[Federal Register Volume 67, Number 235 (Friday, December 6, 2002)]
[Proposed Rules]
[Pages 72622-72626]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 02-30905]


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SMALL BUSINESS ADMINISTRATION

13 CFR Part 120


Business Loan Program

AGENCY: Small Business Administration.

ACTION: Advanced notice of proposed rulemaking (ANPRM).

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SUMMARY: The U.S. Small Business Administration (SBA) is considering 
ways to improve coverage of the Certified Development Company (CDC) 
Loan Program (the ``CDC Program'' or the ``504 Program'') to ensure 
that all small businesses have access to long-term fixed-rate 
financing. After a review of public comments, SBA will consider 
proposing amendments to existing program regulations that will improve 
overall program management. SBA also anticipates that some changes 
suggested by commenters may ultimately require new legislation.
    SBA is revisiting the 504 Program policies as a prudent management 
exercise in light of major changes in the economy, the financial 
services industry, technology, and in CDCs' operations since the 
program's inception in 1980. The review has also been prompted by SBA's 
on-going discussions with the 504 industry and by specific requests 
made to SBA to expand CDCs' product base to include 7(a) loans or Small 
Business Investment Companies. In particular, SBA is seeking comments 
on the following: Whether the 504 Program is meeting its statutory 
purpose as defined in section 501(a) of the Small Business Investment 
Act; the appropriate long-term goals and annual performance measures 
for the program given its statutory requirement; the appropriate data 
elements required to assure solid program oversight while minimizing 
public data collection burdens; operational or regulatory impediments 
to providing long-term financing in rural or urban areas; and 
programmatic changes that could increase CDC competition and increase 
small businesses' access to loans.
    This ANPRM and request for comments are intended to stimulate 
dialogue on these and other issues pertaining to the CDC Program.

DATES: All interested parties are invited to submit written comments. 
Comments must be received on or before February 4, 2003.

ADDRESSES: Mail written comments to: James E. Rivera, Associate 
Administrator for Financial Assistance, U.S. Small Business 
Administration, 409 Third Street, SW., 8th Floor, Washington, DC 20416. 
Comments may be sent by e-mail to [email protected].

[[Page 72623]]


FOR FURTHER INFORMATION CONTACT: Gail H. Hepler, Chief, 504 Loan Policy 
Branch, U.S. Small Business Administration, 409 Third Street, SW., 8th 
Floor, Washington, DC 20416. Questions may be sent by e-mail to 
[email protected] or by telephone at (202) 205-7530. This is not a 
toll-free number.

SUPPLEMENTARY INFORMATION:

History and Purpose of the 504 Program

    During the late 1970s and early 1980s, the prime interest rate and 
unemployment reached historically high levels. It was generally 
believed that long-term, fixed-rate money was not available at a 
reasonable cost to small businesses because of these high prevailing 
rates and that this was hindering job creation.
    Congress enacted Section 503 of Title V of the Small Business 
Investment Act in 1980. The 504 Program was intended to provide fixed-
rate financing for small businesses at favorable terms unavailable in 
the marketplace. Congress specified in the Act that this program 
``foster economic development and create or preserve job opportunities 
in both urban and rural areas by providing long-term financing for 
small business concerns . . .''
    The statute authorizes SBA to guarantee debentures backing long-
term, fixed-asset loans (504 Loans) issued by Certified Development 
Companies (CDCs). It also authorizes SBA to pool the guarantees and 
sell interests in the pools to investors.
    SBA guarantees the debentures pursuant to terms and conditions set 
forth in SBA regulations. These regulations are found at 13 CFR Part 
120. Sections 120.800 through 120.991 are exclusive to the CDC Program. 
In support of the statutory mandate to create or preserve jobs, SBA 
currently requires each CDC to affirm that its 504 loan portfolio 
creates, on average, one job per $35,000 of CDC financing.

