Notice of Petition - "Compensation, Retirement Programs and Related Benefits"
Dear Mr. Mardock
Thank you for the opportunity to respond to FCA's request for comments published in the Federal Register on February 19,2013 seeking alternatives to the "say on pay" provisions in the final rule on Compensation,Retirement Programs,and Related Benefits. I fully support the comments submitted in response to this request by the Farm Credit Council and urge the FCA to adopt the Farm Credit Councils position.
As coopertive board members, we are nominated and elected by our fellow stockholders to serve them. Our unique structure means we can maintain an arms' length relationship with management because only non-employee stockholders can serve on the board. As a director we receive feedback from local stockholders on the Associations business affairs. Our association hold client advisory meetings, where we solicit imput from owners.
Congress found it unnecessary to include Farm Credit institutions in the provisions for "say on pay" advisory voting procedures in the Dodd-Frank Act. Our stockholders already participate in the "control,management,and ownership" of their Association appropriately, and I do not believe that soliciting an advisory vote on any issue would promote more meaningful involvement by our owners. Your plan would increase the risk liability of every director in the Farm Credit System and leave them without any protection.
John Baylor Director, 1st Farm Credit Services