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Return to Comments
Capital - Tier1/Tier 2 Regulatory Capital Framework Proposed Rule
Type: Regulation
Federal Register Document Type: Proposed
Request that Board approve a new part 628 to FCA's regulations and amend parts 607, 614, 615 and 620 to modify the regulatory capital requirements for System Banks and associations

Text of Comment Letter
Dear Sirs,

We have been a member of Capital Farm Credit for many years. We would hope that before you make effective the new rules concerning the Patronage Program you would look at these proposals from the viewpoint of the current, as well as potential, members.

Most of us are not large agricultural providers or wealthy individuals. We pay attention and look forward to our turn at receiving these dividends, as was promised when we signed up. We ourselves, after waiting our 5 years, were at the top of the list. Now, you are telling us that it will be 5 more years. What will you do then, change it again? Many companies, even individuals, may not survive 10 years. What good will it be to them then?

We believe that current membership should be "grandfathered in". Change the rules, if you must, but do that for the new members, but they have to know up front that they won't get their dividends for 10 years. Then those of us who have stayed with you won't feel that we have been "slapped in the face."

You use patronage dividends strongly in your promotions. Do you intend to clearly state how long the wait time will be to potential members?

We strongly protest the unwarranted change in the Patronage Program. Should you wish to discuss this further, please do not hesitate to contact me.


Terry Bishop
Presidio Valley Farms, Inc.
PO Box 818
Presidio, TX 79845