Notice of Petition - "Compensation, Retirement Programs and Related Benefits" Erik Jacobson 3492 NW Braid Dr. Bend, OR 97701-8682
April 19, 2013
Barry F Mardock Deputy Director, Office of Regulatory Policy, Farm Credit Administration 1501 Farm Credit Drive McLean, VA 22102-5090
Dear Barry Mardock:
I appreciate the opportunity to 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 recently elected and new Director of CoBank 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. It became clear to me early in the process of orientation as a new Director that it is incumbent on the System Boards of Directors to attract and retain the highest quality leadership in Senior Management positions. As System Directors we are elected by the members of these institutions and entrusted with the responsibility of maintaining the best performance and standards within institutions. Clearly compensation and performance incentives are and should remain within the purview of those with the fiduciary responsibility of the financial health of the organization. Shareholders can make their interests known on compensation matters currently disclosed through the requirements that are in place. As a new Director I have already heard opinions regarding the leadership of CoBank and the observations are that we have a very good leadership team that serves their needs well. I have found no interest on the part of members to participate in discussions regarding compensation; they clearly expect the Directors to represent the best interests of the System institutions.
Thank you for the opportunity to comment on this important issue.