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76–479 2012

SMALL-BUSINESS LENDING: PERSPECTIVES FROM 

THE PRIVATE SECTOR 

HEARING 

BEFORE THE

SUBCOMMITTEE ON INVESTIGATIONS AND 

OVERSIGHT 

OF THE

COMMITTEE ON SMALL BUSINESS 

UNITED STATES 

HOUSE OF REPRESENTATIVES 

ONE HUNDRED TWELFTH CONGRESS 

SECOND SESSION 

HEARING HELD 

JUNE 21, 2012 

Small Business Committee Document Number 112–073 

Available via the GPO Website: www.fdsys.gov 


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(II) 

HOUSE COMMITTEE ON SMALL BUSINESS 

SAM GRAVES, Missouri, Chairman 

ROSCOE BARTLETT, Maryland 

STEVE CHABOT, Ohio 

STEVE KING, Iowa 

MIKE COFFMAN, Colorado 

MICK MULVANEY, South Carolina 

SCOTT TIPTON, Colorado 

CHUCK FLEISCHMANN, Tennessee 

JEFF LANDRY, Louisiana 

JAIME HERRERA BEUTLER, Washington 

ALLEN WEST, Florida 

RENEE ELLMERS, North Carolina 

JOE WALSH, Illinois 

LOU BARLETTA, Pennsylvania 

RICHARD HANNA, New York 

NYDIA VELA ́ ZQUEZ, New York, Ranking Member 

KURT SCHRADER, Oregon 

MARK CRITZ, Pennsylvania 

JASON ALTMIRE, Pennsylvania 

YVETTE CLARKE, New York 

JUDY CHU, California 

DAVID CICILLINE, Rhode Island 

CEDRIC RICHMOND, Louisiana 

GARY PETERS, Michigan 

BILL OWENS, New York 

BILL KEATING, Massachusetts 

LORI SALLEY, Staff Director 

PAUL SASS, Deputy Staff Director 

BARRY PINELES, General Counsel 

MICHAEL DAY, Minority Staff Director 


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C O N T E N T S 

OPENING STATEMENTS 

Page 

Hon. Mike Coffman .................................................................................................. 1 

WITNESSES 

David J. Rader, Business Executive, SBA Lending, Wells Fargo, Minneapolis, 

MN ......................................................................................................................... 2 

Brett Martinez, President & CEO, Redwood Credit Union, Santa Rosa, California ..................................................................................................................... 4 

Tim D. Dixon, Senior Vice President, Head of Small Business Administration 

Lending, Citizens Bank, Warrensville Heights., OH ........................................ 5 

Robert L. Marquette, President/CEO, Members 1st FCU, Mechanicsburg, PA . 7 

APPENDIX 

Prepared Statements: 

David J. Rader, Business Executive, SBA Lending, Wells Fargo, Minneapolis, MN ................................................................................................. 19 

Brett Martinez, President & CEO, Redwood Credit Union, Santa Rosa, 

California ....................................................................................................... 23 

Tim D. Dixon, Senior Vice President, Head of Small Business Administration Lending, Citizens Bank, Warrensville Heights, OH .......................... 36 

Robert L. Marquette, President/CEO, Members 1st FCU, Mechanicsburg, 

PA ................................................................................................................... 46 

Questions for the Record: 

None. 

Answers for the Record: 

None. 

Additional Materials for the Record: 

Millwork & More Letter for the Record .......................................................... 60 

Pekel Construction Letter for the Record ....................................................... 61 

Written Testimony of Christopher G. Hurn ................................................... 62 

CG&S Design-Build Letter for the Record ..................................................... 70 

National Association of the Remodeling Industry Letter for the Record ..... 71 

Small Business Investor Alliance Letter for the Record ............................... 72 

A&C Kitchens & Baths Letter for the Record ............................................... 76 

Total Home Letter for the Record ................................................................... 77 

Benjamin Plumbing, Inc. Letter for the Record ............................................. 78 

Creative Concepts Remodeling, Inc. Letter for the Record ........................... 80 


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SMALL-BUSINESS LENDING: PERSPECTIVES 

FROM THE PRIVATE SECTOR 

THURSDAY, JUNE 21, 2012 

HOUSE OF REPRESENTATIVES, SUBCOMMITTEE ON INVESTIGATIONS AND OVERSIGHT, COMMITTEE ON SMALL BUSINESS, Washington, DC. 

The Subcommittee met, pursuant to call, at 10:00 a.m., in Room 

2360, Rayburn House Office Building, Hon. Mike Coffman (chairman of the Subcommittee) presiding. 

Present: Representatives Coffman, Tipton, West, Schrader, and 

Hahn. 

Chairman COFFMAN. Good morning. 

On Wednesday, June 6th, the Small Business Committee held an 

oversight hearing with SBA Administrator Karen Mills to question 

this administration about its procedures for setting policy for its financial assistance programs. The Committee also examined SBA’s 

procedures for lending oversight to make sure that SBA is protecting taxpayers by conducting proper oversight of its lending 

partners. 

Today, we are here to follow up on that hearing. Testifying today 

are private-sector lending partners who will discuss the effect of 

SBA policy on loan processing and how SBA can be a better partner. 

In addition to reviewing SBA policy and procedures, we will also 

hear about how other financial regulators are impacting credit 

availability for small businesses. The Committee consistently hears 

from both bankers and small businesses that the regulatory environment is harming economic growth. This is an opportunity to 

hear more about the regulatory burdens on banks. 

We all know that economic growth will be led by small businesses. To encourage this important sector to grow and create jobs, 

we need an environment where small businesses can access capital 

and banks have the freedom to lend without consistent secondguessing by regulators. 

I would like to thank our witnesses for taking time away from 

their businesses to testify here today. 

If Subcommittee members have an opening statement prepared, 

I ask them to have it submitted for the record. 

I would like to take a moment to explain the timing lights for 

you. You will each have 5 minutes to deliver your remarks. The 

light will start out as green. When you have 1 minute remaining, 

the light will turn yellow. Finally, at the end of your 5 minutes, 

it will turn red. I ask you to adhere to the time limit. 


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Our first witness is David Rader, head of small-business lending 

for Wells Fargo. Wells Fargo is SBA’s top lender by dollars lent to 

small businesses and second in the number of loans. So far in fiscal 

year 2012, Wells Fargo has already made over half a billion dollars 

in loans to small businesses through the SBA’s 7(a) Loan Program. 

