneider : [Preamble misc. thank-yous] PPP not working for everyone. Many problems. HEROES has improvements. SBA implemt of CARES has not worked for 8 wk framework, esp rest & hospitality. Need to incl all non-profits. [Additional misc thank yous].

102/ @RepSchneider cont: I was on call 3 wks ago with SBA Admin Carranza who promised forgivness guidance "in short order" and "that week". Now 3 wks passed. 9 IFRs & 12 updates to FAQs. Creating confusion. Worst possible time. Need clarity.

103/ @RepSchneider Q for J. Hannah: Will be stutters out of gate, but what do we do now to fix glitches & make easy to provide assistance?

J. Hannah: Over and over again - clarity of rules. 9 IFRs, 11/12 FAQ updates, like peeling an onion. Add clarity + confusion at same time.

104/J. Hannah: 8 weeks was good projection at start, but pandemic reality & consumer activity hasn't cooperated. Extension of time & flexibility is necessary. Esp for small community banks. In OK, 200 financial inst. Half have <$100M assets. They were not active SBA prev.

105/J. Hannah cont: We are highest producing SBA lender in OK for 27 years, and we only have staff of 11 people. I've conscripted over 70 people in 24 hr shifts to meet demand. I can only imagine what smaller institutions have had to go thru.

106/J. Hannah: Clarity, accessibiility, simplicity.

@RepSchneider As a small biz person myself, I point out those are things you also need in normal times, not just pandemics.

107/ @repkevinhern closing comments. [Thank you's]. Great committee right now, very bipartisan approach. About helping biz to keep people in jobs & return to economic health. PPP has faults, easy to Monday-am quarterback. Seeking solns & answers to make better.

108/ @repandykimnj closing comments. [Echos thanks to panelists & colleagues]. When talk to SMBs that survived 2008 crisis, or Hurricane Sandy, they talk abt small biz= 1st to get hit & last to recover. in some ways even worse now. 1st to get hit, yet to be seen IF can recover.

109/[add'l comments about importance of SMBs]

Conclusion.

[END OF THREAD]

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