Friday Flash 12/09/22

Join Us for a Holiday Party at the Tower Club, December 15

The holiday season provides an opportunity to take a break from our usual routines to appreciate human connection and surround ourselves with the things that bring us joy. As we enter the holidays and approach the end of another year, we are given an opportunity to reflect on and celebrate our accomplishments with family, friends, and colleagues.

As we reflect on another successful year at the Coalition, we cannot overstate the importance our members have in helping us grow towards our goal of creating an effective federal procurement system that delivers common sense acquisition. To this end, the Coalition would like to show our appreciation by inviting you to commemorate a wonderful 2022 at a one-of-a-kind festive event– Off the Shelf: Exclusive and In-Person! This special event will take place December 15 at the Tower Club in Tysons Corner, VA from 4 – 7 pm. We hope that you can join us for a memorable night of networking, relaxing, and plenty of good food and drinks with your friends and industry peers.

As the title indicates, not only is this holiday event a great opportunity to enjoy each other’s company one more time before we break to connect with friends and family, but it also features a special exclusive and in-person episode of the Off the Shelf podcast. Off the Shelf covers the latest federal acquisition topics across a wide range of sectors, with distinguished guest speakers from both government agencies and industry. Joining Off the Shelf live on December 15 will be Bill Gormley, President of the Gormley Group, Brian Friel, Co-Founder of BD Squared, and Tim Cook, Executive Director of the Center for Procurement Advocacy. They will lead an insightful and thought-provoking discussion on the state of governmentwide contracting, key legislative developments affecting procurement policy, and what federal contractors can expect in 2023. This event provides an excellent opportunity to have your procurement-related questions and concerns addressed by a panel of recognized industry experts!

We encourage all our members to stop by to celebrate our accomplishments in 2022 and toast to the New Year. Registration for Off the Shelf: Exclusive and In-Person! is complimentary to all members, and can be found here. The Coalition wishes you and your loved ones a fantastic holiday season, and we look forward to seeing you next week!

Senate and House Armed Services Committee Release Compromise NDAA

The Hill reports that the fiscal year 2023 National Defense Authorization Act (NDAA) has passed the House in a 350-80 vote. Earlier this week, the House and Senate Armed Services Committees released the compromise version of the bill, which appropriates $857.9 billion to national defense.

This marks an increase of $45 billion over the President’s initial budget request this spring and is greater than the requests made in both the House ($839 billion) and Senate ($847 billion) versions. Among the bill’s provisions are a 4.6 percent pay raise for military services members and the Department of Defense (DoD) workforce; $800 million for security assistance to Ukraine ($500 million more than the Biden administration requested); and authorizations for additional munitions, aircraft and vehicles, including five F-35A fighters, 15 Arleigh Burke-class destroyers, and the Columbia-class submarine program.

On the policy side, the bill sets manpower levels for the armed services, requires the creation of a joint force headquarters for the U.S. Indo-Pacific Command in that region, and ends the COVID-19 vaccine mandate for service members. The final provision was a key concession to move the bill forward, although the White House has stated its opposition to the change.

Despite bipartisan confidence that the NDAA is on track to pass before the end of the year, funds must still be appropriated through the omnibus spending bill before the Pentagon will be allowed to use the money. House and Senate Democrats have indicated that they wish to pass the omnibus before the end of the year, which would fund the government through 2023 and replace the short-term continuing resolution that the government is operating on through December 16. It is not clear, however, that that will happen, and Senate Minority Leader Mitch McConnell (R-KY) expressed to reporters on Tuesday that it is “increasingly likely” that another short-term continuing resolution would be necessary.

As with all NDAAs, the bill will bring or codify numerous changes to procurement, with the bill’s acquisition policy section carrying eighty-four separate sections. Perhaps the most consequential provision for contractors, however, is Section 5949. The provision resembles the Section 889 provision of the 2019 NDAA that barred certain telecommunications and video surveillance products from use by Federal contractors and the government in order to address cybersecurity concerns. 5949 prohibits the Federal government from purchasing semiconductor products from several manufacturers with close ties to the government of the People’s Republic of China after 2027. It also bars the government from doing business with contractors who use these products within their critical systems after that date.