David has been with Wells Fargo for 29 years. 

David, thank you for being here, and we look forward to your testimony. 

STATEMENTS OF DAVID J. RADER, BUSINESS EXECUTIVE, SBA 

LENDING, WELLS FARGO, MINNEAPOLIS, MINNESOTA; 

BRETT MARTINEZ, PRESIDENT AND CHIEF EXECUTIVE OFFICER, REDWOOD CREDIT UNION, SANTA ROSA, CALIFORNIA, 

ON BEHALF OF THE CREDIT UNION NATIONAL ASSOCIATION; TIMOTHY D. DIXON, SENIOR VICE PRESIDENT, HEAD 

OF SMALL BUSINESS ADMINISTRATION LENDING, CITIZENS 

BANK, WARRENSVILLE HEIGHTS, OHIO, ON BEHALF OF THE 

CONSUMER BANKERS ASSOCIATION; ROBERT L. MARQUETTE, PRESIDENT AND CHIEF EXECUTIVE OFFICER, 

MEMBERS 1ST FEDERAL CREDIT UNION, MECHANICSBURG, 

PENNSYLVANIA, ON BEHALF OF THE NATIONAL ASSOCIATION OF FEDERAL CREDIT UNIONS 

STATEMENT OF DAVID J. RADER 

Mr. RADER. Mr. Chairman, Ranking Member Schrader, and 

members of the Subcommittee, my name is David Rader. And for 

the past 5 years, I have been the business executive of Wells Fargo’s SBA lending business. I have been employed at Wells Fargo 

for 29 years. Thank you for inviting me here today. 

Wells Fargo, as the Chairman said, is the national SBA lender 

that offers all core 7(a) as well as the 504 loan products. We have 

over 350 dedicated SBA team members, and we are a growing and 

profitable business for the bank, holding loan balances of $7 billion. 

As the Chairman said, for the past 3 years Wells Fargo has been 

the number-one 7(a) dollar lender, approving more than $1.2 billion 

in 7(a) loans, representing 3,142 loans. And we also made history 

by becoming the first institution to generate over a billion dollars 

of 7(a) loans in the program. Our lending trend continues today, 

and, through May, Wells Fargo remains the number-one 7(a) lender, approving $734 million, and we currently are the number-two 

unit lender. 

These dollars represent significant numbers of both large and 

small loans. We believe that the flow of new dollars into our communities represents a very powerful statement for job creation and 

economic development. We want to lend more dollars to more creditworthy customers, and we believe the SBA agency is aligned with 

Wells Fargo to achieve that goal. 

As the Nation’s number-one SBA lender, we appreciate the very 

constructive engagement of the SBA and the interest it has in our 

lending perspectives. We regularly participate with the SBA in an 

ongoing dialogue on credit policy issues, oversight, and program enhancements. We also believe there are opportunities to improve the 

programs and streamline the very complex SBA Standard Operating Procedures (SOPs). 


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The agency’s efforts to reduce regulation and process over the 

years, especially the SOPs, are welcome. In Wells Fargo’s view, the 

SOPs can be simplified and clarified further for the benefit of all 

without added risk to the taxpayer. For example, the public September 2011 SOPs lack clarity surrounding stock ownership rules 

and Eligible Passive Company/Operating Company (EPC/OC) structure rules. As a result, many industry lenders sought standard 

processing approval rather than Preferred Loan Program (PLP) approval, resulting in customer delays and added processing expense 

for all. 

When SOPs are made, the agency must provide the industry 

with enough lead time to educate, train, and develop internal risk 

systems so we are equipped to best serve our customers and make 

loans with enforceable guarantees. 

We believe there can be much more transparency in the SOP vetting process, both with the SBA and the lending industry at large, 

as well as with the SBA and the SBA Office of Inspector General 

(OIG). From our vantage point, the OIG continues to be too deeply 

involved in the vetting process. We find the process unclear, and 

we are often surprised at the outcome, hampering our ability to 

react and train our teams effectively. We suggest that the SBA give 

lenders an opportunity to change the SOPs and give us time, at 

least 30 days, prior to any final release. 

We also recommend that the agency revise the current SOPs. For 

example: Eliminate the requirement for blue-ink signatures on necessary SBA forms. Number two, allow loans to individuals when 

there is a change-of-ownership transaction involving a stock purchase rather than just an asset purchase. Number three, allow 7(a) 

loans under $350,000 to be approved and processed under the SBA 

Express program using lender’s delegated authority. Those are just 

a few suggestions. 

Wells Fargo continues to urge the SBA to focus its resources on 

streamlining existing programs, both 7(a) and 504, rather than creating brand-new programs that serve limited niches. The recently 

revised CAPLine program is a great example of SBA’s progress in 

this regard. 

Wells Fargo welcomes practical and prudent lender oversight. 

Strong lender oversight will level the playing field and make the 

programs more consistent, cost-effective, and easier to use. We view 

the SBA on-site review process as rigorous and an opportunity for 

us to improve. We take pride in our substantial compliance with 

SBA regulations. 

We welcome the recent appointment of the Office of Credit Risk 

Management (OCRM) director and look forward to a new era of 

transparency and collaboration. OCRM’s willingness to discuss key 

portfolio-monitoring tools is a welcome change that we appreciate. 

There is much work to do. If we work together and share best 

practices, Wells Fargo continues to be optimistic about our ability 

to help businesses succeed financially while being good stewards of 

the SBA program. We look forward to our ongoing dialogue and 

partnership with the SBA. 

And I would be happy to answer any questions. Thank you. 

Chairman COFFMAN. Great. Thank you for your testimony. 


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Our next witness is Brett Martinez, president and CEO of Redwood Credit Union located in Santa Rosa, California. Brett is testifying on behalf of the Credit Union National Association, where he 

serves on their board of directors. In his 25 years of banking experience, Mr. Martinez served as a senior executive with the California Credit Union League with a large southern California credit 

union prior to joining Redwood in 2002. 

Mr. Martinez, thank you for being here, and we look forward to 

your testimony. 

STATEMENT OF BRETT MARTINEZ 

Mr. MARTINEZ. Thank you. 

