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

Bruce Alford
3115 West 2nd Ct
Russellville, AR 72801-4504

April 22, 2013

Barry F Mardock
Deputy Director, Office of Regulatory Policy, Farm Credit Administration
1501 Farm Credit Drive
McLean, VA 22102-5090

Dear Barry Mardock:

We appreciate the opportunity to respond and 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.

Shareholders of Farm Credit have access to a great deal of information and
several ways to make their voices heard in each association. Our
membership is highly engaged in the nomination and election processes,
with no interference from employees and existing directors. Specifically,
our CEO‚€™s compensation is itemized at this time without further
regulation. Additionally, our senior management‚€™s collective salaries
are also disclosed and will be individually disclosed upon request to any
member. We have had no complaints in this regard.

We believe that, as directors, we serve our membership in very important
roles. One of the most important duties is the hiring of the Chief
Executive Officer, determining his objectives and rewarding his/her
accomplishments. We have a Compensation Committee that studies executive
compensation, in order to better serve the association and better protect
the safety and soundness of our financial cooperative.

To quote a paragraph from FCA‚€™s The Director‚€™s Role ‚€" Farm Credit
System Institutions: ‚€œThe board can fulfill its responsibility and help
protect the institution‚€™s future by making sure that day-to-day
operations are properly managed. Every soundly run and successful
operation is led by a quality management team. Therefore, the board‚€™s
duty in hiring and retaining quality management becomes one of those
critical elements, if not the most critical element, necessary for the
institution‚€™s success. Consistent with these sound governance principles
and FCA‚€™s governance regulations, especially 620.31, each institution
must charter and maintain a formal compensation committee.‚€Ě As FCA has
indicated with this quote, we believe that trained directors are needed to
properly understand the dynamics of executive compensation.

FCA, in extending the comment period, has also asked for alternatives. We
do not think that alternatives are necessary or helpful to our membership.
As directors, we have been asked to make decisions in an oversight role.
If further information and/or thoughts are needed in regard to executive
compensation, we believe that the directorship should choose what best
fulfills that need, not an FCA, regulatory-mandated say on pay vote.

We highly encourage FCA to eliminate this portion of the proposed
regulation and not replace it with any alternatives.


Bruce Alford
Chairman of the Board of Directors
Farm Credit Services of Western Arkansas


Bruce Alford