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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.


Erik N Jaccobson
503 931 8610