Unlike Section 889, however, 5949 will not require contractors to remove prohibited equipment installed before the law takes effect. Contractors will also be allowed to use prohibited semiconductors in non-critical business systems, such as those used for payroll or finance. The original version of 5949, submitted by Senate Majority Leader Chuck Schumer (D-NY), would have simply extended Section 889 to cover semiconductors and required contractors and the government to comply within three years.

With its passage in the House, the bill now heads to the Senate, where sources on Capitol Hill indicate that it will pass next week.

What Contractors Need To Know About the Proposed GHG Rule, December 12

On December 12, 10:00 – 11:00 am EST, the Coalition will be hosting a briefing with Paul Freeman, Partner at Crowell & Moring and an expert on environmental law, on the Biden administration’s proposed rule regarding greenhouse gases and climate risk. Published on November 14, the rule would require certain Federal contractors to report greenhouse gas emissions and climate-related financial risks, and to set targets to reduce emissions. It would require all contractors with more than $7.5 million per year in Federal obligations to report direct greenhouse gas emissions (Scope 1 emissions) and emissions from their power consumption (Scope 2 emissions) on an annual basis. Contractors with more than $50 million in obligations would be additionally required to report value chain emissions (Scope 3 emissions), submit an annual public climate disclosure that identifies climate-related risks to their enterprise, and set science-based targets to reduce greenhouse gas emissions.

After Freeman’s briefing, the Coalition will collect member feedback and develop comments to the FAR Council on the proposed rule through its Green Committee.

To register for the briefing, please click here. Please note that this is a members-only event.

Those with questions about registration or the comment process should contact Ian Bell, Policy Analyst, at

OASIS+ Working Group Meeting with GSA, December 15

As part of the process for producing comments on the OASIS+ Draft Request for Proposal (RFP), the Coalition will be hosting a meeting with GSA Regional Commissioner and Assistant Commissioner for the Office of Professional Services and Human Capital Tiffany Hixson on December 15, 10:00 – 11:30 am EST. The meeting will be held in a hybrid virtual/in-person format, with in-person attendance at the offices of Northrop Grumman in McLean, Virginia. To register, click here. Please note that this meeting is for Coalition members only.

If you are interested in joining the OASIS+ Working Group, please contact Joseph Snyderwine at If you wish to submit comments for inclusion in the Coalition’s comments on the draft RFP, please submit them by December 21. GSA’s deadline for all comments is December 31.

SBA and DoD Announce Joint Venture for Small Business Investment in Critical Technologies

The Small Business Administration (SBA) and DoD announced the joint Small Business Investment Company Critical Technologies Initiative (SBICCT). The initiative’s goal is to drive investment in technologies essential to U.S. national security.

At a joint press conference in Simi Valley, California SBA Administrator Isabella Guzman spoke with Defense Secretary Lloyd Austin. “SBA and DoD’s new historic initiative will help make sure America maintains its edge in technologies critical to national security,” said Administrator Guzman. “DoD’s newly established Office of Strategic Capital will leverage SBA’s expertise and successes aligning and scaling public and private capital through its Small Business Investment Company program to address funding gaps in the innovation ecosystem. We are proud to be deepening SBA’s long standing partnership with DoD to drive forward America’s technological and defensive strength – and in turn America’s national security and prosperity.” In addition to this partnership, SBA has proposed regulation that would expand the Small Business Investment Company program while introducing a new financial instrument, the Accrual Debenture.

VA Releases T4NG2 RFI

The Department of Veterans Affairs (VA) Office of Technology Acquisition Center has released the Transformation Twenty-One Total Technology Next Generation 2 (T4NG2) multiple award contract request for information (RFI). The contract is an indefinite delivery, indefinite quantity multiple award task order contract covering solutions and service in support of information technology. The VA expects to release a draft solicitation for review and feedback in early calendar year 2023, with the goal of making awards for T4NG2 prior to the end of fiscal year 2023. All responses to the RFI must be submitted electronically by December 12, 2022, by 3 pm EST here.

GSA Announces New Director of Technology Transformation Services

GSA announced that Ann Lewis has been appointed as Director of the Technology Transformation Services. Prior to stepping into her current role, Lewis focused on supporting small business as Technology Officer at Next Street and as Senior Advisor for Technology and Delivery at SBA. She will take over for acting Deputy Director Lauren Bracey Scheidt.

