Notice of Petition - "Compensation, Retirement Programs and Related Benefits" Nancy Baerwald PO Box 549 Cando, ND 58324-0549
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 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.
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 are nonbinding. 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 even more serious 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.
Therefore, I request that the FCA either keep the final rule as is or strengthen it as I have suggested in this letter. Thank you for considering my comments.