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Letters to Regulators

Proposed Changes to the Farmers Notes Program

November 24, 2004

Mr. Robert Coleman
Director, Regulation and Policy Division
Office of Policy and Analysis
Farm Credit Administration,
1501 Farm Credit Drive,
McLean, Virginia 22102-5090

Re: Funding and Fiscal Affairs, Loan Policies and Operations, and Funding Operations; Investments in Farmer Notes - RIN 3052-AC23

Dear Mr. Coleman:

We are sending this letter on behalf of the Independent Community Bankers of America (ICBA)1 and our community bank members. Our comments pertain to the Farm Credit Administration's (FCA) request for public comments in regard to proposed changes to the so-called Farmer Notes program.

Background: Farmer Notes Rulemaking

The FCA has asked for responses to the Farmer Notes proposed rule, which it claims will make affordable credit more available to farmers by enabling Farm Credit System (FCS) associations to provide additional funding and liquidity to non-System lenders and businesses that extend agricultural credit in the normal course of business. The agency states the proposal is therefore designed to increase the cooperation between System and non-System financial institutions.

The FCA originally paired the farmer's notes proposal with the Other Financial Institutions (OFI) proposed rule. As noted in our comment letter on the two issues in December 2003, we supported the modifications to the OFI program in an effort to improve the program's funding and access for commercial banks while recognizing that the Federal statute may need to be updated to make the OFI program more useful to banks as a funding source. But, we also noted our serious concerns with the proposed changes that would broadly expand the Farmer Notes program, and we questioned the agency's authority to make such sweeping changes.

While there have been a couple of reviews of the OFI program over the last decade, the same is not true for Farmer Notes. Furthermore, the OFI program has specific authorizing language in the Farm Credit Act, but the Farmer Notes program does not.

As stated previously, ICBA believes the FCA is proposing to re-invent an unused lending program and inappropriately label it as an investment program. FCA doesn't have the authority to create an expansive new retail business-lending program that hasn't been authorized by Congress. Further, the program shouldn't be called an investment program when it really isn't. If it walks like a duck, quacks like a duck and acts like a duck; it is a duck. FCA should be more forthcoming and call the program what it is - a new lending program to expand FCS powers.

Additionally, the Farmer Notes program presents many troubling implications as discussed below. Therefore we strongly recommend that FCA drop the Farmer Notes program or revise the proposal to ensure the FCS can only engage in Farmer Notes by engaging in loan participations with commercial banks.

General Comments

In the original Farmer Notes proposed rule adopted by FCA on August 11, 2003, the FCA suggested "substantive" and major changes to the so-called "Farmer Notes" program. ICBA strongly opposed those changes. That proposal would have made all entities that routinely extend agricultural credit in the normal course of their business eligible to participate in this newly revised program, including "merchants and all types of creditors" and farm-related businesses, which would be able to sell Farmer Notes to FCS associations. This would have been broader than the current Farmer Notes program that applies only to "cooperatives and private dealers".

Currently, community banks supply a significant portion of the credit to Main Street businesses, including the financing activities that these businesses are involved in. Allowing the FCS to expand into this lending area will lead to unfair competition with banks. Since community banks depend on Main Street businesses for a substantial portion of their lending business, the FCS, with its tax and funding advantages as a government sponsored enterprise (GSE), should not be allowed to enter new areas of lending that crowd out the private sector.

Under the proposal, both long-term and short-term loans would be eligible to be financed by FCS associations, not just those with short- and intermediate-term lending authorities. We question the need and justification for expanding the program to include long-term credit.

FCA Did Not Receive "Many Comments" on Farmer Notes

In reviewing the rulemaking process on OFIs, which began in April of 2000, we have found very little mention of Farmer Notes throughout the review process, contrary to what FCA suggested in the proposed rule. There was no mention of Farmer Notes in the Advanced Notice of Proposed Rulemaking (ANPRM) or the comments received in response to it. With respect to the public meeting FCA held on August 3, 2001, the notice for the meeting only mentioned OFIs and "suggestions for other types of partnering relationships between System and non-System lending institutions". Yet, FCA's Farmer Notes proposal suddenly, unexpectedly, and dramatically expanded this scope to business retailers in addition to non-System lending institutions.

