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Return to Comments
Collateral Evaluation Rule
Type: Regulation
Federal Register Document Type: Proposed
Appraisal Reporting Requirements

Text of Comment Letter
July 15, 2021

Mr. Kevin J. Kramp
Director, Office of Regulatory Policy 
Farm Credit Administration
1501 Farm Credit Drive
McLean VA 22102-5090

Re:  Proposed Rule-12 CFRPart614-RIN 3052-AC94;
       Collateral Evaluation Requirements;
       86 Federal Register 27308-27323

Dear Mr. Kramp:
I appreciate the opportunity to comment on the Proposed Rule regarding Collateral Evaluation Requirements.  I have reviewed the responses from the Farm Credit Council and GreenStone Farm Credit Services and am in complete support of their comments.
In my opinion, the Proposed Rule would very significantly increase the cost and complexity to Association operations without corresponding benefits.  Such costs are both “out of pocket” as well as large amounts of increased costs of time and effort.  The directors and leadership of GreenStone take ultimate care to ensure that internal controls and practices are appropriate relating to the risks of the organization.  The Proposed Rule is extreme in the resulting added costs and complexity, with adverse impact to the customers of the organization.
I respectfully request that the Proposed Rule be withdrawn so FCA and the Farm Credit System can have meaningful joint discussions on all of the key issues surrounding collateral evaluation matters.  Again, thanks for the opportunity to respond.

Eugene College
12805 Hamilton Street
Omaha NE 68154

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