Chairman Coffman, Ranking Member Schrader, and members of 

the Subcommittee, thank you for the opportunity to testify at today’s hearing. Again, my name is Brett Martinez, and I am president and CEO of Redwood Credit Union, a $2 billion State-chartered credit union serving 220,000 members, located in Santa Rosa, 

California. Redwood is the largest credit union SBA lender in the 

country by loan volume. 

Credit unions share the Small Business Committee’s goal of increasing access to credit for small businesses through the reduction 

of statutory and regulatory impediments. At the end of the year, 

there were over 330 credit union SBA lenders. These credit unions 

collectively have $800 million in SBA loans outstanding. The average credit union SBA loan is roughly $100,000. 

Since December of 2007, SBA loans have grown by 90 percent at 

credit unions throughout the Nation. SBA-guaranteed loans are important to borrowers who otherwise would not be able to get a conventional loan, but they are complicated to make. They require 

staff with a special kind of expertise. They cost the borrower and 

their lender more to make than conventional loans, and they take 

longer to complete. 

My written testimony describes how we have been able to use 

SBA loan programs to help small businesses in our community. We 

find ourselves in a fragile economic recovery. Small businesses that 

have survived the recession have largely done so by rightsizing 

their business following a path of declining profits. Many have 

shown losses for several years. As a result of their ongoing restructuring, they are beginning to once again show profits. Ultimately, 

they are left with a need to restructure their balance sheets, consolidate debt, and free up cash flow to grow their business. 

We have used SBA programs, including the 504 Refinance Program and the First Mortgage Lien Pool program, to help our members stay in business, preserve jobs, and survive through the economic recovery. These programs expire in September, and we encourage Congress to reauthorize them. Otherwise, small businesses 

will be adversely impacted. 

My written testimony describes efforts that CUNA has taken to 

encourage SBA to improve its programs through reduced regulatory burden, increased transparency, and a streamlined application program. In general, we have seen improvements in this area 

over the last several years. However, other lenders who do not 

have the experience that we do still may find the process very complicated. To that end, it is important for SBA to continue its efforts 


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in this regard and continue to engage lenders when it modifies 

SOPs and other policies. 

Enhancing access to credit for small businesses is an important 

part of promoting job creation and the economic recovery. There is 

significant demand for credit from small businesses. During the financial crisis, credit unions expanded business lending to their 

members while other lenders pulled back. Many credit unions that 

contributed to the vast majority of this growth are now becoming 

severely constrained by the statutory cap on credit union business 

lending. 

Redwood is one of these credit unions. We are at 75 percent of 

our capacity, and we will only be able to lend to business members 

for the next 18 months. The cap will not only affect our ability to 

offer conventional loans but also our ability to offer SBA loans. 

That is why we are strongly encouraging Congress to increase the 

statutory cap on credit union business lending. 

Representatives Ed Royce and Carolyn McCarthy have introduced legislation to allow experienced credit unions operating near 

the cap to apply to NCUA for authority to lend beyond that cap. 

We estimate that the Royce-McCarthy legislation would inject $13 

billion into new capital and to small businesses in the first year 

after enactment and create 140,000 new jobs, all at no cost to taxpayers. We appreciate the several members of the Subcommittee 

that have cosponsored the legislation. 

Some banking trade associations strongly oppose the RoyceMcCarthy bill. They suggest it is unnecessary because the guaranteed portion of an SBA loan does not count against the cap. However, SBA is not a solution to the cap limitations. Notwithstanding 

their merits, SBA loans clearly are not a substitute for conventional business loans. 

At the same time, increasing the cap on credit union business 

lending would almost certainly lead to an increase in SBA-guaranteed lending. Some small businesses, both that qualify for a conventional loan and those that require a government guarantee, 

would have more access to credit to start growing their business 

and create jobs. We encourage Congress to enact the Royce-McCarthy legislation. 

Thank you again for the opportunity to testify today, and I am 

happy to answer any questions. 

Chairman COFFMAN. Thank you for your testimony. 

Our next witness is Timothy Dixon, senior vice president and 

head of SBA lending at Citizens Republic Bancorp. Citizens serves 

customers in Michigan, Ohio, and Wisconsin. Tim has close to 30 

years of commercial banking experience, serving as executive vice 

president of commercial banking at SkyBank before joining Citizens Republic. Tim is testifying on behalf of the Consumer Bankers 

Association. 

Tim, thank you for being here today, and you have 5 minutes to 

present your testimony. 

STATEMENT OF TIMOTHY D. DIXON 

Mr. DIXON. Chairman Coffman, Ranking Member Schrader, and 

members of the Subcommittee, my name is Tim Dixon, and I am 

senior vice president and head of Small Business Administration 


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lending for Citizens Bank. Citizens Bank serves communities located within Michigan, Ohio, and Wisconsin, with 219 branches 

and 249 ATMs. We are a community-oriented institution, with a 

majority of our revenue being derived from our core bank, which 

is heavily oriented toward small business. 

Citizens is a preferred SBA lender, with dedicated specialists to 

fast-track the process, and we also have expertise in other State 

and local loan programs. While we utilize a number of the SBA 

loan programs across the bank, the majority of our loan volume is 

7(a) Express, with an average loan size of $60,000. 

I am also a member of the Consumer Bankers Association’s 

Small Business Banking Committee, which includes the top business bankers in the country, who share the common goal of helping 

small businesses meet their financial needs. 

Headlines highlighting weak consumer confidence and high unemployment have created a great level of uncertainty for smallbusiness owners. Many business owners are cautious to take on additional debt or to hire new employees with the current level of economic uncertainty. Continued reports of a possible double-dip recession only further the concerns of business owners and the confidence of American consumers. 

SBA lending has played an important role in helping small-business owners meet their financial needs in difficult times. While 

SBA lending remained strong in the first half of 2012, overall numbers appear to be lower than those of 2011, a banner year for SBA. 

Much of the difference can be attributed to the expiration of loan 

enhancements provided under the Small Business Jobs Act. 

Short of reinstating these temporary provisions, today’s hearing 

is an opportunity to highlight positives and identify ways to improve the SBA programs. CBA’s Small Business Banking Committee compiled a list of recommendations focused on the SBA’s 

7(a) and 504 programs and sent them in a recent letter to the SBA 

and Congress, highlighting our suggestions to improve the efficiency and effectiveness of these valuable programs. The SBA incorporated a couple of our recommendations in its most recent revision of its standard operating procedures, or SOP. However, CBA 

believes there are still a number of changes the SBA can make to 

help increase lending. 

