First Central
Bank McCook, N.A.
From: Don Moore [mailto:dmoore@fcbm.local]
Sent: Wednesday, April 07, 2004 10:43 AM
To: regs.comments@federalreserve.gov; Comments; regs.comments@occ.treas.gov;
regs.comments@ots.treas.gov
Subject: EGRPRA
Dear Sir or madam:
I would like to make a few general comments about three items---the
Farm Credit System, Credit Unions and the regulatory/compliance
burden on banks--my intention is to keep my remarks short--so
you will be compelled to read this email. I would be willing
to expand upon my comments if you will simply contact me.
The Farm
Credit system was originally formed to assist farmers and ranchers
who were
unable to obtain credit from a more traditional
source. It was a great idea. Today we complete with the Farm
Credit System---but on a playing field that provides them with
too many advantages. First, they are not required to pay income
tax. This in itself gives them over 240 basis points advantage
on interest rate. They have expanded their customer base---with
their tax advantage to "cherry picking" the best customers---this
is not "the basis on which they were formed". I have
no problem competing with them---but when they have the tax advantage
we are asked to compete with one hand tied behind our back. I
support legislation in Congress to "level the playing field" by
granting banks tax relief to banks on loans to Agricultural or
by implementing a tax on the Farm Credit system.
Credit Unions also have the tax advantage that banks do not
enjoy. Again this is an unfair advantage. It they want to act
like banks they should be taxed.
Finally,
the regulatory burden on banks over the past 5 years has doubled.
The Federal
Government requires banks to "police" information
from (1) money laundering to (2) foreign business activities--if
they don't they are subject to fines and penalties. Again these
regulations should apply to the Farm Credit system and credit
unions or support providing banks with tax relief to allow them
to compete on a level field.
Thank you.
Sincerely yours,
Donald E. Moore
President & CEO
First Central Bank McCook, N.A.
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