Director, Office of Regulatory Policy

Farm Credit Administration

1501 Farm Credit Drive

McLean, VA. 22102-5090

 

Dear Mr. Kramp:

As a Director serving on the Farm Credit West Board of Directors, I am writing to express my concern that FCA’s recently proposed rule on collateral evaluation will have a negative impact on the agricultural producers, agribusinesses and other customers we serve.

 

My diversified family farming operation grows vegetables, lemons, avocados and produces estate grown wine.  It isn’t apparent to me what benefits the proposed rule would provide to me or or any of the other farmers and ranchers who are customers of Farm Credit West.  Has FCA conducted cost/benefit analysis of the proposed rule and the impact it would have on agricultural producers across the country?  If so, please provide that analysis.  If that analysis has not been conducted, I submit that this should be the first step in this process.  Either way, please consider this a formal request of the cost/benefit analysis of this rule making.

 

It appears to me that the proposed rule would slow the the loan approval process and place needless burden on producers without any real benefit to the safety and soundness of the Farm Credit System.  At the same time, this will likely adversely impact young, beginning, small, minority and socially disadvantaged producers who have limited capacity to absorb higher costs of borrowing and very likely lack additional collateral to pledge.  The bottom line is that this will probably hurt a critical group the Farm Credit System is charged to serve.

 

I respectfully ask FCA to withdraw the rule and engage with Farm Credit System representatives in a constructive dialog to identify an approach to collateral evaluation requirements that better serves agricultural producers, recognizes modern best practices and simplifies the credit delivery process.

 

Thank you for your consideration of my comments.

 

Sincerely,