As detailed in our written testimony, the Consumer Bankers Association suggests a number of enhancements to the 7(a) and 504 

programs. Most notably, we suggest a streamlined 7(a) process by 

allowing preferred lenders to use Express loan forms and processes 

for all 7(a) loans. For 504 loans, we encourage the reauthorization 

of the Refinance Program, which is currently scheduled to sunset 

in September. 

The SOP is a complicated document, and while having the ability 

to make slight tweaks can be beneficial at times, quick and frequent changes to the SOP process can create real-world challenges. 

As the terms of the SOP are ever-changing, it creates practical 

challenges to interpret revisions, train staff, update systems, and 

be in compliance if these changes are coming too frequently. The 

ability of an institution to keep up with changes to the SOP can 

have large compliance cost implications, which can adversely affect 

lending. 


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Furthermore, the clarification of SOP terms can be time-consuming and difficult. For example, the improvements to the 

CAPLine program issued in late 2011 do not provide clear terms 

for loan qualification. In response to industry inquiries, the SBA 

took over 6 months to provide adequate clarification. And so we 

recommend a more methodical and consistent approach to SOP policy changes. 

Finally, effective SBA lender oversight is another area of concern. Members of the CBA have found that the SBA audit process 

can be a very time-consuming exercise and is not always useful to 

assess and mitigate risk. A more transparent and streamlined 

audit process would go a long way in improving lender efficiency. 

Lender oversight should be a means for the agency to identify 

variances from established lender benchmarks and provide a reasonable process for lenders to remedy deficiencies. 

We applaud this Committee’s continued efforts to improve the efficiency and effectiveness of the SBA’s programs. I thank you for 

the opportunity to appear here today, and I would be happy to answer any questions you may have. 

Chairman COFFMAN. Thank you for your testimony. 

Robert Marquette is president and CEO of Members 1st Federal 

Credit Union, located in Pennsylvania. Members 1st Credit Union 

has over 200,000 members. Robert is testifying on behalf of the National Association of Federal Credit Unions, where he serves on 

their board of directors. 

Mr. Marquette, you have 5 minutes to present your testimony. 

STATEMENT OF ROBERT L. MARQUETTE 

Mr. MARQUETTE. Good morning, Chairman Coffman, Ranking 

Member Schrader, and members of the Subcommittee. My name is 

Bob Marquette, president and CEO of Members 1st Federal Credit 

Union, and I am testifying today on behalf of NAFCU. Thank you 

for holding this important hearing. I appreciate the opportunity to 

share our views on small-business lending from a lender’s perspective. 

Credit unions currently operate under an arbitrary business 

lending cap of 12.25 percent of total assets. This artificial cap acts 

as a barrier to credit unions meeting the needs of their small-business members. It should be noted that the government-guaranteed 

portions of SBA loans do not count toward the member business 

funding cap, but the nonguaranteed portions do. This could cause 

a credit union to scale back participation in SBA programs as they 

approach the arbitrary cap. 

A 2011 SBA study indicates that credit union business lending 

increased before and during the financial crisis, while banks decreased. This demonstrates that credit unions continue to meet the 

capital needs of their business members even during the most difficult of times. In addition, the study found that bank business 

lending was largely unaffected by changes in the credit unions’ 

business lending. 

We urge Subcommittee members to support the bipartisan legislation, H.R. 1418, the Small Business Lending Enhancement Act, 

which addresses the arbitrary business lending cap. 


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Our Nation’s Main Street businesses also recognize that the artificial cap hurts job creation and their access to capital. Like us, 

they support and urge passage of H.R. 4293, the Restore Main 

Street’s Credit Act of 2012, introduced by Subcommittee Ranking 

Member Kurt Schrader. 

At Members 1st, we launched our member business lending program in January of 2003 but are unfortunately approaching our arbitrary cap today. Our average member business loan is $185,000, 

while the median size is only $60,000. We estimate that Members 

1st business loans created 52 new jobs in our area and helped save 

269 more in 2011. 

At Members 1st, we entered the SBA 7(a) program in late 2010 

and have originated two 7(a) loans. We have also participated in 

the SBA 504 program for a longer period and have originated three 

loans in that program. 

Both 7(a) loans were for existing firms that were expanding and 

provided additional capital. However, both loans took nearly a year 

to fund. The SBA 7(a) process was time-consuming and burdensome. It left us with the impression that an established business 

lender, such as Members 1st, seeking to enter into the SBA marketplace is at the bottom of the SBA priority list. The multiple tiers 

within the SBA 7(a) program give larger lenders a competitive advantage over small institutions. Members 1st has stopped actively 

marketing our SBA 7(a) loans until we find a solution that can 

more efficiently meet our members’ needs. 

Members 1st has had success using the SBA 504 loan program. 

That program and the USDA Business and Industry Loan Program 

have been well received by our members. Both programs treat all 

incoming applications equally, regardless of our history with the 

agency. 

NAFCU is pleased that SBA Administrator Karen Mills has been 

open to meeting with credit unions and hearing our concerns about 

SBA programs. We hope that this dialogue will continue and ultimately be productive in addressing our concerns. 

One way for the Subcommittee to help address these concerns is 

to support H.R. 4191, the Credit Union Small Business Lending 

Act, introduced by Subcommittee Ranking Member Kurt Schrader 

and full Committee member Representative Steve Chabot. This bipartisan bill would amend the Small Business Act to: one, direct 

the SBA Administrator to implement a program to increase credit 

union participation in the SBA small-business loan program; two, 

simplify the application process for such participants; and, three, 

provide a guarantee of up to 85 percent for loans made in underserved areas. These steps would make the process easier for credit 

unions to become more involved in SBA lending and open the door 

to more access to credit for those small businesses and communities served by them. 

In conclusion, we recognize that small businesses are the driving 

force of our economy and the key to its success. While the SBA 

lending programs are providing much-needed opportunities to businesses, there are still obstacles preventing them from reaching 

their full potential. That is why we, on behalf of our Nation’s credit 

unions, their 94 million members, and our Nation’s small businesses, urge the Subcommittee to support legislation such as H.R. 


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1418, H.R. 4191, and H.R. 4293 to make it easier for credit unions 

to aid our Nation’s small businesses and create jobs. 

We thank you for your time and the opportunity to testify before 

you here today on this important issue to small businesses, credit 

unions, and our Nation’s economy. I would welcome any questions 

that you may have. 