The FCA's proposed rule on Farmer Notes states, "Many System and non-System commenters encouraged us to promote other arrangements, in addition to the OFI program, that make it easier for Farm Credit banks and associations to provide funding and liquidity to non-System agricultural lenders" (emphasis added). Yet, of the testimony presented as part of the Des Moines public meeting, only one witness mentioned Farmer Notes, very briefly, and only one mentioned FCS investment authorities in general.

Not until the proposed rule issued by FCA on August 11, 2003, were there any specific proposals on Farmer Notes and an opportunity to provide specific comments. We also note that of the 105 letters FCA received as a result of the proposed rule, almost all of the comments opposed Farmer Notes, showing a vast majority of the public, in excess of ninety percent, did not want FCA to proceed with Farmer Notes. This raises obvious questions which include: 1) What is FCA's true rationale for even including Farmer Notes since there has never been any real support for this program from the public?; and 2) Is the FCA truly responding to the comments received from the public given the public's overwhelming opposition or are they just pandering to the FCS's interest to expand its lending powers, regardless of the public's input?

We also question how the FCA can state with any credibility that this rulemaking involving Farmer Notes started over four years ago and has already included a public meeting. Such statements are simply not factual. The early phases of the rulemaking dealt solely with the OFI provisions, not Farmer Notes. And the reason the OFI changes took four years to implement was because the FCS wanted to bottle up the changes as long as possible.

Comments on Farmer Notes Proposal

Advanced Notice of Proposed Rulemaking

On April 20, 2000 the FCA issued a notice of proposed rulemaking that asked the pubic about ways to improve the funding and discount relationships between FCS banks and OFI's. Specifically, the ANPRM stated, "Are there other regulatory changes we could make or alternatives not addressed above that we should consider to improve a System bank's ability to serve an OFI and its agricultural customers?"

There is nothing that we read in the ANPRM that looks at issues outside the scope of OFIs and their funding. Yet, FCA amazingly claims that commenters responded with a "broad array of suggestions on various ways that System and non-System agricultural lenders could cooperate to extend credit to agriculture and rural America". In our review of the comments responding to the ANPRM, we found no specific mention of the Farmer Notes program from any commenters. The comments dealt entirely with the OFI program and ways to improve and enhance the performance of that program. We did not see any suggestion for expanding or modifying the Farmer Notes program, contrary to what FCA has stated.

FCA Public Meeting- OFI's

Following the ANPRM, the FCA announced it was holding a public meeting for interested parties to provide input regarding OFI's and to "seek your suggestions for other types of partnering relationships between System and non-System lending institutions that would increase the availability of funds to agriculture and rural America".

The meeting was held on August 3, 2001 in Des Moines, Iowa. Two individuals presented comments on behalf of ICBA, along with eight other individuals representing other financial entities and the FCS. After reviewing all the comments presented at the public meeting, we found only one individual that even mentioned Farmer Notes; one that mentioned investment authorities in general; and one that mentioned alternatives to provide funds to non-System lenders.

The one commenter that mentioned Farmer Notes was a non-bank OFI and stated, "I would recommend that FCA allow OFIs to be financed with all of the modern lending tools available, including syndications, specialized loan facilities, portfolio purchases, purchases of Farmer Notes, participations and so forth". This comment was suggesting ways for OFI's to better utilize FCS funding to provide financing to agriculture, not a way for FCS associations to expand their lending authorities. This statement suggested Farmer Notes should be part of the OFI's authorities, not a separate authority that would circumvent commercial banks.

The commenter that mentioned investment authorities was the Farm Credit Council (FCC), which stated, "For instance, it has been suggested that current interpretations of the existing investment authorities of the System are limiting institutions' ability to fully serve their customers". Obviously, the FCC wants to expand FCS powers as broadly as possible, with as little transparency as possible, with as little public accountability as possible and with no regard to private sector lenders already serving the market place. But logic does not reasonably suggest that FCA should disregard all the other public comments in favor of the FCC's comment.

