Ethics and Arm’s-Length Role
As an agency of the Federal Government, FCA is committed to fulfilling its mission faithfully and ensuring that its employees conduct themselves with integrity. And as the arm’s-length regulator of the Farm Credit System, FCA is committed to carrying out its work without any undue influence, favoritism, or special access.
In 1989, President George H.W. Bush issued Executive Order 12674, which set forth 14 principles of ethical conduct and established the Office of Government Ethics. The Executive order created a framework to establish uniform ethics programs throughout the Executive branch. As a result of this order, FCA appointed its first Designated Agency Ethics Official in 1992 and established the FCA Ethics Program that we have today.
As head of FCA, the Chair of the Board oversees the FCA Ethics Program, which is administered by the following staff positions:
- Designated Agency Ethics Official (DAEO)
- Alternate DAEO
- Deputy Ethics Official
As part of the ethics program, the ethics staff has a number of responsibilities:
- Collecting and reviewing the Federal financial disclosure forms of FCA employees
- Providing counsel to FCA Board members, staff, and former employees regarding conflicts of interest and other ethical issues
- Providing regular education and training to FCA staff on ethics issues
- Serving as liaison to the Office of Government Ethics and the Federal ethics community
- Developing FCA regulations and policies related to ethics
- Taking corrective action if ethics violations, or the appearance of violations, occur
FCA must abide by the following ethics laws, regulations, and rules:
- Title I, Title IV, and Title V of the Ethics in Government Act of 1978 (Pub. L. 95-521, as amended)
- The regulations implementing Titles I, IV, and V of the Ethics in Government Act: Office of Government Ethics Regulations
- Executive Order 12674, which outlines the 14 principles of ethical conduct for executive branch officials and employees
- FCA’s supplemental ethical standards, listed in Title 5 of the Code of Federal Regulations.
FCA is committed to maintaining an arm’s-length relationship with the Farm Credit System. This means that Agency decisions must be independent of any undue influence, favoritism, or special access so that all parties coming before the Agency stand on an equal footing. FCA Board Members and employees with decision-making authority affecting System institutions must be especially mindful to conduct themselves in a fair and impartial manner, avoiding any actions that create an appearance of partiality.
Although an effective regulator must have open, informative communication with regulated institutions, the FCA Board and staff strive to maintain an appropriate balance in their communication with the System. Before engaging with System entities, they consider the content, timing, and setting of their communication with the System. Whenever in doubt about the propriety of communication with System institutions, FCA Board and staff consult with the ethics staff.
For more information, see Board Policy Statement 81, Ethics, Independence, Arm’s-Length Role, Ex Parte Communications and Open Government. Also see FCA’s Arm’s-Length Role.