Docket ID: SBA-2022-0010
The comment was received on: 2024-02-02T05:00:00Z
Original comment on regulations.gov
As currently drafted, Reinvestor SBICs must file annual and interim (quarterly) Form 468s within 120 calendar days of the close of the calendar quarter. It is important to note that a fund-of-funds LPA will typically provide for between 90-120 days to produce its quarterly reporting for unaudited periods (i.e., Q1-Q3) and then will have 180 days (or more) to produce audited ficial statements (i.e., Q4). With only 120 days for a Reinvestor SBIC to produce Forms 468, such Reinvestors will either be in non-compliance nearly every single quarter of their term, and/or be required to report ficial statements and capital accounts with insufficient information and larger estimates than the industry standard. Reinvestor SBICs should have additional time for reporting Forms 468 than currently allotted, with probably 120 days from interim quarter end and 180 days-240 days from annual year-end. Such reporting timelines would reflect the fund-of-funds industry standards and not disadvantage a Reinvestor SBIC for partnering with SBA.