One commenter mentioned alternatives to provide funds to non-System lenders, stating, "These alternatives can be helpful to commercial banks that lend in rural communities as well as agriculture. This includes working with commercial banks that lend to rural communities and agriculture." These comments are directed toward finding ways to allow commercial banks to work better with the FCS by providing more opportunities for funding. While the Farmer Notes proposal from FCA could help address this need, it will do more harm than good if the program is as broad in scope as currently proposed in allowing FCS lenders to completely bypass commercial banks in extending credit. It will only lead to the FCS providing additional funding to Main Street businesses for their lending activities, while completely bypassing commercial banks that currently are meeting those credit needs. This is not a way to create better cooperation and partnerships with commercial banks as FCA suggests.

Based on the actual comments made, we are mystified at the conclusions FCA formed from this public meeting regarding Farmer Notes. For instance, the current Farmer Notes proposed rule background states, "Many System and non-System commenters encouraged us to promote other arrangements, in addition to the OFI program, that make it easier for FCS banks and associations to provide funding and liquidity to non-System agricultural lenders. Many commenters expressed their desire for more flexible and informal arrangements between FCS and non-System agricultural lenders."

First, we can not see how FCA took the comments presented during the public meeting and determined them to mean non-System lenders wanted to see the FCS given an additional lending tool that would allow direct lending to the current business retail customers already served by commercial banks. No logical reading of the comments could lead to such a conclusion.

Second, the Farmer Notes program as proposed would not make it easier for non-System lenders to receive funding from the FCS. It would, however, make it easier for the FCS to engage in additional lending activities with commercial businesses and consumers without working with commercial banks to do so. This seems to be in direct conflict with the stated purpose of the Farmer Notes proposed rule. In actuality, the FCA is using rhetorical statements about "partnering" and "cooperation" when there is no requirement to do so. FCA is knowingly designing a program with questionable legal underpinnings to implement a new lending program for FCS lenders that has no basis in the statute and no references in the legislative history of the Act.

August 11, 2003 Proposed Rule

FCA notes that it received 111 comments on the August 2003 proposed rule and of those, 105 addressed issues related to Farmer Notes. FCA goes on to state, "System commenters supported the proposed rule while all non-System commenters opposed it". Of the nine System commenters, only six specifically addressed the Farmer Notes issue. The 99 non-System commenters opposed the Farmer Notes program as proposed by FCA. This is an overwhelmingly strong showing of opposition to this proposal, yet FCA decided to go ahead with this program in a way that diminishes the lending portfolios of community banks. Therefore, we believe it is incumbent upon the FCA to work with the banking industry to revisit this proposal in order to withdraw or rewrite the regulation so that it meets the stated purpose of fostering greater partnering between System and non-System lenders.

System Comments to 2003 Proposed Rule

FCA notes that System commenters believed the revisions to Farmer Notes would strengthen the cooperation between System and non-System lenders and increase the flow of credit to agriculture. We argue that this will clearly not be the case if the program only provides more opportunities for the FCS to compete with commercial banks, which will happen unless FCS entities are required to work with commercial banks when engaging in the Farmer Notes program. Regarding the increased flow of credit, this will not be the result if the program is serving no new businesses. We can see no new customers that will be served by Farmer Notes, nor has FCA suggested how new customers not currently being served would suddenly receive financing under the program. Rather, it will only allow the FCS another avenue to unfairly lure away current customers of commercial banks through cherry picking activities.

September 14, 2004 Revised Rule

We appreciate the FCA tightening the earlier proposal by clarifying that FCS associations will only be allowed to invest in notes from farmers, ranchers, aquatic producers or harvesters, and farm related businesses that are eligible to borrow from the FCS. However, this still relies on the current weak definition of who is a "bona fide" farmer.

If FCA moves forward with this proposal and since this is supposed to be an "agricultural investment" program, we believe it would be appropriate for the definition of a farmer, for the purposes of this program, to be tightened to include individuals who are actively engaged in farming or will be within a two-year time period. Ensuring that "farmers" are actually involved in agricultural production is important given the expansive nature of this new lending program. In addition, while FCA suggests that because the proposal includes "financial institutions" there will be greater cooperation between System and non-System lenders, we remain totally unconvinced. The rule contains absolutely no provisions that will require the FCS to partner and participate with commercial banks under the Farmer Notes program - which is what would be necessary to achieve the goals of partnering and cooperation among System and non-System lenders. Furthermore, because there are no limits on the amount or percentage of Farmer Notes business the FCS can do with non-bank entities (retailers), the FCS can completely bypass commercial banks and partner solely with the commercial banks' customers.

