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Dear Director, Office of Regulatory Policy , As a Farm Credit System director, I write to express concern that FCA’s recently proposed rule on collateral evaluation will negatively impact the agricultural producers, agribusinesses and other customers we serve.
The rule would slow the loan-making process and place needless cost and burden on producers without any real benefit to the safety and soundness of Farm Credit System institutions.
I respectfully ask FCA to withdraw the rule and engage Farm Credit System representatives in a constructive dialogue designed to identify an approach to collateral evaluation requirements that is farmer friendly, recognizes modern practices, and simplifies the credit delivery process. Thank you for your consideration. Sincerely,
John Lay
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