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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 11 2014
Mr. Barry Mardock
Deputy Director
Office of Regulatory Policy
Farm Credit Administration
1501 Farm Credit Drive
McLean, VA 22102-5090

Dear Mr Mardock

I was planting crops so I appreciate the extension on the timeline to
comment on the FCA's proposed rule regarding Standards of Conduct.
Standards of conduct are a serious topic needing careful attention, but
the FCA's proposal fails to understand the realities of business and
will be harmful in the end.

As a director at CoBank I find the requirements in the disclosure
section to be unreasonable and unworkable. In my own farm I do business
with my local coop elevator dozens of times a month. The products
needed and timelines change with the weather and are ordered on short
notice. This is just one of the CoBank customers I do business with.
There are four others. As a director I have no role in approving loans
nor terms of loans for any of them.

The added burden on CoBank, the customer and myself for no added safety
is unreasonable.

A further complication, In a time when we are searching for a diversity
of candidates to serve on Farm Credit boards it is not helpful to make
the job appear unreasonably burdensome. Rules like this will
immediately sort out anyone who does business with a member or
customer. I don't think that was a goal of the FCA.

Thanks for your consideration. Just Kill the rule.

David Kragnes
Director - CoBank
10600 60th St. N
Felton MN
218 236 0857

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