Chairman COFFMAN. Thank you for your testimony. 

The first question is for Mr. Rader and Mr. Dixon. I often hear 

from financial institutions that while entities in Washington encourage them to lend more, regulators on the ground are in fact requiring them to increase capital reserves. Have you experienced 

this? And, if so, how has this decreased the amount of loans that 

you can make? 

Mr. Rader. 

Mr. RADER. Mr. Chairman, our SBA lending business is providing capital to small businesses, and Wells Fargo has always 

been in a good position to provide that capital. So while we implore 

and applaud the SBA to reduce regulation and enhance and modify 

SOPs, we absolutely have not seen a decrease in our lending because of capital concerns at Wells Fargo. 

Chairman COFFMAN. Mr. Dixon. 

Mr. DIXON. Yes, Mr. Chairman, you know, I think we have continued to see growth in our SBA loan portfolio. We don’t feel constrained or feel that the regulatory burden is causing us, you know, 

difficulties in continuing to grow the portfolio and support small 

business. 

Chairman COFFMAN. Great. 

And a question to all the witnesses. We can start with Mr. Marquette. Are small businesses confident, in your view, about their 

ability to access credit and grow their businesses at this time? 

Mr. MARQUETTE. What we have heard from small businesses in 

our area, they have seen some kind of a retrenching of business 

lending in our area. For whatever purpose, for whatever reason, I 

am not sure. 

We have seen a significant increase in the number of applications that we have received. But because of that business cap that 

we have, business lending cap that we have, we have to be more 

selective. We have to operate within that cap, and we are about 90 

percent of our cap right now. 

So we have seen some retrenchment. It is easing up a little bit. 

And credit unions have really stepped up to the plate in order to 

be that dependable source of business lending that our businesses 

need. 

Chairman COFFMAN. Mr. Dixon. 

Mr. DIXON. As we talk to business owners and look at the research, you know, I think while there has been recovery in small 

business, business owners have learned something. They are cautious; they are keeping available credit in their hip pocket, if you 

will, for a rainy day. 

So I think some of the challenge with loan demand has been just 

small businesses not requiring as much credit. But where we have 

creditworthy borrowers, you know, we feel the markets are competitive and the access to capital is there, particularly partnering 

with SBA. 


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Chairman COFFMAN. Uh-huh. 

Mr. Martinez. 

Mr. MARTINEZ. We are seeing an improvement in that area. I 

will just give you an anecdote. Redwood Credit Union started SBA 

lending in 2008, and we immediately became the number-one SBA 

lender in our area. That wasn’t because we were doing a significant 

number of SBA loans; it was because we were continuing to lend. 

A lot of the local banks had pulled back. 

So we are seeing that start to improve. We are still the numberone SBA lender in our area, but improvement is there. A big impact over the past 41⁄2 years, though. 

Chairman COFFMAN. Mr. Rader. 

Mr. RADER. Mr. Chairman, we are seeing better financial statements from our small-business borrowers. We do believe their revenue trends and their profitability trends are improving. We have 

in our business, in our SBA business right now an increase in applications, an increase in new loan activity and submissions for 

credit. Our approval rates are higher this year than last year. And 

our approved pipelines, both in the 504 as well as 7(a), are up. 

So we are encouraged by that activity, and we believe that we 

have the tools, especially with the new revised SOPs on the 

CAPLine program to provide larger working capital loans, that we 

will have the tools necessary to continue that slow improvement 

and progress on borrowing. 

Chairman COFFMAN. Okay. 

As you go through audits for both banking regulators, in the case 

of credit unions, your regulators, and the SBA, do you feel that the 

two entities are working together, or are they just completely separate? 

Anybody who would like to answer that. 

Mr. MARTINEZ. I will go ahead and start. 

I know NCUA is very supportive of SBA and has actually been 

talking to SBA and talking to Congress about their support there. 

So NCUA credit union regulators are very supportive. 

Chairman COFFMAN. Okay. 

Anyone else? 

Mr. DIXON. Our experience has been that the SBA is listening 

and we have a good working relationship, but we think there is 

work to be done in the audit and oversight area. And as we talk 

among the banks at CBA, we have made some specific recommendations to just improve the efficiency of that process. 

Chairman COFFMAN. Okay. 

Mr. Martinez, according to your testimony, approximately 2,000 

credit unions engage in business lending. Why so few? Roughly, I 

think, 300 are offering SBA business loans and products to their 

members. 

Mr. MARTINEZ. Yes, those numbers are accurate. 

I know this hearing isn’t about the business lending cap, but it 

is the number-one impediment for credit unions to get into both 

commercial lending and SBA lending. Those that are already in it 

are managing to a cap, and those that see the cap as a reason for 

them to not get into something that they are going to shut down 

is a reason that they are not getting into that. 

Chairman COFFMAN. Okay. 


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At this time, we will make some rounds to the Members. And I 

think we will hopefully have a second opportunity for rounds of 

questions. 

Ms. Hahn. 

Ms. HAHN. Thank you, Chairman. This is actually my first hearing as a member of this Subcommittee, so I really want to thank 

you for holding this important hearing on the state of lending for 

our small businesses. 

And thanks to all the witnesses for being here today. 

You know, since I have been on the Small Business Committee, 

I have really made an effort to go out and talk to many, many 

small businesses personally, hundreds personally I have talked to. 

And I wanted to find out, what is it, what do you need from us, 

do we need to get out of the way or do we need to get involved, 

to make it better? 

And the number-one thing my small businesses have told me 

that they needed was better access to capital. They need more customers, number one, so they wanted the economy to improve and 

they want folks to have jobs so they can be customers. But the second thing was, they felt like if they could get access to capital, that 

they would expand, they would hire, and it really would be about 

job creation. 

One of the things I also heard was the burden of paperwork to 

fill out for an application for a small-business loan. And I introduced H.R. 3836, the Small Business Paperwork Reduction Act, 

which would reduce the amount of paperwork needed for a loan of, 

I think, $250,000 or under from 12 pages to 2—something simple 

that I think we can do to help folks, you know, at least get through 

the process of application. 

I am really pleased to see our credit union witnesses here today. 

I am a big fan, as you know, of credit unions. I am also a fan of 

Wells Fargo. I am an equal-opportunity borrower. I have borrowed 

from Wells Fargo, and I have borrowed from my local credit union. 

