Director Agan’s:
    As a director in the Farm Credit System at Western AgCredit I appreciate the opportunity to comment on the proposed YBS rule. We, at our association, have a strong interest in YBS borrowers and are aligned with FCA’s vision. Our track record and strategic vision bears that out. We are committed to our YBS borrowers through educational opportunities, scholarship programs, succession assistance, grants, reduce requirements on dept-to-equity ratios, and earning rate discounts by registering in our AgFuture program. Our efforts and outreach to the YBS program are evident by the YBS statistics in our portfolio: 38% of total portfolio volume, with 47% small and 19% beginning and 17% young of total outstanding loans.
     The proposed rule states 4 objectives.  The regulation that would be created by the proposed rule, would negatively impact our current efforts to serve the YBS borrowers, creating undue compliance and reporting burdens, diverting resources to administrative coordination. The regulation created by the proposed rule would reduce the effectiveness and productivity of administering products and services to our YBS customers. Therefore, it would creat greater cost and administrative burdens to achieve the same favorable outcomes that we experience now.
     Our mission to all our costumers, is to provide the best opportunities for them to succeed. Sound and constructive credit and related services to YBS farmers and ranchers and to all Ag borrowers accomplishes that mission. The well meaning intention of this proposed rule would not accomplish the agency’s intention to improve services to YBS borrowers, but would do the opposite. The financial and time consuming burden created would severely effect our ability to serve YBS and the agriculture community.
    I applaud your efforts and acknowledge your efforts and share common goals relating to the YBS program. But I am concerned with excessive planning and administration getting in the way of implementing and doing. This is goal we both have.
  
Sincerely submitted,
Ted Andrew, Western AgCredit Board Member
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