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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
Mr Barry F. Mardock
Deputy Director
Office of Regulatory Policy
Farm Credit Administration
1501 Farm Credit Drive McLean, VA 22102-5090
Dear Mr, Mardock:
  Thank you for the opportunity to comment on FCA's recent proposed Standards of Conduct rule. I believe directors of the Farm Credit System should hold themselves to the highest standards of conduct and display the highest of ethical behavior. I believe we have rules and standards in place that provide and direct that behavior. I believe the new proposed rule on Standards of Conduct is unrealistic and very hard to comply with. I believe in addition, to comply with the new rule would be an invasion of privacy of those people I do business with. I would have to inquire if they have loans with the system.
  If we are forced to comply with this proposed rule, I fear that we will lose many good directors , and potential directors, who look at the rule and say it is too difficult to comply with, and give up their seats, or simply decide not to run for a directorship in the first place.
   My husband and I do a number of transactions with Northwest ACA and CoBank customers. Would I have to ask my husband to inquire about wether or not they do business with Farm Credit before he completes every transaction? I think he will tell me to quit before he would agree to that!
  I urge the FGCA to revise the proposed rule substantially prior to issuing a final rule. I would also like to offer my support for the comments submitted by CoBank and the Farm Credit Council. Thank you for your consideration.
Mary E Fritz, Chairman of the Farm Credit Council and CoBank board member