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Return to Comments
Standards of Conduct--Reproposed NPRM
Type: Regulation
Federal Register Document Type: Reproposed
Revise existing standards of conduct regulations in Subpart A, Part 612, and consider a more principle-based rule to facilitate a sound standards of conduct program at System institutions.

Text of Comment Letter

I am not in favor of changing the rules of conduct. Our associations are using the current rules effectively. The combination of high ethical and moral standards along with peer scrutiny for the board and I staff have served us well. We don't need another level of bureaucracy to our organization with the addition of a Standards of Conduct officer and the supporting staff. We struggle to keep our association lean and efficient for our members and certainly don't follow the model of our federal government inefficiencies.

Our board regularly discuss standards of conduct compliance topics as part of our ongoing board education training. In my 9 years as a board member I have not observed or heard of a conflict of interest issue in our association. The conflict of interest issues that I have heard about in other associations were so blatant that additional regulations would not have made a difference. You cannot regulate morals and ethics. Fortunately I have only heard of a couple instances of standards of conduct issues and they were given during FCC training sessions.

In conclusion I believe in the old adage, if it isn't broke don't fix it. We have rules in place that effectively give guidance for standards of conduct without being over burdensome.

Keith L. Roberts
Ag Credit ACA