Certified Development Companies

    Since enactment of the 504 program, the CDC industry has been 
developed to meet the job creation and economic development goals of 
the program. Several hundred CDCs either were started in local 
communities or amended their existing operations to participate in the 
program. There are currently approximately 270 CDCs. Each CDC has a 
specific geographic area of operations. In general, CDCs have a 
membership comprised of financial institutions, community 
organizations, businesses, and government organizations responsible for 
economic development in the CDC's area of operations. Over the years, 
SBA has made changes to the CDC program to help ensure its vitality. 
For example, the original job opportunity objective was one job created 
or retained per $15,000 of guaranteed debenture investment. In 1990, 
SBA raised the job opportunity objective to one job per $35,000 of 
guaranteed debenture investment to reflect the inflationary factors of 
the previous 10 years. Congress also has amended the program 
legislation in a variety of ways including incorporating other economic 
development goals such as assisting businesses located in rural areas 
or veteran-owned businesses.
    The characteristics of individual CDCs vary significantly. Some are 
independent entities devoted primarily to making 504 Loans. Others are 
part of local or state governments. These organizations use the 504 
Program along with many other economic development programs such as HUD 
108 and EDA revolving loan funds. For these entities, the 504 Program 
is but one program in an array of economic development tools. Any cash 
flow over and above related 504 staff and overhead expenses is 
available to these CDCs to support other economic development 
activities such as establishing revolving loans funds or microloan 
programs. Most CDCs fall in between these two types of entities.
    The role of a CDC in the 504 Program loan process has expanded over 
the years. Initially, the CDC identified prospective small business 
borrowers and assisted with application processing and servicing. SBA 
made all credit decisions and approved, in advance, all servicing 
actions. The CDC did not have any financial stake in the loan other 
than the on-going servicing fee that it was paid by the borrower. As 
the program has evolved and SBA's personnel resources have diminished, 
CDCs, along with other types of lenders, have developed substantial SBA 
lending expertise and have assumed greater processing, closing, and 
servicing responsibilities. Some CDCs even liquidate defaulted loans. 
These responsibilities have increased the ability of CDCs to serve 
small business borrowers.
    Under the Premier Certified Lenders Program (PCLP) authorized by 
the Congress through Public Law 103-403, approved October 22, 1994, 
participating CDCs have increased authority to perform origination, 
servicing, and liquidation functions for their 504 Loans. By statute, 
all PCLP CDCs are required to deposit into a reserve fund one percent 
of the value of all PCLP loans that they fund. Cash from these reserve 
funds is then available to reimburse SBA for 10 percent of any loss 
incurred by SBA in connection with any individual PCLP loan. The 
reserve also creates a financial incentive for PCLP CDCs to originate 
high-quality loans and to service and liquidate their loans in a 
prudent manner. PCLP authority is limited to those CDCs that 
demonstrate on an on-going basis sound and effective loan processing, 
servicing, and liquidation practices.

Accomplishments

    As a result of the CDC Program, long-term, fixed-asset financing by 
SBA has grown dramatically since its inception. Almost 5,500 504 loans 
for an approximate total of $2.47 billion were approved in FY 2002. 
Over the life of the program, more than $15 billion has been funded. 
Combined with the required private sector financing this represents $42 
billion in funding for growing small businesses. This tremendous growth 
is largely attributable to the solid program structure, the hard work 
of the CDCs, and the ability of the program to provide financing 
appropriate for the economic times. Overall, more than 39,000 loans 
have been approved resulting in the creation or retention of over 
1,000,000 jobs since 1980.

Policy Considerations

    Since the CDC program was initially authorized, both the CDC 
industry and the economic environment in which it operates have changed 
significantly. As a result, it is vitally important that the SBA and 
those interested in the 504 Program work together to re-examine 
existing program policies and to consider new or revised policies to 
assure the program's continuing vitality and compliance with its 
statutory purpose, to foster economic development and create or 
preserve jobs.
    For example, a CDC that has managed to accumulate substantial cash 
reserves from its fee income has requested that SBA permit it to 
establish a subsidiary to make 7(a) Guaranty loans. This subsidiary 
would be initially financed by the CDC, managed by the CDC, and owned 
100 percent by the CDC to make 7(a) loans. Other CDCs wishing to expand 
or new CDCs that wish to establish themselves where existing, active 
CDCs operate are finding it increasingly difficult to meet the 
membership requirements and have asked for waivers of the membership 
requirements. While SBA may have the legal discretion to grant these 
requests, it is not clear whether or how these changes would serve the 
broader purpose of the statutory authorization. It

