Mr. Barry 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, 2014
Dear Mr. Mardock:
As a member of High Plains Farm Credit board, I appreciate the opportunity
to comment on the Farm Credit Administration's ANPRM with respect to standards of conduct. I
have read our CEO's letter and agree in its entirety.
This was discussed at length at our regular board meeting. Our staff knows
we, as board members, like to keep on the forefront of emerging issues. I will be brief and to the
point on the issues I would like to comment on.
Conflicts of Interest
To require directors to disclose any transaction in the ordinary course of
business would be impossible to comply with. I feel there would be very few, if any, stockholders willing
to become board members under this type of scrutiny.
In the agricultural sector businesses are so intertwined, our day to day
business would be interrupted to the point of not wanting to deal with this type of regulation. Stockholders
that are doing business with board members (such as fertilizer dealers and grain elevators) would be
apprehensive in doing business with that member, knowing that every transaction is being scrutinized.
Standards of Conduct Official
To place the responsibility of this type of regulation on an employee would
be totally inappropriate. The SOC official can educate, investigate, and take appropriate action. But to hold
them responsible for the actions of others?
I truly wonder how difficult it would be to fill SOC official position.
Directors/Employees- Prohibited Conduct
I am an independent agricultural producer. The thought of a SOC official in
the middle of any, and possibly every, business transaction I make would be enough to disinterest me (and most everyone I
know) from being on a Farm Credit Board.
I got in late tonight from planting crops. I would like to elaborate more
but, would also like to rest. I hope you understand my points and appreciate you taking the time to read my response.
Tim Benoit, Chairman of the Board
High Plains Farm Credit