2025-03172RuleWallet

Farm Bureau Ditches Red Tape to Ease Farmer Paperwork Woes

Published Date: 3/3/2025

Rule

Summary

The Farm Credit Administration is cutting down on confusing and costly rules for Farm Credit System institutions, including Farmer Mac. After hearing from these groups in 2022, they're making changes to simplify regulations and reduce unnecessary paperwork. These updates start March 3, 2025, aiming to save time and money for farms and lenders across the country.

Analyzed Economic Effects

8 provisions identified: 4 benefits, 4 costs, 0 mixed.

Troubled Debt Restructuring (TDR) Reporting Updated

FCA says Generally Accepted Accounting Principles changed so the TDR loan performance category is no longer required under GAAP after January 1, 2023, and FCA issued an Informational Memorandum on December 30, 2022 explaining that change. FCA also plans to propose updating Sec. 621.6(b) to reflect the GAAP change.

Electronic Delivery Remains Opt‑In for Shareholder Reports

FCA declined to remove the requirement in Sec. 620.2(c) that shareholder reports may be delivered electronically only with shareholder agreement (an "opt-in"). That means institutions must obtain shareholder agreement before using electronic delivery instead of mailing hard copies for reports covered by Part 620.

Criminal Referral Rules and Portal Use Remain

FCA affirmed that institutions must refer known or suspected criminal violations within 30 calendar days using the FCA referral form and explained Bookletter BL-073 guidance on what constitutes "known or suspected" activity. FCA said it is considering updates to the online criminal referral portal but did not change the referral requirements.

Independent Credit Judgment Required for Loan Purchases

When an institution purchases an interest in a loan participation, Sec. 614.4325(e) requires the purchasing institution to independently evaluate creditworthiness and document a credit analysis independent of the originating lender; it may use originating information but must independently evaluate it.

Permanent Capital Ratio ARS Disclosure Under Review

FCA plans to address the comment requesting removal of the permanent capital ratio from the Annual Report to Shareholders (Sec. 620.5) as part of its proposed permanent capital rulemaking listed in the Fall 2024 Regulatory Projects Plan.

Similar Entity Rulemaking Underway

FCA is engaged in a rulemaking and published an Advanced Notice of Proposed Rulemaking on September 6, 2024, to consider comments about Sec. 613.3300 (the similar entity participation limit and how the 50 percent test is applied).

No Separate Call Report for Farm Credit Leasing

FCA determined that Farm Credit Leasing Corporation (FCL), a wholly owned service corporation of CoBank, is no longer required to prepare and file a separate Call Report because CoBank's reporting is sufficient. FCA may require a separate Call Report in the future if FCL's structure or reporting changes.

Ballots Must Be Retained Until Director's Term Ends

FCA confirms Sec. 611.340 requires retention of ballots, proxy ballots, and election records at least until the end of the term of office of the director, including undeliverable, late, and invalid ballots.

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Key Dates

Published Date
Rule Effective
3/3/2025
3/3/2025

Department and Agencies

Department
Independent Agency
Agency
Farm Credit Administration
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