We are attempting to deal with the new requirement (effective 7/1/99)
at this point that any SDB's we report on SFR294 and SFR295 be
certified by the SBA.  In so doing, we are running into multiple
issues and wonder how other institutions are dealing with this.

Specifically, how are you identifying the smalls, women-owned
and SDB's?

Also, how are your vendor databases maintained with regard to coding
the smalls, women-owned and SDB's?

The new guidelines will "grandfather" in existing plans--that is
we will be able to count currently self-certified vendors to meet
the goals of those existing plans.  How will you maintain your data
on self-certified smalls, etc, while adding in the newly indentified
SBA-certified SDB's that will be required for plans after 7/1/99?

 The new version of the 294 and 295 have a new category called
HUBZONE, which apparently is not completely defined yet.  How are you
planning to implement this?

How do you report on subcontracting plans that have lower-tier
subcontracts--do you incorporate their reports with yours, send a
copy of their report along with yours, or do they report directly?

SBA-certified  SDB's will be on Pro-Net with multifple SIC codes.  We
are being asked to report on the 2-digit major group for each
SDB vendor that we have used to meet the goal.  How are you
classifying these when there are multiple SIC codes listed on
Pro-Net?

Thank you for any input you may have.

 ============================================================================