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Notice of Petition - "Compensation, Retirement Programs and Related Benefits"

Nathan Richter
PO Box 468
Hazen, ND 58545-0468

April 19, 2013

Barry F Mardock
Deputy Director
Office of Regulatory Policy, Farm Credit Administration
1501 Farm Credit Drive
McLean, VA 22102-5090

Dear Mr. Mardock:

I'm writing this letter in opposition to the Farm Credit System (FCS)
petition against giving a voice to their member owners (say on pay) and in
support of the Farm Credit Administration's (FCA) final rule adopted last

I would recommend that the FCA make the final rule more stringent by
requiring the vote to be binding upon the FCS institution if a final vote
against such pay increases is agreed to by 60 percent of the voting
members and that a vote by 50% of voting members be enough to be binding
upon FCS CEOs.


Nathan Richter