Home About FCA News & Events Reports & Publications Law & Regulations Exam Guidance FCS Information FCA Logo

Return to Public CommentsPrevious PagePrevious Comment LetterNext Comment LetterNext Page

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


Scott Nissen
278 2nd Ave E, P.O. Box 99
Franklin, MN 55333-0099


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.  Rejecting the FCS petition is also necessary to
ensure better safety and soundness practices are in place for the FCS.
Therefore, I request that the FCA keep the final rule in place and
strengthen it as suggested above.  Thank you for considering my comments.

Sincerely,


Scott Nissen
507-557-2233