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Return to Comments
Conservators, Receivers and Bridge System Banks
Type: Regulation
Federal Register Document Type: Proposed
This rulemaking would update certain FCA regulations in part 627 to reflect changes made in the Agricultural Improvement Act of 2018 (2018 Farm Bill). This rulemaking would also make conforming amendments to other regulations to clarify that they do not apply to bridge System banks, which are governed under new section 5.61C(h) of the Farm Credit Act of 1971, as amended.

Text of Comment Letter

RE: Document FCA-2022-0005-0001  FRN 2022-05999 Public Comment

The Farm Credit Administration (FCA) has a goal to ensure that Farm Credit System institutions and FArmer Mac are safe, sound and dependable sources of credit and related services for all creditworthy and eligible persons in agriculture and rural America.  This commitment is taken seriously by Congress which looks to this independent agency for policies for regulatory quality.

The proposal to revise certain Part 627 etal regulations should have clear objectives and frameworks for implementation to ensure that, if regulation is used or revised, the economic, social and environmental benefits justify the costs, distributional effects are considered and the net benefits are maximized.

In the past, FCA has clarified numerous provisions of the capital regulations and corrected technical areas.  This type of agency action seems to reduce the burden of stakeholders by simplifying certain requirements and changes.  However, adhering to principles of open government, including transparency and participation in the regulatory process to ensure that regulation serves the public interest rather than revising the regulations for no apparent reason.

These proposed changes, especially those in 627.10 and 627.20 appear to establish mechanisms and institutions to actively provide oversight of regulatory policy procedures and goals, support and implement regulatory policy and over time will foster increased regulatory quality.

Conducting systematic program reviews of the stock of significant regulation against clearly defined policy goals, including consideration of stakeholder and agency costs and benefits, to ensure that regulations remain up to date, cost-justified, cost-effective, technology enhanced and consistent is always in order.  The proposed rule modification and changes by the Administration should be considered for approval.


Bruce Grimm

Silvana WA