You may, in SBA's discretion, retire a Debenture through the issuance of Participating Securities. To do so, you must:
Obtain SBA's approval to issue Participating Securities;
Pay all unpaid accrued interest on the Debenture, plus any applicable prepayment penalties, fees, and other charges;
Have outstanding Equity Capital Investments (at cost) equal to the amount of the Debenture being refinanced; and
Classify all your existing Loans and Investments as Earmarked Assets.