New Report Sheds Light on Obstacles to Improving the Federal Customer Experience

FCW reports that the Partnership for Public Service has released a new report in collaboration with Accenture Federal Services on obstacles to the Administration’s efforts to improve the Federal customer experience. Based on interviews with customer service leaders across government and with private sector experts, the report argues that the root cause of poor customer service is that Federal services are designed to maximize convenience for the government, not customers. Government should instead take “a collaborative, human-centered approach,” as articulated by the “life experience” framework in the President’s Management Agenda. The life experience approach focuses on designing services around common experiences of Federal customers, such as having a child or exiting military service, that may require them to interact with multiple agencies.

To realize the promise of initiatives like the life experience framework, the report made four recommendations related to budgeting, personnel, data-sharing and regulation. Agencies should identify customer experience personnel needs and “connect those requirements with annual budgeting processes and acquisition planning” so that the Office of Management and Budget (OMB) and Congress can collaborate and fund a customer-focused workforce. In tandem with creating a better workforce, Congress and OMB should allow agencies to fund more cross-program and cross-agency initiatives, and agencies must make clear where gaps exist through budgeting tools like “customer experience portfolios.” Federal agencies and the OMB should use existing authorities to share data and establish new coordination tools, while avoiding temporary workarounds–a common issue in Federal data sharing practices. Congress could assist in these efforts by passing legislation like the Federal Agency Customer Experience Act to allow agencies to collect the data they need to understand the customer experience. Finally, Federal agencies should redesign programs to be more customer-focused, including through expanding presumptive eligibility and increasing delivery flexibility.

Legal Corner:

Final Rule Establishes Requirements for New SBA Veteran Small Business Certification Program

The Legal Corner provides the legal community with an opportunity to share insights and comments on legal issues of the day. The comments herein do not necessarily reflect the views of The Coalition for Government Procurement.

By Meghan F. Leemon and Daniel Figuenick, III, PilieroMazza

The Small Business Administration (SBA) issued a final rule last week, officially transferring the responsibility for certification of veteran-owned small businesses (VOSB) and service-disabled veteran-owned small businesses (SDVOSB) to SBA, effective January 1, 2023.

We previously blogged about this change here, indicating that Section 862 of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2021 provided for the elimination of the Department of Veterans Affairs’ (VA) certification program altogether and implementation of a certification requirement for all VOSB / SDVOSB sole source and set-aside contracts across the Federal Government. As this PilieroMazza client alert highlights, SBA’s final rule not only transfers the VOSB and SDVOSB certification program to SBA, but implements several other notable regulatory changes.

Establishment of SBA’s Veteran Small Business Certification Program

The final rule establishes SBA’s Veteran Small Business Certification Program. The Veteran Small Business Certification Program primarily combines pre-existing regulatory requirements for SDVOSBs (13 C.F.R. Part 125) and VOSBs (38 C.F.R. Part 74) together into a more uniform, consistent certification program. Previously, to bid on VOSB / SDVOSB set-asides procured by the VA, firms had to be certified by the VA’s Center for Verification and Evaluation (CVE). For other agencies seeking to award SDVOSB set-asides (VOSB set-asides are limited to the VA), firms were permitted to self-certify. Now, however, firms seeking to become eligible VOSBs and SDVOSBs will have to comply with the Veteran Small Business Certification Program regulations, which will be codified at 13 C.F.R. Part 128.

One-Year Grace Period and Additional One-Year Extension for Firms Certified by CVE

The final rule contains several important deadlines, extensions, and grace periods for VOSB / SDVOSB firms. Section 862 of the NDAA for FY 2021 created a one-year grace period for self-certified SDVOSBs until January 1, 2024. This grace period grants SDVOSBs one year to file an application for SDVOSB certification, which will allow them to continue to rely on their self-certification to compete for non-VA, SDVOSB set-asides. Self-certified SDVOSBs that submit a complete application before December 31, 2023, will maintain eligibility until the SBA makes a final eligibility decision. Once this grace period ends, VOSBs and SDVOSBs that are not certified by SBA will be ineligible to bid on sole source or set-aside VOSB / SDVOSB awards across the Federal Government. Companies who wait to submit an application until January 1, 2024, or later must wait for a final decision before bidding on SDVOSB sole source or set-aside contracts.

