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Return to Comments
Investment Eligibility Amendments Proposed rule
Type: Regulation
Federal Register Document Type: Proposed
Proposed Amendments to 615.5140 (b)

Text of Comment Letter

Dear FCA

Please find attached a PDF and Word version of ICBA’s Comment Letter on FCA’s proposed rule regarding the purchase and sales of the guaranteed portion of USDA loans.

RIN: 3052-AD35

Federal Register Number: 2019-19917 

Organization; Funding and Fiscal Affairs, Loan Policies and Operations, and Funding Operations; Investment Eligibility

Please note – I tried submitting this comment letter online at the website per the instructions in FCA’s proposed rule. However, there was no “Submit Now” button. This has happened to me several times in filing recent comment letters to the FCA. Therefore, this time I called the ‘Help Line’ at and asked why this was occurring. I was told that “FCA has failed to make it possible to submit comments online at the website (”
I believe this is unfair to the general public in that recent FCA proposed rules state the public can file online at the website but that is not true. This may well lead to FCA suppressing the ability of the public to file comments with the agency and raises questions why the FCA has been preventing the public from commenting on the official government’s website even though  FCA states this is an option.  If this is a glitch that FCA is unaware of, and since this happened on several occasions, then FCA should reopen the comment period for a period of time, say 30 days, and correct this submission issue giving the public enough time to be made aware of the issue and submit via in accordance with FCA’s proposed rule’s stated submission options.


Mark Scanlan

Mark Scanlan

Senior Vice President

Agriculture & Rural Policy

Independent Community Bankers of America

1615 L Street NW, Suite 900

Washington, DC 20036

P: 202-659-8111

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