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Office of Advocacy

Grammar and Mechanics

Use one space after periods

Equally owned businesses, which are businesses half owned by men and half owned by women, totaled 860,754 employers in 2018. These businesses employed 7,970,121 workers, generated $1.3 trillion in annual sales receipt, and paid $280 billion in annual payroll.

Italicize caselaw and executive orders

While analyzing the RFA claim, the Court relied on the case U.S. Citrus Science Council v. U.S. Department of Agriculture.

Executive Order 13272, Proper Consideration of Small Entities in Agency Rulemaking, requires Advocacy to report annually on agencies’ compliance with the RFA.

When alphabetizing agencies, cabinet-level agencies start with “Department of”

The following agencies responded to Advocacy comment letters:

Department of the Interior

Department of Commerce

Department of Defense, Army Corps of Engineers

Department of Health and Human Services

Subject-Verb Agreement

Singular nouns require singular verbs, and plural nouns require plural verbs.

The box of State Profiles is on David’s desk.

David, along with Akira, is working on the report.

David and Akira are working on the project.

Verb Tense Consistency

Shifting from one tense to another in the same time frame diminishes clarity. The same tense should be used to state the facts about a rule or proposed rule. If you are stating the effects of a rule by using serial commas, each section should have the same tense.

Example: EPA is required to promulgate regulations requiring certain facilities to create a plan for responding to worst case discharges of either oil or hazardous substances into navigable waters. In response, EPA is proposing this rule, …

Verb Tenses

Present Continuous (-ing verbs) is used to describe an action or condition that is occurring now, occurs frequently, or is on-going. Present Perfect (has or have + past tense verb) is used to reflect actions that happened or started in the past but relate to something in the present. When interpreting data, use present tense. However, use present perfect when the time period emphasizes when the data was collected.

Small businesses also make nearly $2.5 billion in patent licensing revenue a year (12% of total).

The structure of the U.S. banking industry has changed considerably over the last 40 years.

Prior literature has suggested that small banks primarily lend to small businesses within their local markets.

Try to avoid overusing a verb plus the preposition “of” behind it. This tends to yield wordiness.

CORRECT: Verb (or gerund form) release/releases (or releasing)

This is a direct result of releasing hazardous substances.

INCORRECT: Verb plus “of” release of

This is a direct result of the release of hazardous substances.

Write This

Regulatory Flexibility Act (RFA)

Small Business Regulatory Flexibility Act (SBRFA)

Small Business Advocacy Review (SBAR)

initial regulatory flexibility analysis (IRFA)

final regulatory flexibility analysis (FRFA)

Not This

regulatory flexibility act (RFA)

small business regulatory flexibility act (SBRFA)

small business advocacy review (SBAR)

Initial Regulatory Flexibility Analysis (IRFA)

Final Regulatory Flexibility Analysis (FRFA)


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The Office of Advocacy supports businesses with less than 500 employees, non-profit organizations, and independent contractors. Our mission is to help small entities as regulations are developed in Washington.

We are an independent office within the U.S. Small Business Administration (SBA). We do not take part in SBA’s work on loans, disaster relief, or procurement.

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