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Last update: 05/22/13
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 Home > Advocacy
> Industry Issues
Summary of ICBA Recommendations
FCS Young, Beginning Small (YBS) Program
Address Predatory Pricing or "Cherry-Picking" Issue
- Implement regulations prohibiting predatory pricing as Congress intended
- Addresses flip-side of YBS issue & places focus on YBS farmers
Accurately Measuring YBS Performance - Definitional Issues
- More clearly define YBS categories & intent
- Prevent double or triple counting of YBS loans
- Establish a mutually exclusive "Combined YBS Category"
- Accurately report father/son combinations
- Modify beginning farmer definition
- Aggregate dollar amounts of multiple loans to individuals
- Distinguish between full-time and part-time farmers
Accurate Reporting of YBS Data - Reporting & Disclosure Issues
- Make examination results publicly available
- Report data annually from each institution
- Report data individually from each FCS institution
- Aggregating data @ Farm Credit Bank level is insufficient
Meaningful Guidelines
- FCA seeks clear, meaningful & results-oriented guidelines
- Definitions will drive effectiveness of any such guidelines
Requiring FCS To Similarly Enhance OFI Outreach
- Commercial banks already comply with CRA and numerous regulations
- FCS needs to similarly measure system's OFI outreach efforts
- New FCA OFI regulations should address evolving need for enhanced OFI program
- These OFI regulations should be finalized in tandem with new YBS regulations
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