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


Gene Batali
612 Follow Through Drive
Yakima, WA 98901-1527


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:

Thank you for requesting 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 director of 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.  Asking shareholders to vote on matters that are the
purview of the board of directors is inconsistent with the Farm Credit
Act, with cooperative principles, undermines the role and responsibility
of directors to represent the interests of shareholders and increases
litigation exposure for directors and institutions.  Shareholder
engagement on compensation matters already exists through the disclosure
requirements that are in place and the ability of shareholders to express
their views on these matters to management and boards at any time.

I have been a Farm Credit System director for 25 years, 15 on the NWFCS
board and 10 on the CoBank board. During those years I have always felt
that both boards were very diligent on how they handled management pay.
Both organizations tied it to performance. I have never heard any
negatives from shareholders and there is an old saying "IF IT ISN'T BROKEN
DO NOT TRY AND FIX IT".

Please modify the final rule on compensation and benefit program
disclosure to remove the requirement for say on pay voting.








Sincerely,


Gene Batali
509-457-4038