[[Page 72624]]

is in this context that SBA seeks public input on these and other 
issues.
    In addition, SBA continues to be concerned that a large proportion 
of the counties in the country are not receiving 504 financing even 
though there are active CDCs that include those counties in their areas 
of operations. For example, of the 67 counties in Alabama, 31 did not 
receive any 504 Loan approvals for the 24 month-period between November 
1, 1999 and October 31, 2001. During that same time period, 59 of the 
75 counties in Arkansas did not. Nationwide, more than 64 percent of 
the counties did not receive one 504 Loan approval per 100,000 
population per year averaged over a two-year period. Most of these 
counties are included in one or more CDC's area of operations. A large 
proportion of these counties have small populations.
    SBA needs additional information to determine the reasons why these 
areas are not receiving 504 financing. If there is a lack of demand for 
small business capital in general, or if there are other, more 
attractive, small business financing opportunities in these areas, a 
change that would permit additional CDC competition in these areas, 
such as a relaxation of the CDC membership requirements may not have 
any appreciable effect. Similarly, a new CDC loan product designed 
specifically for rural counties, such as a stand-alone debenture that 
does not require the participation of a first mortgage lender, might be 
warranted, but only if existing 504 loans do not meet the existing 
unmet demand for small business capital.
    Issues raised by the noted circumstances as well as those arising 
through the SBA/financial services industry dialogue are among those 
addressed by the questions posed to the public for comment in this 
advance notice of proposed rulemaking. Additional questions relate to 
issues raised in connection with regulations published on July 11, 2000 
(65 FR 42624) which permitted CDCs to apply to expand their areas of 
operations beyond their state of incorporation into a contiguous state 
beyond a local economic area.
    Financial markets change over time, and the Agency wants to insure 
that the CDC Program is flexible enough to meet the long-term, fixed-
asset needs of small businesses in all geographic locations.

Request for Comments

    While SBA has posed specific questions in this ANPRM, SBA seeks 
input from the public on the entire 504 program. The public, including 
the CDCs and small businesses, are welcome to provide comment on all 
aspects of the program, from its regulatory structure to the ability of 
the program to meet its statutory goals, and to suggest amendments to 
the program. SBA is also willing to consider changes that may require 
additional statutory authorization. SBA intends to pursue feasible 
suggestions that further the statutory purposes of the program.
    SBA would like feedback on whether the program is meeting its goals 
to bring economic development loan funds into local communities. The 
Agency also seeks to determine if there are unmet needs in business 
lending that the financial services industry is not serving. As the SBA 
is a ``gap lender,'' the Agency is interested in hearing from both SBA 
borrowers and individuals who may wish to use the 504 Program in the 
future.
    In addition, as part of SBA's review of the 504 program, SBA is 
evaluating its goals and performance measurements for the 504 Program, 
particularly in the context of the Government Performance and Results 
Act of 1993 (Pub. L. 103-62).
    SBA invites public comments on the following questions as well as 
any other topic related to the 504 program. Comments may be addressed 
to one, all, or any combination of the following questions. Questions 
are grouped under the following headings for ease of review by the 
public.

Questions About Overall 504 Program Effectiveness

    1. Does the problem which the 504 Program was created to remedy, 
lack of small business access to long-term fixed-rate capital, still 
exist? What evidence exists to demonstrate this need?
    2. Is the 504 Program optimally designed to address the problem?
    3. Is the 504 Program designed to make a unique contribution in 
addressing the problem (i.e., not needlessly redundant of any other 
Federal, state, local or private effort)? Are there financial products 
in the private market that can remedy this problem?
    4. Does the 504 Program collaborate and coordinate effectively with 
related programs that share a similar purpose?
    5. How would the 504 Program demonstrate adequate progress in 
meeting the statutory goals of the program?
    6. What long-term performance goals would be appropriate for the 
504 Program? Performance goals should be specific, ambitious, focused 
on outcomes, and meaningfully reflect the purpose of the program. In 
other words, how can we demonstrate the scale of the problem and show 
that the 504 Program is working to remedy the problem?
    7. What kind of evaluation would be most beneficial in measuring 
program effectiveness, both over the short term and the long term? Does 
the program currently gather the information necessary to make this 
evaluation?
    8. Does the performance of this program compare favorably to other 
programs with similar purposes, if any, and goals?

