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.