ICBA sent a letter to the Farm Credit Administration (FCA) urging them to avoid implementing any future regulatory proposals that would expand Farm Credit System (FCS) powers and instead asked FCA to focus on safety and soundness issues. ICBA suggested FCA examine 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," stated ICBA's president and ceo Ken Guenther.
Specifically, ICBA recommended the FCA promulgate regulations as part of their regulatory agenda that would:
- Implement predatory pricing controls;
- Prohibit FCS institutions from deposit-taking activities under the label of "cash management accounts" or "funds held accounts";
- Enhance OFI funding access;
- Require FCS institutions to hire outside appraisers to assess real estate valued over $250,000; and
- Prohibit loan officer commissions on new loans.
ICBA's letter was in response to a survey by the FCA's Office of Inspector General.