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

Steve Zeman
120 Mill Street South
West Salem, WI 54669-1611

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 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 must have a high
standard of accountability and transparency in all of 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.  That is how a cooperative works!

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 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?   They have been given
more and more powers and authorizations over the years to the point that
they no longer work toward the best interest of the small and medium sized
farming entity.  They only want to do business with large farming
enterprises and with their funding mechanism they can offer lower rates to
all of their borrowers than tax paying banking institutions can.

The final rule should even be 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 is completely gone and its
supposed interest in transparency will 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.


Steve Zeman