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Rural Community Investments - Proposed Rule - Comments received after 8/15/08


JERRY L. O'CONNOR
President
The National Bank of Waupun
N11346 Ott Drive
Waupun, WI 53963-9644


August 18, 2008

Gary Van Meter
Deputy Director, Office of Regulatory Policy
1501 Farm Credit Drive
McLean, VA 22102


Dear Gary Van Meter:

I am a former employee of the Farm Credit System.  I use to work on
projects to create strategies that would expand Farm Credit's activities
beyond those that are authorized by Congress.

Since leaving Farm Credit, I am highly concerned that this mostly untaxed
(taxpayer supported) GSE NOT be allowed to expand services beyond their
current structure.

In fact during this time when COngress should be addressing huge deficits,
it seems more appropriate that Farm Credit be converted to a tax paying
entity.

Like Fannie Mae and Freddy Mac, Farm Credit has gotten into trouble that
requried a tax payer bail out to keep them afloat.

The quas- guaranty that the tax payer would bail them out again still
exists.  WHY?

With the capital base Farm Credit has accumulated, this would be the right
time to remove the GSE status, the quasi-guaranty of taxpayer bailouts and
let them pay taxes in the same manner as their competition.

I am writing to express my opposition to the Farm Credit Administration's
proposed rule that would allow Farm Credit System lenders to invest up to
150 percent of their capital surplus on projects unrelated to agriculture.

The Farm Credit System (FCS) is a farmer-owned and farmer-capitalized
cooperative lender that is also a government-sponsored enterprise (GSE).

Congress created GSEs to serve specific missions, with certain advantages
and limitations.

The proposed rule would shift the FCS away from its statutory mission to
lend to farmers, ranchers, certain farm-related service businesses,
farmer-owned cooperatives, and certain rural homeowners.

It would authorize FCS institutions to finance hospitals, healthcare
facilities, transportation infrastructure, hotels, office parks,
manufacturing facilities, and any other types of investments FCA
identifies as appropriate.

The proposed FCA rule would permit FCS institutions to invest up to 150
percent of their owners' capital surplus in speculative investments that
the FCA has little or no experience in evaluating for safety and soundness.

The proposal would harm farmers and ranchers, as well as the System's
cooperative framework since every FCS lender is jointly and severally
liable for the actions of their fellow cooperative members.

Poor investment decisions could hurt the FCS's credit rating, resulting in
higher interest rates and fees charged to farmers and ranchers.

Congress rejected similar expansion proposals for the Farm Credit System
in the 2008 Farm Bill.

This proposal also violates principles limiting the mixing of banking and
commerce.

When banking and commerce are integrated there exists a genuine risk of
insider activity, preferential treatment, undue influence, and
anti-competitive activities.

The System should not be allowed to make investments in areas where it has
no experience, no loan making authority, no branch networks, and no
authority granted by Congress.

The Farm Credit Administration should withdraw the proposal on
"mission-related activities."

Sincerely,


Jerry L. O'Connor
920-324-5551
President
The National Bank of Waupun


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