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Notice of Petition - "Compensation, Retirement Programs and Related Benefits"


Jeffrey L Gerhart
PO Box 479
Newman Grove, NE 68758-0479


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.

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.

Sincerely,


Jeffrey L Gerhart