But I do think that you made the case very clear, as you have 

in the past, about the lending cap. I am a cosponsor of the Small 

Business Lending Enhancement Act, which will raise the lending 

cap for credit unions. I believe that our credit unions really are 

there in the communities. They are like the community banks. 

They know their members; many of them know them by name. 

They help them, not only with the loan, but just with, kind of, overall counseling about becoming financially sound in their dealings. 

So I appreciate that. And I hope Congress will pass that. 

You know, Mr. Rader, what I am going to ask you is, one of the 

other things I heard from my small businesses was that sometimes 

the commercial banks will add a couple of requirements that the 

SBA does not require in their loans—for instance, collateral, real 

estate collateral. In other words, the Small Business Administration doesn’t put that as a criteria to make the loan, but then sometimes the commercial banks will add that because your auditors 

would require that. 

Is there a way that we can reconcile that? Because I heard that 

over and over again, that what the Small Business Administration 

put on as a requirement, you all added to that and sometimes 


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made that then the breaking point that small businesses were unable to comply with. 

Can we reconcile that? 

Mr. RADER. Yes, Congresswoman, I would be happy to understand the details of your clients’ situation. The SBA rules basically 

say that if a borrower does not have 100 percent collateral coverage 

in their real estate loan or in what they are purchasing, that we 

have to take all available collateral. 

That is an SOP rule. That is what we follow. And that is currently something that is a good lending practice, but also it hurts 

demand and the ability to provide loans for those customers who 

don’t. 

So there is a delicate balance of making sure—— 

Ms. HAHN. So you are not adding any? 

Mr. RADER. The SBA programs and the rules of the SOP require 

all available collateral. 

Ms. HAHN. Okay. 

And let me go back to the credit unions. Either one of you can 

answer this. You have made it pretty clear on what you think we 

can do. So, specifically, is there anything else that you see Congress doing that could increase the amount of loans that our credit 

unions can be making out there to our small businesses specifically? 

Mr. MARTINEZ. I will go ahead and start. 

You know, besides the cap—that is to keep people in—is, make 

the entrance easier. It is a little daunting process. We were able, 

over the past 41⁄2 years, one of the banks in our area pulled back, 

so we were able to attract people that had significant experience, 

so it wasn’t as daunting for us. But if you don’t have that experience, it is a relatively daunting process to get involved. 

And then additional training. There are not a lot of people out 

there that are trained in this. You don’t take internal staff and say, 

go be an SBA expert. It is very technical. 

So I would say those two things: make the process easier, reach 

out to credit unions; and provide additional training. 

Ms. HAHN. How are our local SBA regional administrators, how 

are they doing on the ground with all of you? 

Mr. DIXON. Our experience is they have been very accessible, 

want to be out in the communities, work with the banks, establish 

a dialogue. So I feel we have a good working relationship with the 

three States we are within in the region. It has been a very positive experience. 

Mr. RADER. And, Chairwoman, I would echo that. You know, 

Wells Fargo is a community bank. We have our SBA lending officers in most of the communities or big communities across the 

country. We have a very good relationship with the local district offices, with the SCORE program, as well as some of the most larger 

CDC organizations. So that is a big part of our outreach and an 

important part of the process. 

Chairman COFFMAN. Thank you. 

Mr. West of Florida. 

Mr. WEST. Thank you, Mr. Chairman and Ranking Member. 

Thanks to the panel for being here today. 


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A couple months ago, the National Federation of Independent 

Businesses put out a survey that said about 8 percent of small 

businesses are looking to grow and expand. When you talk to these 

individuals, when you have them here in front of our hearings, 

three things: tax policy, regulatory environment, and lack of access 

to capital. Last week in Palm Beach Gardens, we had a small-business roundtable with Regents Bank. Once again, the exact same 

thing. And so there is a serious concern about the regulatory environment that is out there that is precluding the right type of lending. 

So the question I have first is, how have you seen, if you have 

seen it at all, any type of effects from Dodd-Frank and what that 

is having on small-business lending practices and procedures in 

your respective financial institutions? 

Mr. RADER. Congressman, again, the SBA programs are primarily driven by the SOPs. So we are focused, as an SBA lender, 

on following those rules and suggesting good changes to those rules 

that prevent the barriers of entry for getting an SBA loan. So, at 

this point, for our lending institution, the Dodd-Frank rules impact 

our larger bank, obviously, but, again, we are focused on SBA and 

the SBA procedures. 

Mr. WEST. But, you know, one of the recurring things, especially—I mean, Wells Fargo is a tad bit bigger than a lot of your 

small community banks, which are the lifeblood to small businesses. And what they are having a problem with—and that is why 

I am trying to get an understanding if you all are having the same 

problem—is examiners and regulators coming down based upon the 

rules of Dodd-Frank—you know, this is above and beyond the rules 

of the SBA—that are reclassifying good-quality loans that you all 

have said are okay, and they are transferring that over to negative 

assets, and a lot of these financial institutions cannot carry that 

much negative asset. 

So that is my question. Are you all seeing that type of trend as 

well? 

Mr. MARTINEZ. On the credit union side, we are not. On the SBA, 

I agree with Mr. Rader. You know, we are focused on SBA SOPs. 

But Dodd-Frank, on the regular business side and consumer side, 

we are not seeing really much impact to that. 

Mr. WEST. Okay. 

Then the next question I will ask is, how often does the Small 

Business Administration come down and do reviews of your loan 

portfolios? 

And then also, how often do you have sharing of best practices 

with the SBA so that you have a voice in the streamlining of processes and procedures? 

Mr. RADER. Our Wells Fargo SBA business routinely gets audited 

at least once a year. Our last audit, we got the final results in August of 2011. So we are most likely due soon for another on-site 

exam. 

We continually have dialogue with the SBA agency personnel in 

policy, in new product development. We wish we had a more transparent voice and transparency in understanding their vetting process, because we do have a lot of ideas to streamline programs and 

eliminate some of the inefficiencies that we see. 


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Mr. DIXON. As we talk about the topic, Congressman, in CBA, 

you know, the audit process depends on the type and size of institution. But our audits are every other year, and then there is a 

continued quarterly review of our loan portfolio. 

And, you know, we think, as we pointed out in our testimony, 

that there are opportunities to make the process more efficient, 

more timely. And I think that will be better for all of us. 

Mr. WEST. Okay. 

