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Letters to RegulatorsFCA Regulatory Development ProgramSeptember 15, 2002 Mr. Stephen G. Smith Dear Mr. Smith: Thank you for your recent letter inviting ICBA to comment as part of FCA's survey to interested parties on FCA's efforts to measure the performance of its Regulatory Development Program. Survey questions evaluate FCA's regulatory actions taken since October 1, 2000. The Independent Community Bankers of America (ICBA) is the nation's leading voice for community banks and the only national trade association dedicated exclusively to protecting the interests of the community banking industry. We are pleased to provide our comments to FCA's survey, which are attached to this letter. In general, we appreciate FCA's stated interest in promoting safety and soundness within the Farm Credit System and believe this should continue to be the key priority for FCA as it promulgates future regulations. We believe that FCA has, on various occasions, proposed regulations whose chief aim was to expand the lending powers and activities of the Farm Credit System while only marginally considering safety and soundness issues. We believe FCA's future regulatory agenda should avoid expanding FCS powers and focus primarily on safety and soundness issues and ways that FCS institutions can work with commercial banks to provide farmers and ranchers with enhanced access to credit. Such an approach would be more appropriate, given that the FCS is a government sponsored enterprise, and FCA should seek to enhance financing to farmers and ranchers while avoiding displacing private sector, taxpaying, community banks - whose presence is vital to healthy rural economies. Thank you for the opportunity to comment. If you have questions regarding ICBA's remarks, please contact Mark Scanlan, director of agricultural finance, at (202) 659-8111 or mark_scanlan@icba.org. Sincerely, Ken Guenther
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