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


Tom Colgan
264 Orford Road
Lyme, NH 03768-3310


April 18, 2013

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


Dear Barry Mardock:

Thank you for requesting comment on the regulatory petition filed by The
Farm Credit Council regarding the Agency's say on pay mandatory
shareholder vote on compensation matters.

As a director of Yankee Farm Credit based in Williston, Vermont, I support
the request contained in the Council's petition that the agency withdraw
the say on pay vote requirement.  Asking shareholders to vote on matters
that are the purview of the board of directors is inconsistent with the
Farm Credit Act, with cooperative principles, undermines the role and
responsibility of directors to represent the interests of shareholders and
increases litigation exposure for directors and institutions.  Shareholder
engagement on compensation matters already exists through the disclosure
requirements that are in place and the ability of shareholders to express
their views on these matters to management and boards at any time.

Please modify the final rule on compensation and benefit program
disclosure to remove the requirement for say on pay voting.

Sincerely,


Tom Colgan