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FCS Diversity and Inclusion - PROPOSED RULE - MARCH 2011


Dear Mr. Van Meter,

Thank you for this opportunity to provide comments on ways the FCS can better serve small and midsized, local and regional food producers.  In regards to your efforts to diversify the FCS loan portfolio please consider the following for inclusion in the future FCS marketing plans:

1. A requirement that FCS institutions create a baseline analysis of producers who meet the farm bill definition of local and regional food producers by number of borrowers, by loan volume, and other key characteristics.

2. A minimum investment goal for local and regional food producers of 10% of the institution’s capital within 5 years.

3. A plan for conducting outreach to local and regional food producers and a commitment to adding local and regional food producers to the FCS board.

4. A requirement that the marketing plan and periodic progress reports be made public.

5. A plan for providing staff development training to FCS personnel across the full spectrum of lending, accounting, farm transfer and business planning services appropriate for serving local and regional food producers.

6. A plan for developing lending and business support products with terms and benefits appropriate for local and regional food producers.

7. An inventory of strengths and weaknesses of the local and regional food infrastructure within the bank’s territory and a plan for leveraging the public and private capital necessary to address those weaknesses.


Ernest J.P. Muhly
P.O. Box 400
Walkersville, MD 21793