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

Gary Baldosser
5120 N TWP RD 78
Republic, OH 44867

April 21, 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 the Ag Credit Association in Northwest Ohio, a Farm
Credit System institution, I support the request contained in the
Council's petition that the agency withdraw the say on pay vote

Asking shareholders to vote on matters that are the defined
responsibilities of the board of directors is inconsistent with the Farm
Credit Act and its cooperative principles.  It 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.
Association Directors spend a lot of time training and educating
themselves on how to govern prudently and effectively.  Just as Congress
or the Senate is ultimately accountable to the tax paying public, we too
are held to a higher standard than other banking institutions by our
VOTING MEMBERS!.  They elect us to make these decisions because they
recognize they are not engaged at a level that gives them comport to make
these decisions as an individual.  If you honestly believe this to be in
the best interest of the entire Farm Credit System, then let us expand
this idea, and ask that all FCA employees offer their personal salaries
open to a public vote by the residents of The United States.  Let the tax
paying public have a voice in how pay is distributed in the Farm Credit
Administration.  I am sure with enough effort on your part, we can fully
educate every resident on the aspects of defined benefit packages, market
based salary ranges, peer review process, job satisfaction surveys, and
all legal issues that surround your human resource department.

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

This rule on compensation voting will only erode the effectiveness the
Farm Credit System has worked so hard to establish the past 60 years.


Gary Baldosser  Director of Ag Credit ACA