Questions to Current and Potential Small Business Borrowers

    9. Because 64% of all counties nationally did not receive any 504 
funding averaged over a 2-year period, are the CDCs meeting all of the 
public demand for capital in both rural and urban areas?
    10. Would ``special programs'' in rural areas attract the needed 
capital that does not currently exist in the market today?
    11. Is the process for receiving a 504 Loan reasonable compared to 
other business lending? Substantive comments/recommendations are 
encouraged to provide the broadest benefit to the Agency.
    12. Does the cost, time and requirements of receiving a 504 Loan 
make the program unattractive compared to the 7(a) program?
    13. Is the 504 Program fulfilling its mission to bring fixed-rate 
financing to small business? If not, what steps can be taken to further 
the mission of the program?
    14. Many of the stated uses for 504 funding are similar to requests 
for funding for 7(a) loans. Are the programs redundant, are there 
additional changes that are required to the 504 Program to fill the 
lending gap to small business borrowers?

CDC Organizational Structure

    15. Should the CDC membership requirements be changed? If so, how 
should they be changed and still meet the test that the membership 
represents the economic development interests of the CDC's area of 
operations? For example, should a CDC be permitted to only have 
financial institutions as members? Should there be fewer members than 
25?
    16. Should SBA permit for-profit CDCs again? If so,why? If not, why 
not? Should the existing, for-profit CDCs be required to become non-
profit CDCs and thus meet the regulations governing all other CDCs? If 
so, by what period of time?
    17. Should SBA establish requirements to assure that a CDC remains 
viable? For example, should

[[Page 72625]]

SBA establish a minimum cash reserve requirement? If so, at what level?
    18. What modifications to the regulations governing PCLP CDCs 
should be considered to increase participation by a larger number of 
CDCs?

