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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. Mardock-

Please see the forwarded message below.  Tim Benoit asked me to verify that you had received his letter.  We have not seen it posted on the website and were concerned that you did not receive it.  Please confirm the receipt of this email with a quick reply.



 Kevin D. Swayne
Senior Vice President - Chief Financial Officer | High Plains Farm Credit | 2905 Vine St. | Hays, KS 67601
phone: 785.625.2110 | fax: 785.625.4309 | mobile:  785.656.1474

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



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


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


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 take this position as a director very seriously, as we all do.  Keeping in mind the stockholders' best interest, and looking forward to having quality
individuals serving on our board, a regulation as proposed would be detrimental to both.    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