Notice of Petition - "Compensation, Retirement Programs and Related Benefits" Paul Franklin 141 River Rd. Plainfield, NH 03781-5031
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 a Farm Credit System institution (Yankee Farm Credit), I support the request contained in the Council's petition that the agency withdraw the say on pay vote requirement. Having members vote on salaries would undermine the cooperative/director structure of farm credit associations and would be awkward and unnecessary, especially for small associations such as YFC. YFC has around 120 shareholders per director and holds four annual meetings throughout the association's territory providing members direct personal access to directors and management. Further shareholder engagement on compensation matters 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. YFC has historically not had incentive pay as part of its compensation package, so the 15% threshold is less likely to be triggered unless there is a need to adjust compensation to meet market adjustments.
Please modify the final rule on compensation and benefit program disclosure to remove the requirement for say on pay voting.