Increasing Geographic Coverage by the 504 Program

    19. If a CDC has an existing area of operations in which it is not 
meeting the ``adequately served'' benchmark of one 504 Loan per 100,000 
population per year averaged over a 2-year period, should it be 
permitted to expand its area of operations? Should it be required to 
shrink its area of operations?
    20. Should this same CDC have to shrink its area of operations by 
those counties in which it has not made a 504 Loan? If so, when? What 
would be the period of time that would be reviewed?
    21. Even if a county is ``adequately served,'' should a new CDC or 
an existing CDC be permitted to apply to include that county in its 
area of operations if there is only one CDC currently including that 
county in its area of operations?
    22. Depending on when a statewide CDC was approved and depending on 
whether other CDCs have been decertified or have been converted to 
Associate Development Companies, a statewide CDC may or may not include 
the entire state in its area of operations. Should all statewide CDCs 
be permitted to include the entire state in their area of operations?
    23. Should the definition of ``adequately served'' change to 
something other than one 504 Loan per 100,000 population per year 
averaged over twenty-four months? If so, what would be a better 
benchmark?
    24. When the Section 503 Development Company Loan Program was 
authorized in 1980, its purpose was to provide financing through 
corporations ``formed by local citizens whose primary purpose is to 
improve their community's economy. They assist in the planned economic 
growth of the community by promoting and assisting the development of 
small business concerns in their area.'' (Legislative History, Pub. L. 
100-590, p. 22) Should SBA eliminate the requirement that a CDC have a 
specific area of operations? If so, how would the purpose of economic 
development be defined and monitored for each CDC?
    25. Would permitting applications for a multi-state CDC where the 
state is not contiguous to the CDC's state of incorporation provide 
greater access and a wider range of choices for borrowers?
    26. Should CDCs be required to adequately serve certain areas (e.g. 
rural areas, enterprise zones) as a prerequisite to serving other 
areas? If so, what would be the requirement for ``adequately served'' 
in this case?
    27. Should SBA relax its standard of two CDC loan approvals per 
year for those CDCs that operate in a rural area?
    28. How can SBA best assure that small businesses in rural areas, 
where lack of population density makes lending more difficult and more 
expensive, have appropriate access to the 504 Program?
    29. Should SBA promulgate regulations that recognize that 
operational difference between CDCs that, because of local government 
affiliation or support, are limited to serving specified areas, and 
those CDCs that do not have such constraints.
    30. In order to encourage a variety of thoughtful comments, the 
following are potential scenarios presented to encourage commenters to 
consider the ramifications of various approaches to ensuring equal 
access by all eligible borrowers, regardless of their geographic 
location. These are not meant to address every issue that may be 
relevant but are designed to illuminate the various approaches that 
could be applied to encourage complete coverage.
    Scenario 1: Make all CDCs statewide CDCs with no restrictions.
    Discussion: This would eliminate the need for SBA to determine if a 
county was considered adequately served. The number of CDCs would be 
controlled by local economic development professionals. If local 
economic development professionals considered an area to be adequately 
served, they would not propose the addition of more CDCs. This should 
also reduce the problem that some new CDCs now have with finding 
government representatives for the board of directors. There should be 
an adequate number of individuals available to serve on a CDC board 
when the geographic region is the whole state. The benefits to this 
approach are (1) a CDC would know that any county in a state would be 
open and (2) SBA staff would not have to process requests for expansion 
within a state. A potential downside is the possibility that CDCs may 
not adequately serve rural areas if access to the more populous areas 
is not restricted. Conversely, it is also possible that competition in 
the urban areas would encourage CDCs to do a better job seeking deals 
in rural areas.
    Scenario 2: Redefine ``adequately served'' to 1 loan for every 
10,000 in population. For rural counties, do not apply the prohibition 
for ``adequately served''. Allow any statewide CDC to market and do 
projects throughout the state and not just in the counties where there 
is no CDC as well as those counties where there is a local CDC and the 
statewide CDC was approved to overlap with the local CDC. Also the 
statewide CDC's loan activity would not be included in the ``adequately 
served'' calculation. This would permit local CDCs to expand into 
counties that the statewide CDC is also in. All existing CDCs would 
have 1 year to meet the new definition of ``adequately served''. After 
1 year, any county that was not adequately served would be available to 
other new or expanding CDCs.
    Discussion: The current definition of ``adequately served'' only 
requires that a CDC make 2 loans in a county over a two year period per 
100,000 population. By only requiring 2 loans in a 2-year period this 
standard has the effect of limiting access to the program in over 83% 
of all counties. Raising the standard has the benefit of continuity of 
process. The same procedures now used to determine if a county is 
adequately served could be used for new determinations. The 1 loan per 
10,000 population standard is slightly higher than what the portfolio 
averages now (30,000 loans divided into 282,000,000 Americans).
    Scenario 3: Determination of an appropriate level of coverage is 
based on a combination of total population and population density. This 
scenario is designed to encourage more access in areas capable of 
supporting multiple CDCs while providing shelter from ``cherry 
picking'' in rural, more difficult to serve areas. Areas that meet the 
following criteria will be considered sheltered exceptions:
    1. County population is less than 125,000; or
    2. County population is more than 125,000 but less than 500,000, 
and the population density of the county is less than the population 
density of the entire state. Neither of these criteria would apply in 
any state where the population density is greater than 600 per square 
mile.
    CDCs that serve a county (or portion of a county) meeting the 
sheltered criteria will have ``right of first refusal'' on a loan in 
that county. The CDC must act to the satisfaction of the borrower 
within 30 days or the borrower may opt to use the services of another 
CDC willing to consider the loan, even if that CDC does not serve the 
sheltered county. New CDCs can be approved in sheltered areas where 
there is no coverage, or where an existing CDC poses no objection. As 
an exception to policy, SBA may declare as sheltered, a portion of a 
county that does not meet

[[Page 72626]]

the criteria, if the geographic distance from a heavily populated 
portion of the county is sufficient to support a contention that the 
area should qualify as sheltered.
    For areas not meeting the sheltered criteria, any CDC who can 
service a loan would be allowed to make a loan. All existing CDCs would 
be grandfathered into their current areas of operations. New CDCs (and 
expansions of existing CDCs) could occur so long as they met the 
representation requirements.
    Any borrower in an area that does not have CDC coverage can be 
served by any CDC that has the capacity to service the loan. Generally, 
we should assume that anything less than 75 miles from the CDC's office 
is acceptable. In western states, the DD may make the call if there is 
a concern.
    Discussion: This approach assumes that CDCs serving rural areas 
should be provided some assistance in ensuring a sufficient level of 
504 activity to sustain their operations but does not penalize a 
potential borrower if the CDC cannot effectively handle the loan 
request. From an administrative standpoint, the ``adequately served'' 
decision is much easier, because it is based on population and 
population density statistics that can be made readily available to the 
public by putting U.S. Census data on SBA's Web site.