For firms verified by CVE prior to January 1, 2023, these will be deemed certified by SBA during the time that remains on their three-year term of eligibility, plus an additional year. In a recent press release, SBA Administrator Isabella Casillas Guzman announced that all firms verified by the VA as of January 1, 2023, will receive a one-time, one-year extension to their eligibility term, giving veterans an extra year to get recertified under the new SBA system. This extension, she noted, “will allow SBA to process applications from new entrants into the program and grow the base of certified firms.”

Critically, though, the above exceptions and grace periods do not apply to VA procurements (including prime and subcontracts for which the VA is the procuring agency). For VA procurements, offerors must be certified prior to offer.

Eligibility and Certification Requirements for the Veteran Small Business Certification Program
Other notable highlights from the final rule include:

In the past, SDVOSBs had to be small under their primary North American Industry Classification System (NAICS) code. Moving forward, to be eligible for certification as a VOSB / SDVOSB, a firm must qualify as small under any NAICS code under which it currently conducts business activities. This makes sense, as the relevant question for contract pursuits is whether the entity qualifies as small for the particular NAICS code assigned to each contract, which may be different than a company’s primary NAICS code.

In addition, the final rule will still permit self-certification outside of VOSB and SDVOSB set-aside and sole source awards for calculating socioeconomic goals, as the SBA currently permits in the 8(a) business development and women-owned small business (WOSB) programs. Interestingly, though, SBA noted that in a separate rulemaking, it anticipates sunsetting these forms of self-certification after five years.

In the hopes of reducing the administrative burden between the different socioeconomic programs, the final rule will allow for reciprocity between the 8(a) / economically disadvantaged WOSB / WOSB and the new Veteran Small Business Certification Program. This means that if an applicant is currently a certified participant in either the 8(a) or WOSB program, it may rely on such certification (still must apply for verification), provided that it demonstrates that the individual(s) who own and control it are qualifying veterans and certifies that there have been no material changes. Additionally, there will be no annual recertification for VOSB / SDVOSB firms, but rather a recertification every three years, similar to how the process currently works at CVE. However, companies will be required to notify SBA of any changes that may affect eligibility within 30 days of any such change.

Notably, however, while the ownership and control requirements for 8(a), WOSB, and VOSB / SDVOSB firms are similar, they are not exactly the same. As you may be aware, there are five extraordinary circumstances (permissible unanimous consent items) that do not impact a veteran’s or service-disabled veteran’s, as applicable, control over a company. SBA received a comment suggesting that amendments to the bylaws, operating agreement, or other corporate governance documents be added to this list. SBA considered this comment, but it has decided not to expand the list. It is, however, clarifying that the sale of the company also includes sale of all assets of the company. In addition, SBA is expanding the exceptions to the unconditional ownership requirement. Specifically, SBA has added an exception for a right of first refusal. Namely, granting a non-qualifying veteran a right to purchase the ownership interests of the qualifying veteran does not affect the unconditional nature of ownership if the terms follow normal commercial practices. SBA is also implementing somewhat of a “lighter approach” to the control requirement.

Lastly, in the past, the VA determined whether an applicant possessed good character (a requirement to be an eligible VOSB / SDVOSB) by considering whether the individual in control or owning the firm was currently incarcerated, on parole, or on probation. SBA removed this consideration under the new program, reasoning that this issue is one of responsibility, which is within the discretion of the contracting officer, not SBA. On a related note, SBA decided not to incorporate the VA’s “good character” provision, but it will still consider whether an entity is debarred or suspended.

While many of the rules for the Veteran Small Business Certification Program are similar to those for the previous (and separate) VA and SBA regulations for VOSBs and SDVOSBs, firms should be aware of the requirements for certification and recertification, which are not identical to prior regulations. Failing to certify or maintain compliance with the eligibility requirements may prevent you from getting certified and successfully winning VOSB and SDVOSB set-aside contracts. In addition, it is important to understand the other new, subtle rule changes as discussed above.

If you have questions regarding the VOSB and SDVOSB certification transfer and how it may impact your business, please contact Meghan Leemon, the author of this client alert, or another member of PilieroMazza’s Government Contracts Group.

Special thanks to Daniel Figuenick for his assistance with this client alert.

