Notice of Petition - "Compensation, Retirement Programs and Related Benefits" Fred Bauer PO Box 220 Ault, CO 80610-0220
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 October.
The FCS is a government sponsored enterprise or GSE and they need to have a high standard of accountability and transparency in their dealings. The FCS is also structured as a cooperative and their members need to be allowed to have a vote on the large pay packages of FCS CEOs, executives, and senior officers.
I disagree with the FCS contention that FCA needs Congress to pass a law in order to allow this fundamental right to cooperative members. Where has FCS been when the FCA has granted FCS lenders numerous power grabs in recent years that were not authorized by Congress?
If the FCA backs down on this final regulation due to pressure from the FCS, then the FCA's credibility as a regulator will be severely undermined and its supposed interest in transparency will be shown to be nothing more than empty rhetoric.
Therefore, I request that the FCA either keep the final rule as is or strengthen it as I have suggested in this letter. Thank you for considering my comments.
I find it strange that when FCA rules in FCS' favor in issues like lending to non-farm entities that they do not challenge FCA's authority.