To address this issue, the FCA should revise the rule to remove part (2) of 615.5172(a) that would allow entities whose primary business is selling agricultural supplies, machinery, equipment, and services to sell Farmer Notes directly to FCS entities. As FCA states in the proposal: "The primary business of financial institutions is to extend credit. In contrast, merchants primarily sell goods and services, while providing credit to their customers as a supplemental but integral part of their overall business." This is a major flaw in FCA's proposal. The rule should be revised to require the FCS to work with commercial banks as part of the Farmer Notes program, since banks are totally dedicated to the business of providing credit to retailers, merchants, and consumers.

Furthermore, it seems that all of the goals of this program, as stated by the FCA, could be achieved through loan participations with banks. Participations help improve funding and liquidity by allowing banks to partner with the FCS to fund loans, while allowing the FCS to participate in loans that they would otherwise not be eligible to make or loans that are outside of their territory. We request an explanation from the FCA as to how the agency envisions the Farmer Notes program operating as compared to typical loan participations. It seems that it would be very similar to the current loan participation process, making the proposed rule completely unnecessary. Therefore, we question why the Farmer Notes program is even being proposed.

FCA states that FCS institutions hold investments for two reasons: to maintain liquidity and manage market risk; and to advance their public policy mission of financing agriculture. While the claim is that Farmer Notes represents the latter type of investment, we question how this is advancing the FCS policy mission if Farmer Notes simply displace financing already provided by commercial banks. We maintain our position that this is really just a lending program, not an investment program.

The FCA claims "Farmer Notes … fosters cooperation between the FCS and non-System agricultural lenders". Again, there is nothing to require participation with banks, so FCS can bypass banks one hundred percent of the time. Banks often do not work more closely with FCS lenders because the FCA does not require more FCS activities to be done in partnership with banks through participations. There is no means to achieve cooperation unless FCA requires the FCS to partner with banks when participating in the Farmer Notes program.

FCA response regarding Congressional authority for Farmer Notes

The FCA declined ICBA's request to consult with Congress about revisions to the Farmer Notes regulation and noted "express authority delegated by Congress under sections 2.2(10), 2.12(18), 5.17(a)(9), 7.6(c), and 7.8(b)". In reviewing these Farm Credit Act statutes, we found no language that could be construed to allow an expansive lending program for FCS entities such as the Farmer Notes program.

For example, 2.2(10) and 2.12(18) are identical and apply to PCAs and FLBAs respectively. They state that associations "shall have the power to invest funds of the association as may be approved by the Farm Credit Bank under regulations of the FCA and deposit the current funds and securities of such with the Farm Credit Bank, a member bank of the Federal Reserve System, or any bank insured under the Federal Deposit Insurance Corporation, and may pay fees therefore and receive interest thereon as may be agreed." We fail to understand how this statutory language can be manipulated to allow FCS associations to provide financing for the lending activities of retail businesses. This language does not imply that FCA can invent lending programs and call them investment programs.

Section 5.17(a)(9) states FCA shall "prescribe rules and regulations necessary or appropriate for carrying out this Act". This is hardly language that could lead to allowing the creation of a lending program like Farmer Notes and such an interpretation is fanciful as well as implausible. Sections 7.6(c) and 7.8(b) deal with mergers of associations and transfer of lending authorities. Again, we see no clear language suggesting FCA's regulatory authorities allow the creation of new, unauthorized lending programs just because FCA labels them investment programs.

Authority to Examine and Monitor Farmer Notes

We not only question the legal authority of the FCA to develop broad new lending programs like Farmer Notes, we question whether FCA can actually monitor and regulate these "investments" if the program is implemented. There is nothing in the proposal outlining how FCA will examine the notes that are purchased.

In fact, in other FCA regulatory proposals such as the YBS, OFI, and Preferred Stock regulations, FCS representatives have argued that the FCA does not have the authority to impose regulatory and examination requirements. For example, an August 3, 2004 comment letter from the FCC on the preferred stock proposal stated, "We believe …any action by FCA to attempt to regulate or otherwise restrict the issuance and retirement of capital stock…is simply not authorized". FCC has made similar statements on challenging other FCA examination authorities, raising the inevitable prospect that FCA will face significant resistance in monitoring and examining Farmer Notes to ensure those notes are truly agricultural in nature and involve real, bona fide farmers. FCA has also not offered any substantive assurances that Farmer Notes information will be transparent and available to the public.