Healthcare Corner:

Cancer Moonshot Resource For Members

The Coalition has now published a resource on the Federal government’s Cancer Moonshot program. Beginning with the launch of Cancer Moonshot in 2016, the slides detail the initiative’s launch, priorities, research goals, and initiatives. The slide deck turns to the relaunch of Cancer Moonshot once President Biden took office. Various new goals, initiatives, and visions of the Cancer Moonshot relaunch are described in more detail. Finally, the slides provide insight into the work Federal agencies and the private sector are contributing to Cancer Moonshot. Hyperlinks are included throughout the presentation to direct you to resources that supplement the content in the slides.

To see the resource in the member portal under the Pharmaceutical Subcommittee resources, click here. For questions or assistance with accessing the resource, please contact Ian Bell at

A View From Main Street

By Ken Dodds, Live Oak Bank

The following blog does not necessarily represent the views of the Coalition for Government Procurement.

Ostensible Subcontractor = Joint Venture = No SBIR Award

The Small Business Innovation Research (SBIR) program was created in 1982 to foster small business research and development (R&D).[1] The program has three phases. Phase I awards are competitively awarded in an amount typically between $50,000 and $250,000 for a term of 6 months to demonstrate the technical merit, feasibility, and commercial potential of the proposed R&D efforts. A Phase II award is typically for $750,000 for 2 years to further the Phase I efforts. Agencies with R&D budgets set aside a certain percentage each year to fund Phase I and II awards. A Phase III award to commercialize the Phase I and II efforts can be sole source without a limit on value but must be funded out of the agency’s regular budget.[2]

The size standard for the SBIR program is 500 employees, including affiliates.[3] Size is determined at the time of award for a Phase I or Phase II award, or at the time of a request for size determination in connection with a pending award.[4] No size standard limitation applies to Phase III awards.[5] The SBIR program has its own affiliation rules, some of which are modeled on SBA’s general procurement affiliation rules, including an ostensible subcontractor rule which provides that a concern and its ostensible subcontractor will be treated as joint venturers.[6]

The SBIR program also has ownership and control provisions which require 50% ownership and control by one or more U.S. citizens or permanent resident aliens, or other small business concerns directly owned and controlled by U.S. citizens or permanent resident aliens. An SBIR awardee can also be owned and controlled by an Indian Tribe, ANC or NHO.[7] For some agencies an SBIR awardee can also be 50% owned by multiple venture capital operating companies, hedge funds or private equity firms.[8] An SBIR awardee can be a joint venture, but each entity in the joint venture must be able to qualify under the SBIR ownership and control rules.[9]

A firm submitted two proposals for SBIR Phase II awards. The contracting officer filed size protests based on the firm’s relationship with its subcontractor, a foreign-owned concern. The prospective awardee was majority owned by a U.S. citizen but had one employee and the majority owner was also an employee of the subcontractor. The subcontractor owned 49% of the prospective awardee and had at least 190 employees. The prospective awardee acknowledged it was affiliated with its subcontractor but argued that the combined employees of the two concerns did not exceed 500 employees. The SBA Area Office found that the subcontractor would perform the primary and vital requirements of the awards. The subcontractor’s employees would perform the majority of the engineering work, and the Area Office concluded that the firm would not have won the awards without the subcontractor’s employees, technical approach and past performance. The Area Office determined that the two concerns did not exceed the size standard, but the concerns were affiliated under the ostensible subcontractor rule and would be treated as a joint venture. One participant in the deemed joint venture, the subcontractor, was not directly owned by U.S. citizens or permanent resident aliens and therefore the deemed joint venture was not eligible for award under the SBIR joint venture ownership rules. On Appeal, the Appellant argued that the regulatory language concerning treatment as a joint venture for size determination purposes is a size issue not an eligibility issue, and that the Area Office should have limited its review to calculating the combined size of a deemed joint venture under the applicable 500 employee size standard. OHA disagreed and denied the appeal, finding that the rules concerning SBIR joint venture ownership are part of SBA’s size rules and that examining compliance with the SBIR ownership rules is a proper function of an Area Office conducting a formal size determination.[10]

Do you have a topic you wish to be covered or a question on how Live Oak Bank can support your business? Email me at

[1] P.L. No. 97-219.
[2] SBIR and STTR Policy Directive (October 2020), pp. 25-6.
[3] 13 CFR 121.702(c).
[4] 13 CFR 121.704(a).
[5] SBIR and STTR Policy Directive (October 2020), p. 27.
[6] 13 CFR 121.702(c)(2).
[7] 13 CFR 121.702(a)(1)(i).
[8] 13 CFR 121.702(a)(1)(ii).
[9] 13 CFR 121.702(a)(1)(iii).
[10] Size Appeal of NFRL LLC, SBA No. SIZ-6174 (September 28, 2022).

