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


William Lipinski
38 Gristmill lane
Hampden, MA 01036-9674


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 Chief Executive Officer of a Farm Credit System institution, 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,


William Lipinski
413-566-2007