How long is the normal turnaround on an audit report, on average? 

Mr. RADER. We had our on-site audit last June, June 2011, and 

we received almost instantaneous feedback on what we were doing 

well. We did receive the official report in August of 2011. 

Mr. WEST. Okay. 

Mr. DIXON. You know, there is an exit conference after the onsite audit is completed, but in talking with members of the Committee, you know, the full closure could be out as much as 12 

months. When you receive a final report and respond to the open 

questions and bring it to close, it could be that long. 

Mr. WEST. Good or bad? 

Mr. DIXON. We think that is a little lengthy. And there are opportunities to compress that timeframe, working with SBA. 

Mr. WEST. Thank you, Mr. Chairman. I yield back. 

Chairman COFFMAN. Thank you, Mr. West. 

Mr. Schrader of Oregon. 

Mr. SCHRADER. Thank you, Mr. Chairman. 

I appreciate the panel’s being here today. You guys are all star 

actors in the lending program as we try and get small businesses, 

medium-size, and even large businesses back on their feet again. 

So I really appreciate all the work you are doing. 

I appreciate the comments by both Mr. Rader and Mr. Martinez 

that Dodd-Frank is not impacting small banks, the community 

banks, or credit unions. That is not where it was intended to. We 

want to keep our attention on that, though. You know, sometimes 

our good folks in the agencies sometimes have a tendency to extrapolate what is supposed to be for the larger institutions, and I 

think that might be what Mr. West was getting at. So if we can 

be in assistance in making sure you are not in the cross-hairs of 

those that pose a systemic risk. So I appreciate that clarification. 

Having said that, I am curious about improvements. We are 

dealing with the small-business side of things in this Committee, 

and we have gotten a new Administrator in the last few years. It 

would appear to most of us, I think, on the Committee that things 

have turned for the better. Some of your testimony would seem to 

indicate that. So, as you go through, I would like your ‘‘yes’’ or ‘‘no,’’ 

it has gotten better or, no, it is still a little Byzantine progress. 

A comment for Mr. Rader, in particular. Talking about the SBA 

being responsive, you list some things in your testimony, you mentioned a few. Has the SBA responded to those? And what do you 

think their tendency has been recently in terms of improved regulatory framework? 

Mr. RADER. We are seeing a positive new era of transparency 

within the agency, so my vote would be, yes, it is getting better. 


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We have constantly talked to the agency officials about credit policy and process. We think we have a good dialogue there. 

However, we do not understand the vetting process. There needs 

to be more clarity. And I believe the agency is intending on providing that, and we are making slow progress. 

Mr. SCHRADER. Good. Good, good. 

I guess, Mr. Chair, I hope we kind of follow through on that to 

make sure that that is occurring and work with both the agency 

and the lenders out there. 

Mr. Martinez, you talked a little bit about, as did Mr. Marquette, 

about trying to improve our opportunities with credit unions. They 

got left out of the Small Business Lending Fund last cycle, if you 

will. And I was pretty disappointed about that, because, as you 

have indicated, you also are, like our community banks, very interested in getting this economy back on track and our small businesses up and running. 

And I was concerned about the testimony that, you know, Mr. 

Marquette also talked about, of the 2,000 banks, credit unions that 

are doing small-business lending, 500, almost 25 percent, are at 

their cap. Could you guys talk a little bit more about how important it is, as, you know, frankly, you have seen an influx perhaps 

of new customers, that raising that small-business cap might be? 

And I don’t want to take business away from one outfit, you 

know. I think all boats should rise here, at this point in time. 

Mr. MARQUETTE. We have seen a significant demand coming in. 

And we, too, are at about 90 percent of our cap, so we have to be 

more selective. We do that through pricing and be more selective 

in terms of the loans we grant. But we are also trying to expand 

the communities that we serve, too, and the cap is an impediment. 

The SBA programs are helpful, in that, again, the guaranteed 

portion of the 7(a) programs don’t count toward the cap. But, again, 

the process that we go through, since we are not a preferred lender, 

is very time-consuming, so it is very burdensome to us. We have 

not been as successful as Mr. Martinez in terms of getting expertise that specializes just in SBA loans in our particular area, and 

that would be very expensive for us to do. 

So anything that SBA could do to help us streamline that process 

and maybe have it work a little bit more efficiently, like the 504 

program, would be much helpful in terms of our even expanded effort in that program. 

Mr. SCHRADER. Mr. Martinez. 

Mr. MARTINEZ. Yes, thank you for the question. 

We are seeing increased requests for SBA loans. There are two 

programs that I mentioned, the SBA 504 refi program and the 

First Mortgage Lien Pool program. Those two programs are very 

important to us, and both of those sunset in September. The refi 

program, for those businesses that their loan is becoming due and 

their loan-to-value is upwards of 90 percent, the SBA program is 

really the only product for them. 

For our credit union, we are having to sell our 504s. We have the 

sunset coming up in September for the First Mortgage Lien Pool 

program. We are having to sell our 504s to the secondary market 

just to give us room to create some room in our cap. Unfortunately, 


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it is only going to give us about 6 additional months at the rate 

that we are going. 

But those programs allow for a little bit of levers to be pulled, 

and I think that they are very important. If those programs weren’t 

there, we wouldn’t be able to help businesses that are refi-ing, and 

we would hit our cap sooner if the pooling program goes away. 

Mr. SCHRADER. Thank you. 

Could I ask one more question real quick, Mr. Chairman? 

Chairman COFFMAN. Yes, go ahead. 

Mr. SCHRADER. I appreciate that. 

Mr. Dixon, you talked about the loan enhancements. Everyone 

has talked about the value, I think, a little bit of the credit loan 

guarantees. Sometimes I get feedback from folks back home, some 

of the lenders back home, that that is not as important. I mean, 

you always want a sound loan; that is the real bottom line. 

But could you comment, real briefly, because I am over my time 

limit, real briefly on how important those loan guarantees are that 

are expiring, whether it is in the refi program or whatever? 

Mr. DIXON. Yeah, let me speak, Congressman, to the 504 refi program. Our experience, in just talking with the CBA member banks, 

is that program is continuing to gain momentum. It has been a 

great tool to help small business in this interest-rate environment. 

It allows them to get access to very attractive capital. And we 

would really like to see that program extended. We think it does 

nothing but gain momentum. 

Mr. SCHRADER. Thank you very much. 

