Notice of Petition - "Compensation, Retirement Programs and Related Benefits" Scott Tewksbury PO Box 515 Edgeley, ND 58433-0515
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 October.
If the FCS system has gotten so large that it is too difficult to get member participation to approve executive level pay packages, then they are probably getting too large and should be broken into smaller entities. Doing so would also increase the likely hood that they will go back to their legislative mandate of helping smaller family farms without access to normal credit markets.
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?
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.
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.