FCA examiners will have difficulty regulating and examining FCS entities that resist compliance with the program. FCS entities will push the boundaries of the program as wide as possible without regard to the true mission of the System as set forth in the Farm Credit Act. The rule, as proposed, lacks clear provisions of how the FCA will examine and regulate this program to ensure it is narrowly focused.

Congressional Review

In our previous comment letter, we suggested the FCA should consult with Congress regarding this proposal since it represents the creation of an additional lending program for the FCS. FCA declined this request and noted that all proposed rules are submitted to Congress for a 30-day review period. While this is true, Congress assumes that the FCA is acting within its authority. When the FCA wants to go beyond its authority, as in this case, it needs to ask Congress to change the Act.

The fact that this proposal allows FCS lenders to circumvent commercial banks and directly pursue lending to current customers of commercial banks is not clear to Congress and much of the public due to FCA's misleading rhetoric about "partnering" and "cooperation". Unfortunately, this is not mentioned in the proposal sent to Congress, so there should be a hearing to give members of Congress a clear picture of the true nature of this program.

Farmer Notes as "Investments"?

The FCA designates Farmer Notes as "agricultural investments", but we question how this can be the case when the proposed rule allows for collateral that is often not agriculture in nature to collateralize Farmer Notes. If the notes are not backed by agricultural collateral, we see no rationale for labeling them as agricultural investments. This brings into question the true purpose of the credit to be offered through the Farmer Notes program. FCA notes that the program will allow FCS associations to act as a source of funding and liquidity for non-System agricultural lenders, including "small local entities that sell agricultural supplies, equipment, machinery, other capital goods, and household appliances to farmers and ranchers on credit".

We appreciate the FCA clarifying that the Farmer Notes program will not be used to provide consumer credit. The provision added to 615.5172(b) to expressly restrict consumer credit is a good step in tightening this program and needs to remain as part of the rule. However, we question how FCA can state that Farmer Notes would not be for the purpose of providing consumer credit, but then state that FCS would fund "small local entities" (i.e. retailers) that sell goods to their customers "on credit", which does indeed suggest the financing of consumer credit. Therefore, Farmer Notes should be restricted to loan participations with commercial banks.

Other capital goods and household appliances are not agricultural collateral. It is illogical to claim that simply because the end consumer may be a farmer, that this is an "agricultural investment" when the product(s) on which the Farmer Notes are based have nothing to do with agricultural production. For example, just because a washer and dryer are sold to someone who lives on a farm instead of someone who lives in New York city, does not make this sale an "agricultural investment". To argue that it does is simply not credible.

We believe the FCS can already meet the needs and purposes stated by using existing authorities to work with commercial banks, such as loan participations. It appears the only reason for this program is to allow the FCS to go after commercial bank customers using this new program and its expanded lending powers. This is truly not the way to encourage cooperation and partnering between the FCS and banks.

The fact that the initial credit is being provided to businesses rather than farmers does not change the fact that credit is being provided, which strongly implies that this is a lending program. FCA notes that FCS associations will be discounting notes from other creditors, when in fact, those "other creditors" are actually retailers selling products.

Concentration Limit

We appreciate the FCA's acknowledgement that the concentration cap for Farmer Notes should be lowered from the previous level of 50% of an association's capital. The proposed 20% is more appropriate than 50%, but we continue to believe the FCS associations are going to be exposed to increased risk through the Farmer Notes program. For example, an FCS association with $1 billion in loans would have a portfolio cap of $150 million in Farmer Notes. If the association had capital of $160 million - 16% capital ratio, typical among FCS associations, then Farmer Notes from one single retail business could total $32 million.

This seems to be an excessive amount of potential risk for an FCS association to take on through a lending program that involves loans outside of the main focus and expertise of the FCS. Further, the association's "investment" portfolio would be quite undiversified. In this case, it actually could consist significantly of additional loans, not investments. We believe this represents an unnecessary and excessive risk to the System. Therefore, we believe the 20% concentration cap should be lowered to 5%.

