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Return to Comments
Standards of Conduct--Reproposed NPRM
Type: Regulation
Federal Register Document Type: Reproposed
Description:
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
Mr. Barry F. Mardock
Farm Credit Administration
1501 Farm Credit Drive
Mclean, VA 22102-5000

Dear Mr. Mardock,

I am a member of the Board of Directors of High Plains Farm Credit, ACA.  I am taking this opportunity to comment on the proposed reg. RIN 3052-AC44 standards of conduct.  Thank you for making the comment period available to me.

My term on the board began in July of 2013.  So it was fairly recent that I made the decision to serve on the board.  I have great concern that this proposed regulation is very far over-reaching.  If the regulation is implemented I would suggest that my decision to serve on the board at High Plains Farm Credit would be different. 

In the sparsely populated farming communities of western Kansas obtaining prior approval for transactions for the normal course of business doesn’t make any sense.  Any attempt to provide oversight to these activities are going to bog down a process of conducting business and make it so farmers and ranchers are un-willing to serve on these boards.  There is not an abundance of willing directors to begin with, and producers will gravitate towards not serving to avoid the regulation.

I also feel that the definition of “family” in the proposed reg. is very broad.  It is opened ended and impossible to enforce.

I realize that my comments are brief and to the point.  I just want to make my voice in regards to this proposed regulation heard, as I feel that it is very damaging to the Farm Credit system.  It would make conducting business by a director difficult and would become a large disincentive to serve.  Thus reduce the pool of candidates for board positions even more, eventually having a real negative impact on the entire system.

Thanks for the opportunity to comment.

Thanks,

Matt Thielen
High Plains Farm Credit, Director

Dorrance KS


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