John W. Klein — profile dossier

Pandemic-program role: SBA's institutional authority on the size-standard and affiliation rules that defined who counted as a "small business" eligible for PPP and EIDL — the regulations his Procurement Law group owns.
Institution · office: SBA · Office of the General Counsel (Deputy General Counsel; formerly Associate General Counsel for Procurement Law) · Type: career (SES)
Tenure (relief-relevant): an OGC lawyer since 1983; led Procurement Law from 2000; Deputy General Counsel by 2024 and still in role into 2025.

The job (role mechanics)

Level / appointment: Career SES attorney: Deputy General Counsel (formerly Associate General Counsel for Procurement Law); in SBA's OGC since 1983, one of the agency's longest-tenured lawyers.
Reports to: The SBA General Counsel (as Deputy GC he is the GC's principal deputy).
Core responsibility: SBA's institutional authority on small-business size standards (13 CFR part 121) and affiliation rules (13 CFR 121.301(f)) and the set-aside programs (8(a), HUBZone, SDVO, WOSB), the body of regulation that defined who counted as a "small business" eligible for PPP/EIDL; now the agency's Deputy General Counsel.
Pay: His pay is not in a first-party document.
Expectations / mandate: Advise senior SBA officials on size/affiliation and contracting law, draft and serve as the named agency contact on size-standard rulemakings, act as Suspension and Debarment Official (All Other Programs), and (as Deputy GC) help run the Office of General Counsel.
Tenure norm: Continuing (career civil servant; does not turn over with administrations). His actual service: OGC since 1983; AGC-Procurement-Law from 2000; Deputy GC by 2024, still in role into 2025.

Who they are

John W. Klein is a career Senior Executive Service attorney who has been in SBA's Office of General Counsel since 1983. He is the agency's recognized expert on small-business size standards, affiliation, and the set-aside contracting programs (8(a), HUBZone, SDVO, WOSB), and is now SBA's Deputy General Counsel.¹²³

Education

B.A., magna cum laude, State University of New York at Stony Brook (1980); J.D., with distinction, Hofstra University School of Law (1983).³

Career before the pandemic

Klein joined SBA's OGC straight out of law school in 1983, serving in the Office of Legislation and the Office of General Law before becoming Associate General Counsel for the Office of Procurement Law in 2000, the principal legal advisor to senior SBA officials on 8(a), government contracting, HUBZone, SBIR, size standards, SDVO, and WOSB. He was the go-to public face for SBA's contracting rulemakings (a 2013 Law360 "5 Questions" profile, frequent National 8(a) Association and bar appearances) and was credited as principal drafter of SBA's limitations-on-subcontracting and Small Business Jobs Act rules.³⁴

Role in the pandemic relief programs

PPP and EIDL eligibility rested on SBA's size standards (13 CFR part 121) and affiliation rules (13 CFR 121.301(f)) , both administered through the Procurement Law group Klein headed.⁵ The PPP affiliation interim final rule ("Promissory Notes, Authorizations, Affiliation, and Eligibility," 85 FR 23450, Apr. 28, 2020) was signed by Administrator Jovita Carranza, with a call-center contact line; Klein is not named on the face of the PPP affiliation rules.⁶ The post-pandemic OIG audit most squarely in his domain is Report 25-14, "Eligibility of PPP Loans Exceeding Maximum Size Standards" (May 2025).⁷

Documents written or signed

Signatory of SBA's formal management response, as Suspension and Debarment Official for All Other Programs (OGC), in SBA OIG Report 19-18, "Audit of SBA's Suspension and Debarment Process" (Sept. 18, 2019); he also appears on its cc-list.⁸
Credited principal drafter of SBA's limitations-on-subcontracting and related contracting rules; profiled in Law360 (Sept. 12, 2013).⁴

Career after / where they are now

Still at SBA. He is listed as Deputy General Counsel on SBA's current bio page and on the Office of General Counsel org page (last updated Jan. 21, 2025), and was billed as "SBA Deputy General Counsel" at an Aug. 7, 2024 Coalition for Government Procurement event. We have no departure or retirement notice.¹²⁹

Sources held in this archive

Original source documents and archived captures

Sources (first-party)

SBA official bio, "John Klein" ("serves as SBA's Deputy General Counsel"). SBA official bio, "John Klein" "serves as SBA's Deputy General Counsel" (original: sba.gov · stored capture) ↩
SBA, Office of General Counsel page (leadership; Procurement Law group scope incl. size standards; last updated Jan. 21, 2025). SBA, Office of General Counsel page describes the Legislation & Appropriations function (original: sba.gov · stored capture) ↩
AmCham Bahrain conference speaker bio (SBA-supplied): education (Stony Brook 1980; Hofstra 1983) and OGC career since 1983, AGC-Procurement-Law since 2000. John Klein Bio Pdf 3Ac465F0C458B645 (original: portal.amchambahrain.org · stored capture) ↩
Law360, "5 Questions For SBA's Procurement GC John Klein" (Sept. 12, 2013). Law360, "5 Questions For SBA's Procurement GC John Klein" Sept. 12, 2013 (original: law360.com · stored capture) ↩
SBA, "Affiliation Guide" / size-standards compliance guidance (13 CFR 121 framework applied to PPP). SBA, "Affiliation Guide" / size-standards compliance guidance 13 CFR 121 framework applied to PPP (original: sba.gov · stored capture) ↩
Federal Register, PPP affiliation IFR, 85 FR 23450 (Apr. 28, 2020), FR Doc. 2020-09098 — signed by Administrator Carranza (call-center contact, not Klein). 2020 04 28 2020 09098 (original: federalregister.gov · stored capture) ↩
SBA OIG Report 25-14, "Eligibility of PPP Loans Exceeding Maximum Size Standards" (May 2025). Report - Sba Oig Report 25 14 Pdf 0Eddab56978B6D73 (original: oversight.gov · stored capture) ↩
SBA OIG Report 19-18, "Audit of SBA's Suspension and Debarment Process" (Sept. 18, 2019), Agency Response signed "John W. Klein, Suspension and Debarment Official for All Other Programs, OGC." Report - Sba Oig Report 19 18 Pdf 5664Bb6Bb41050A3 (original: sba.gov · stored capture) (link now dead; copy taken from the Internet Archive, 20 November 2024) ↩
Coalition for Government Procurement event listing, "SBA Regulatory Update with John Klein, SBA Deputy General Counsel" (Aug. 7, 2024). Coalition for Government Procurement event listing, "SBA Regulatory Update with John Klein, SBA Deputy General Counse... (original: thecgp.org · stored capture) ↩