Pub. 10 2015-2016 Issue 3

September/October 2015 19 Extraordinary Service for Extraordinary Members. Comptroller Acknowledges FCS Competition In an Aug. 4 speech, Comptroller of the Currency Thomas Curry candidly acknowledged the unfair competition bankers face from the FCS. In speaking at an Interagency Outreach Meeting on the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA), Comptroller Curry noted that “rural banks face a number of challenges,” including agricultural borrowers who “almost certainly face the prospect of reduced net income. At the same time, some of your competitors, includ- ing Farm Credit institutions, have pricing advantages that make it more difficult for you to compete with them.” [Emphasis supplied.]  Bert Ely — continued on page 20 we’re Always CLOSE BY NetWorks is the Electronic Funds Transfer (EFT) service provider that Nebraskans have used and learned to trust like family for over 30 years. Since our offices are right here in Nebraska, you can count on us to provide quick and personalized service for all of your EFT needs. Give us a call and let’s talk about how we can simplify EFT for you. You will talk with a fellow Nebraskan and not some automated system. www.netseft.com Toll Free 800-735-6833 Local 402-434-8202 The guidance goes on to provide that WB “reports can be made through WB links on the institution’s website with a best practice of having the WB link available on all website pages.” The challenge today for bankers and others will be to find theWB link. For example, CoBank has done a good job of burying the link to its WB reporting page. Only by scrolling to the bottom of a very long site map for CoBank’s website did I find a link to CoBank’s whistleblower webpage, which happens to be: www. reportlineweb.com/cobank. Hopefully, this link will get lots of use. Checking the websites of a few other large FCS institutions revealed some interesting anomalies. For example, FCS America does not use the word “whistleblower.” Instead, it merely has a link to “anony- mous reporting,” whatever that is sup- posed to mean. A search on its website for “whistleblower” turned “0 search results.” Farm Credit Mid-America does not have a search mechanism for its website but clicking down through several levels of its website brings an avid searcher to “Anonymous Report- ing.” Again no use of the word “whistle- blower” under Corporate Governance. Checking the websites of a few other large FCS institutions produced mixed results, from no obvious whistleblower link to Farm Credit East, where typing “whistleblower” into its search mecha- nism provided a link for reporting complaints anonymously with a third party, www.ethicspoint.com . Howwell this whistleblower reporting systemwill work has not yet been tested. Clearly the FCA has a lot of work to do in getting every FCS institution to install highly visible, easy-to-use whistleblower reporting procedures on key pages of their websites. The FCA should set an example by clearly providing on its website a link for whistleblowers to register complaints about FCS lend- ing abuses. At present, the FCA link at www.fca.gov/home/inspector/whistle- blower_protection.html only receives complaints related to FCA employment practices.