July 16, 2021 

Mr. Kevin J. Kramp ​Email to reg-comm@fca.gov 

Director, Office of Regulatory Policy 

Farm Credit Administration 

1501 Farm Credit Drive 

McLean, VA 22102-5090 

Re: ​Proposed Rule – 12 CFR Part 614 – RIN 3052-AC94; Collateral Evaluation Requirements; 86 Federal Register 27308-27323 

Dear Mr. Kramp: 

As a regulator in the past myself I can understand the complexity of the issues you deal with daily so I’m sympathetic to your role in the issue noted above.  I am an outside director for GreenStone FCS and have been since 2002.  Our association was formed by the combination of four smaller associations that have grown into what is now an $11B co-op for farmers who are fueling our economic recovery.  I’ve watched with delight and some amazement at the changing environment for farm credit and have nothing but pride in the role directors, farm credit associations and FCA play in the system.   With your patience I’d like to add my personal comments to the Farm Credit Administration (“FCA”) on the above referenced Proposed Rule.

The GreenStone management team has been actively engaged in a workgroup with several other Farm Credit System institutions to review, analyze and discuss the Proposed Rule and its ramifications utilizing a very talented group of executives and active farmers.   Over the years I have come to abide by the two golden rules of our farm credit business:  Protect our members and borrowers and make credit available to the backbone of our country, the farm community.

As you have heard from others, GreenStone is completely supportive of the Farm Credit System comment letter urging rejection of the proposed rule.  Our leaders understand the complex nature of balancing existing state and federal appraisal standards, current FCA appraisal rules, and today’s Farm Credit collateral evaluation processes.   The Proposed Rule puts directors at real disadvantage as we play out our fiduciary role in trying to uphold those two golden rules I referred to above..  I take my role seriously on the GreenStone board and have read, analyzed as best a non-practitioner could and fully support the System’s comment letter and join the request for withdrawal of the Proposed Rule.  While I would never claim to be even remotely as knowledgeable as you or our FCS staff, it seems obvious the rule unnecessarily complicates the process and places farm credit at a disadvantage when competing with other financial institutions.  The success of many young and beginning farmers and I would say without doubt many of their predecessors would be hampered by these proposed rules. 

Thanks for the opportunity to comment, I’m sure your role in this is complicated enough but I wanted to add my two cents to the process.  Let’s find some common ground on a fundamental issue like this and rely on the expertise developed and encouraged by Farm Credit over these many years.  It’s a system admired throughout the world, 

Respectfully submitted,

Dennis Muchmore