GSA Seeking Feedback on Alliant 3 Draft RFP

On December 1, GSA posted its first set of responses to comments and questions the agency received on its Alliant 3 draft RFP, which was posted on on October 19. At a meeting with the Coalition this Tuesday (slides available here), Larry Hale, Acting Director, GSA Office of IT Services, stated that more answers to comments and questions would be posted this week. The draft solicitation remains open for comment through January 6.

The Coalition plans to submit feedback to GSA in response to the draft RFP. For those interested, please provide any comments and questions on the draft RFP to Michael Hanafin at by close of business on December 16.

Join the NASA SEWP VI Working Group

The Coalition is forming a NASA SEWP VI Working Group to engage with NASA on the procurement vehicle and its future. The Working Group will hold meetings with key NASA SEWP VI personnel and develop consensus feedback on any draft documents. If you are interested in joining the Working Group, please contact Michael Hanafin at

GSA Webinar on Upcoming Climate and C-SCRM Acquisition Policy, December 13

GSA FAS’s Office of Policy and Compliance will host a webinar for Federal contractors on the latest changes in Federal procurement policy on December 13, 1:00 – 2:00 pm EST. The webinar will address “cybersecurity supply chain risk management and climate,” and attendees will be briefed on “the policy making and implementation process; how [they] can participate; an overview of climate related initiatives and resources; and an overview of cybersecurity and secure software initiatives.” To register for the meeting, click here.

Help the Coalition Set Priorities for 2023

As the weather has turned cold, the days short and the year late, the Coalition has begun to set its priorities and objectives for 2023. We invite all members to assist in this process by sharing their ideas about topics to address in 2023 through the Coalition’s committees, training, and events. Please send any ideas or suggestions you may have to Aubrey Woolley, Vice President at

SBA Announces Amendment to Veteran Small Business Certification Program

SBA has announced a final rule implementing a statutory requirement to certify Veteran-Owned Small Business concerns (VOSB) and Service-Disabled Veteran-Owned Small Business (SDVOSB) concerns participating in the Veteran Small Business Certification Program. The new rule implements Section 862 of the NDAA for Fiscal Year 2021 by transferring the responsibility for certification as a VOSB or SDVOSB to SBA. Previously, to be certified as a VOSB or SDVOSB, contractors could self-certify unless the contract was with the VA, in which case the verification was handled by the VA’s Center for Verification and Evaluation (CVE).

The change will be effective on January 1, 2023, and businesses have until the end of 2023 to become certified. In the interim, businesses that have self-certified maintain eligibility as their application is considered for certification. CVE-certified businesses will be deemed certified by SBA during the firm’s three-year term of eligibility, but once the term is over, these businesses will have to apply for SBA certification.

For more information on the SBA’s Amendment, please see today’s Legal Corner.

DoD Announces New Office of Strategic Capital

DefenseScoop reports that DoD has created an Office of Strategic Capital (OSC). Announced by Secretary of Defense Lloyd Austin last Thursday, OSC will identify critical technology areas like “advanced materials, next-generation biotechnology, and quantum science” and ensure that innovations there have the necessary financing to overcome the “valley of death” between R&D and production.

Although the office has yet to announce how it will provide financing, the Department stated in a press release that it will work with private capital markets to “crowd-in capital” in key defense technologies, and it is considering “non-acquisition-based tools” like loans and loan guarantees, rather than typical grants and contracts. The OSC will also assist existing organizations like the Defense Advanced Research Projects Agency and the Defense Innovation Unit in capitalizing and scaling projects and “help counter non-market actions by strategic competitors that use U.S. capital markets to advance their own technology goals.” Secretary Austin also announced this week that the OSC’s first official action will be working with SBA on the Small Business Investment Company Critical Technologies Initiative, a joint defense tech investment initiative.

A Strategic Capital Advisory Council, composed of several DoD undersecretaries and other high-ranking personnel, will monitor the OSC and review its investment portfolio prior to approval by the Secretary. The OSC plans to make its first investments early next year.

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