June 18, 2014
Mr. Barry F. Mardock
Office of Regulatory Policy
Farm Credit Administration
1501 Farm Credit Drive
McLean, Va 22102-5090
Dear Mr. Mardock:
Thank you for the opportunity to comment on FCA's proposed rule regarding Standards of Conduct.
As a director of High Plains Farm Credit, I find that the disclosure requirements in the Conflicts of Interest section of the proposed rule to be entirely inappropriate and completely unrealistic. The proposed rule ignores my association's cooperative structure and the way I do business in my own farming operation. I routinely do business transactions with a number of people, some may be High Plains customer's. even in cases where I Know I'm dealing with an association customer, there is no conflict of interest since directors at High Plain Farm Credit do not have any role in approving loans or the terms of loans.
Requiring me to disclose any transaction with a customer, even when I know I am doing business with a customer, is not realistic. The number of transactions I have in the normal course of my business means that both High Plains and I would spend an enormous amount of time with extra paperwork with absolutely no impact on any conflict of interest. Also the proposal might discourage qualified individuals from serving on their FCS association boards.
I urge the FCA to revise the proposed rule substantially prior to issuing a final rule. I would also like to offer my support for the comments submitted by CoBank. Thank you for your consideration.
High Plains Farm Credit