Thank you, Mr. Chairman. 

Chairman COFFMAN. Mr. Tipton of Colorado. 

Mr. TIPTON. I am fine, Mr. Chairman. 

Chairman COFFMAN. Very well. 

Let me, since they are going to call a vote soon—and if anybody 

has any additional questions, I will come back around. 

This is a question for all of you. Do you encourage small businesses to apply for an SBA loan because of concerns that banking 

regulators will question the loan if made conventionally? Would 

anybody like to respond to that? 

Mr. MARTINEZ. I will comment. 

When we have a business come in, we sit down and look at them 

and explain all the loan options. We don’t push them into any particular loan. If they can go conventional, that is the best product 

for them, and we go conventional. And then on the SBA program, 

it is laying it out and not driving them into a specific product because it is better for us. 

Mr. DIXON. Congressman, I think we find that we let that decision be made one client at a time as we look at a loan request and 

decide if any of the SBA programs will make the difference in getting that small business the credit that it needs. 

Mr. RADER. Mr. Chairman, I believe the best course of action for 

our clients and our borrowers is to give them financial options— 

so, conventional, 7(a), 504—making sure we profile the borrower 

for what their needs are and where they are going with their business. And so, we do not steer. 

Chairman COFFMAN. Okay. 

For additional questions then, Ms. Hahn of California. 


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Ms. HAHN. Thank you, Mr. Chairman. 

Mr. Marquette, in your testimony, you talked about the process 

that your credit union went through to begin offering SBA loans, 

and you said new lenders were feeling like they were on the bottom 

rung of the SBA priority list. 

What do you think SBA could and should do to encourage, you 

know, new lending partners out there in this quest that I think we 

are all having to provide small businesses with more access to capital? 

Mr. MARQUETTE. As I mentioned, we have been having discussions with the SBA Administrator, Karen Mills. She has been very 

open. 

The issue is the 7(a) process. It seems that they are more interested, in our perspective anyway, in the larger loans and larger institutions and larger employers. In our particular area, our niche 

is the smaller loans, the smaller employers. About two-thirds of our 

business loans are to employers that have less than 20 people 

working for them. So that is our particular niche. 

They could reach out more to smaller institutions. They could 

ask those smaller institutions, what are the impediments, what are 

the processes. We can’t afford to put an SBA expert on staff. We 

worked very closely with a community development corporation to 

help us with the 7(a) program, and even with their assistance it 

took us 1 year for the two S–7(a) programs that we did. 

We do, however, on the 504 programs, since we go through the 

CDCs, they seem to have a better relationship with SBA in terms 

of processing those loans and have been much more successful in 

those. 

Chairman COFFMAN. Thank you, Ms. Hahn. 

Mr. West of Florida. 

Mr. WEST. Last question. You brought up a lot of great recommendations that you were discussing. Have you provided any of 

those recommendations over to the SBA, Mr. Rader? 

Mr. RADER. Yes, we have, Congressman. 

Mr. WEST. Okay. 

And the next thing: When the SBA—I know they have come up 

with some new practices and new procedures. Do they send those 

out to get maybe a buy-in or a comment from financial institutions 

first and foremost? Or do you kind of get the, you know, ‘‘surprises 

are not just for birthdays’’ effect? 

Mr. RADER. As I have spoken in my testimony, the agency could 

do a better job of giving us a better lead time when they do make 

changes. We have to do a lot of training and investment in education and develop risk controls for these programs. And when we 

get a new SOP that is announced, for example, on May 25th with 

an effective date of June 1, it doesn’t give us the proper time to 

train our people to help our customers. 

Mr. WEST. And last question: The preferred lending status, do 

you find that is an easy status to attain? A little bit difficult? 

Do you understand how to attain that status? Across the board. 

Mr. RADER. Yes, we understand how the process works and how 

the process doesn’t work. So, yes. 

Mr. MARTINEZ. We are a fairly new preferred lender. We started 

in 2008. And we were actually kind of cautious to go into that preVerDate Mar 15 2010 03:47 Nov 16, 2012 Jkt 076479 PO 00000 Frm 00021 Fmt 6633 Sfmt 6602 E:\HR\OC\A479.XXX A479

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ferred-lender status, so we could have gotten it earlier than we did 

and felt comfortable with the process of having SBA continue to 

look. So I don’t think it was burdensome. It was a decision that we 

made when we were ready for it. 

Mr. WEST. Okay. 

Mr. Dixon. 

Mr. DIXON. Congressman, we have been a preferred lender for 

many years. I think we find it works well, and that status is, you 

know, reviewed and renewed each year. But that process works 

pretty smoothly for us. 

Mr. MARQUETTE. As I said, we are just new in the 7(a) program, 

and our experience has been less than acceptable. So we are still 

exploring it, and we will look into that in the future. 

Mr. WEST. Thank you, Mr. Chairman. I yield back. 

Chairman COFFMAN. Ms. Hahn of California for an additional 

question. 

Ms. HAHN. I just wanted to follow up on what Congressman West 

asked Mr. Rader. 

Would it be possible for you to provide to the members of this 

Subcommittee the list of the SOPs that you are encouraging the 

SBA to look at? And then maybe we could follow up with the Administrator to see where they are at, what is the status, and if 

there is anything that we could do to follow up on that. 

Mr. RADER. Absolutely. Wells Fargo can provide that. 

I would also encourage the chair and Committee to check out the 

National Association of Government Guaranteed Lenders (NAGGL) 

Association recommendations, as well. 

Ms. HAHN. Thank you. 

Chairman COFFMAN. Very well. I want to thank all the witnesses 

for testifying today. 

For us to get this economy moving, it is going to take small business. And for small business to lift us out and create some jobs, it 

is going to take access to capital. And you are all integral to that 

process, so thank you for what you do. 

The hearing is adjourned. 

[Whereupon, at 11:00 a.m., the subcommittee was adjourned.] 


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pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 96 76479A.049
68 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 97 76479A.050
69 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 98 76479A.051
70 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 99 76479A.052
71 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 100 76479A.053
72 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 101 76479A.054
73 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 102 76479A.055
74 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 103 76479A.056
75 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 104 76479A.057
76 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 105 76479A.058
77 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 106 76479A.059
78 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 107 76479A.060
79 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 108 76479A.061
80 


pwalker on DSK7TPTVN1PROD with HEARINGInsert graphic folio 109 76479A.062