ICBA - Advocacy - Summary of ICBA Recommendations

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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