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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
 May 19, 2014

Mr. Barry F. Mardock
Deputy Director, Office of Regulatory Policy
Farm Credit Administration                            
1501 Farm Credit Drive                                 
McLean, VA 22102-5000
RE:      RIN 3052-AC44: ANPRM Standards of Conduct;
            Published in the Federal Register on February 20, 2014Dear Mr. Mardock:
As member of the Board of Directors (Board) of High Plains Farm Credit, ACA, I appreciate the opportunity to comment on the Farm Credit Administration’s (FCA) advance notice of proposed rulemaking (ANPRM) with respect to standards of conduct.   

There are parts of these proposed rules that just reach too far.  With all these rules it will make it too difficult to find good board members to serve on the board as it interferes with their own day to day efforts in operating their farming business to such an extent that they would not be able to justify the excess time and inconvenience.

Thank you for the opportunity to comment.  I take my responsibility as a Farm Credit directors very seriously and discourage any regulatory changes that may impede our ability to meet our stockholders’ financial needs while maintaining excellent customer service and financial stability.

Jon Herrmann