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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
June 18th, 2014

Mr. Barry F. Mardock
Deputy Director
Office of Regulatory Policy
Farm Credit Administration
1501 Farm Credit Drive
McClean, Virginia  22102-5090

RE: Proposed Rule - RIN3052-AC44

Dear Mr. Mardock:

    As a director with 1st Farm Credit Services of IL. since 1986 I take seriously the system's expectations for ethical conduct. I feel that the new disclosure requirements are overly burdensome to current and future directors. 
    My farm operation is a relatively simple one.  I produce corn, soybeans, and feeder calves.  I have 5 landlords and I sell my grain at 4 different grain elevators.  I buy most of my inputs from 2 farm supply businesses.  I buy feed and fence posts from a family owned business whose owners also farm. I recently bought a bull from another local farmer.  I hire 2 different neighbors to bale my hay crop. Another neighbor often hauls my grain to bin sites or local elevators.
    Since I have no insight into who Farm Credit loans money, I have no idea whether any of the many people that I deal with are FCS clients.
    I understand that in the future it would be incumbent on a director to ask for that information then disclose it to our S.O.C. official.  Such intrusions into these relationships are unwarranted and could be quite damaging in some cases, as the asking itself has a weight beyond the moment.
   We  expect a lot from our directors.  We expect  them to put Farm Credit meetings ahead of their farming responsibilities and family activities for 20 to 25 days a year.  Travel for overnight stays and 2 or 3 day meetings are expected.  Personal and family relationships must be disclosed.  Directors' loans are subject to greater scrutiny.
    It comes as no surprise that a chronic complaint from the nominating committee is the difficulty of finding suitable candidates who will agree to serve under the regulations and strictures that are currently in place.  Adding another layer can only make this more problematic.
   Farm Credit needs wise, conscientious, and highly ethical people as board members.  We can't expect people with these qualities to commit to rules that may seem designed more to trip up people for minor errors and omissions than to address serious ethical violations.
   We will scare away the very people that we most need.   
   Thank you for the opportunity to air my concerns.

Rod McGaughey
director 1st Farm Credit Services of Illinois