504 Loan and Debenture Structure

    31. Presently only 10 and 20-year fixed-rate debentures are 
offered. Would 504 Program economic development objectives be better 
served if SBA made changes to the terms of debentures offered?
    32. What would the costs and benefits to borrowers, CDCs, private 
sector lenders, and any other party be if SBA provided a debenture 
product that amortizes monthly rather than semi-annually?
    33. Are there benefits to allowing CDCs to jointly participate in a 
504 Loan project?
    34. Would a stand-alone debenture (no third-party lender 
requirement) for projects located in rural counties make 504 financing 
more attractive in these under-represented counties? If so, should 
there be a dollar limit on the project?

Performance Requirements

    35. SBA has developed a system that enables SBA and the CDC to 
track a CDC's 504 Loan portfolio performance as measured against SBA-
established benchmarks as well as the CDC's peer group. In order to 
insure the quality of the 504 Loan portfolio as well as the 
accessibility of the program that could be severely jeopardized if 
defaults increase and/or recoveries decrease, resulting in an increase 
in future borrowers' fees to maintain the program at its zero subsidy, 
should SBA establish 504 Loan portfolio performance requirements by CDC 
as a regulation? If so, since CDCs with large portfolios have a 
proportionately greater effect on the overall portfolio performance, 
but CDCs' with small portfolios are disproportionately affected by the 
failure of 1 loan, should there be a minimum portfolio size under which 
the regulation takes affect? If so, what should the size be?
    36. Should SBA require CDCs to have a financial stake in the 
performance of all of their 504 Loans, not just in the performance of 
any loan processed under PCLP authority? If so, what should be the 
requirement?

Operational/Logistical Issues

    37. What regulatory impediments are there to processing or closing 
504 Loans?
    38. If a 7(a) lender closes and disburses a loan that SBA 
subsequently determines to be ineligible, SBA can deny liability under 
its regulations. If a CDC closes and disburses a 504 Loan that SBA 
subsequently determines to be ineligible, what financial or other 
penalty should be imposed on the CDC?

Definition of Economic Development

    39. Current regulations require a CDC to provide evidence to SBA 
that it has created at least one job per $35,000 of 504 debentures that 
it has issued. At the two-year anniversary of the small business's 
receipt of the loan proceeds, the CDC is required to document how many 
jobs were actually created. Should SBA require CDCs to provide evidence 
of other economic development in their Areas of Operations in addition 
to creating jobs? If so, what other evidence of economic development 
should be required, and what quantitative measures should be used?
    40. Should SBA develop a list of acceptable ``economic development 
activities'' in which SBA permits a CDC to invest its resources? If 
yes, what activities should be included? What activities should be 
excluded?

Participation in Other Programs

    41. Should SBA permit a CDC to contribute to the financial support 
of a 7(a) lender? Is this economic development as intended by Congress 
when it created the development company loan program?
    42. Should SBA permit a CDC to establish an affiliate relationship 
with a 7(a) lender through a management contract? Are there any 
benefits or drawbacks for borrowers?
    43. Should SBA permit a CDC to establish or acquire a 7(a) lender 
subsidiary? Is this economic development as intended by Congress? What 
are the benefits and drawbacks for borrowers?
    44. SBA's regulations prohibit a financial institution, among 
others, from controlling a CDC. (Sec.  120.824) Should SBA permit a 
7(a) lender to establish a CDC affiliate or subsidiary controlled by 
the 7(a) lender?
    45. Should SBA permit a CDC to financially contribute to an SBIC? 
If so, under what limitations?
    46. Should SBA permit a CDC to establish an affiliate relationship 
with an SBIC through a management contract?
    47. Should SBA permit a CDC to establish an SBIC subsidiary? If so, 
under what limitations?
    48. Should SBA permit a separate corporation to have control 
through common management of the corporation, a CDC, and other 
corporations such as a 7(a) lender, an SBIC and so on? If so, under 
what limitations?
    Comments on any other aspect of the CDC Program are also welcome. 
SBA reminds commenters that all submissions by commenters are available 
to the public upon request.

    Dated: December 2, 2002.
Hector V. Barreto,
Administrator.
[FR Doc. 02-30905 Filed 12-5-02; 8:45 am]
BILLING CODE 8025-01-P