Farmer Notes Extended to Long-term Loans

We question the provision that would extend the Farmer Notes program beyond short- and intermediate-term loans to include long-term obligations. Since the program is currently limited to short- and intermediate-term loans, how and why would it be extended to include long-term lending? Long-term obligations are not the type of credit that agricultural suppliers are typically involved in when it comes to input and production financing for their customers. So, if the goal of FCA is to allow the FCS to finance the credit activities of the agricultural supply market, then why the need for long-term obligations? Also, Congress has not authorized long-term lending for FCS associations except in limited circumstances.

Cross-title Lending

We continue to express our concerns about potential cross-title lending activities that may occur through the Farmer Notes program. FCA notes that investments are not subject to the same restrictions as loans, but as we've clearly shown, the Farmer Notes program is really just a retooled lending program with a few restrictions. FCA adds that there are no freestanding PCAs in the System and only twelve FLCAs. While this is true, there are still statutory restrictions that apply to cross-title lending and these should be adhered to within the Farmer Notes program if FCA chooses to move forward with the program. However, the FCA, by referencing minor statutory provisions related to regulating FCS investments, is attempting to sweep away these carefully crafted legal parameters by allowing extensions of credit for any term for any type of FCS lender. These all-encompassing changes have never been endorsed, let alone even discussed, by Congress.

Loan restrictions vs. investment restrictions

Another distinction FCA ties to make regarding Farmer Notes is the fact that portfolio caps are imposed on the program, which FCA suggests should further differentiate it as an investment rather than a loan. FCA states, "615.5172 imposes a portfolio cap on Farmer Notes, which the Act and FCA lending regulations do not establish for agricultural or aquatic loans". However, we note that the Farm Credit Act statute does establish limits and caps on FCS lending authorities. For example, Section 2.4(a)(1) sets a throughput requirement (20%) if financing is provided for basic processing or marketing of agricultural products. Section 2.4(b)(2) and (3) sets a portfolio limit on financing of rural housing and a maximum population size limit for rural areas, respectively. Section 1.7(a)(1) sets the minimum and maximum term of real estate loans. So, it is apparent that just because there are restrictions imposed on a lending program, it does not automatically become transformed into an investment program.

Conclusion

The FCA is creating an enormous new lending program for agricultural businesses that allows FCS to solicit, likely without any participation from banks, the banks' retail business customers. We again point out that this proposal is related to "investments" in name only and distorts minor references in the statute that allows FCA to regulate actual FCS investments. It shifts the intended purpose of FCA's investment authorities from, for example, managing securities and depositing funds in banks, to making general consumer and business loans. There is already plenty of business and consumer credit available from the private sector. But, under this business-lending program, it appears FCS would be financing installment loans, credit card lending, and other credit or cash needs of retailers and their customers so long as the primary business of the retailer is selling agricultural supplies and equipment to farmers while also extending agricultural credit in the normal course of business.

FCA has not shown which "farmers", consumers, or businesses would be able to receive financing that cannot now obtain it from commercial banks and this should be a requirement for Farmer Notes. No new credits would be extended that are not now being extended. This is a major expansion of FCS powers. Selling "Farmer Notes" to FCS associations is simply a transfer of financing for agricultural businesses and consumers from commercial banks to FCS lenders. FCA doesn't have the authority to create an expansive new consumer and business-lending program that hasn't been authorized by Congress.

We thank FCA for the opportunity to comment on this proposed rule. Again we urge FCA to either withdraw this proposal entirely or redraft it with a requirement that FCS associations participating in the Farmer Notes program must do so through loan participations with commercial banks. We request that the FCA respect the public's past input on this issue, which was overwhelmingly against the proposal.

ICBA reserves the right to make additional comments and raise additional concerns regarding this proposal. If you have any questions regarding this comment letter, please feel free to contact Mark Scanlan, Director, Office of Agriculture and Rural Policy or Reece Langley, Deputy Director, Office of Agriculture and Rural Policy, at 202-659-8111.

Sincerely,

Camden R. Fine
President and CEO

1 The Independent Community Bankers of America represents the largest constituency of community banks of all sizes and charter types in the nation, and is dedicated exclusively to promoting the interests of the community banking industry. With nearly 5,000 members, ICBA members employ more than 225,000 Americans and hold more than $778 billion in total assets. For more information, visit ICBA's website at www.icba.org.






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