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

Erick Gandrud
Box 217
Glenwood, MN 56334

April 22, 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

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.

The vote allowed if there is five percent or more of members petitioning
for a vote on compensation and related issues is nonbinding in nature.
Therefore it is advisory in nature for their boards.  Allowing members
such a vote does not cause a hardship on FCS institutions.  For the same
reasons, members should be allowed to vote on large pay increases of
fifteen percent or more.  These issues go to the heart of what cooperative
governance and what the one-member, one-vote principals are all about.

I would recommend that the FCA make the final rule more stringent by
requiring the vote to be binding upon the FCS institution if a final vote
against such pay increases is agreed to by 60 percent of the voting
members and that a vote by 50% of voting members be enough to be binding
upon FCS CEOs.

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.


Erick Gandrud