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In order to participate in the program, a mentor and protégé must submit their joint venture agreement to the SBA for approval. Id. § 124.513(a)(1). The Section 8(a) participant must be the “managing venturer” of the joint venture, and an employee of the Section 8(a) concern must be designated as the project manager responsible for overall contract performance. Id. § 124.513(c)(2). Where the “8(a) concern brings very little to the joint venture relationship in terms of resources and expertise other than its 8(a) status, SBA will not approve the joint venture agreement.” Id. § 124.513(a)(2). The applicable regulations specifically provide that “[n]o determination of affiliation or control may be found between a protégé firm and its mentor based on the mentor/protégé agreement or any assistance provided pursuant to the agreement.” Id. § 124.520(d)(4).

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