Pub. 9 2014-2015 Issue 4

www.nebankers.org 22 Extraordinary Service for Extraordinary Members. FCA having made the case as to why that greater flexibility is needed. In fact, as the data in the preceding paragraphs clearly show, the FCS as a whole has a far larger investment portfolio than it needs tomeet short-term liquidity needs and to manage interest-rate risk. As noted above, most of those investments reflect “GSE arbitrage”—FCS use of cheap GSE debt to invest in higher-yielding private-sector securities, such as commercial MBSes—to enhance its profitability. No public benefit flows from that profit enhancement. Arguably the real intent of the proposed revisions is to open the door wider to FCS investments in businesses and other entities which the FCS cannot legally lend to, such as businesses and real estate projects unrelated to agricultural or agriculturally related activities. Medical facility and nurs- ing home loans are excellent examples of illegal FCS lending. The key word here is “other” as it opens the door to any type of credit extension that can be characterized as an invest- ment. Conceivably, these “other investments” could even be equity-capital investments, a clearly inappropriate activity for any GSE. These other investments “would be subject to the portfolio limit on association investments . . . unless otherwise provided for by the FCA.” While “these other investments could also be subject to specific conditions of approval and subject to other limits on a case-by-case basis,” as a practical matter, the sky is the limit. Given that most FCS associations have no or very few investments, the ability of these associa- tions to properly evaluate the riskiness of any investment is highly questionable. Report FCS Lending Abuses Bankers are continuing to send FCW reports of FCS lending abuses such as FCS loans for rural estates, weekend getaways, and hunting preserves. Email reports of similar lending abuses in your market to green-acres@ely-co. com. Please provide as much detail as possible about any loan that violates the spirit, if not the law, governing FCS lending.  To contact Bert Ely, email bert@ely-co.com , phone (703) 836-4101, fax (703) 836-1403, or send mail to P.O. Box 320700, Alexandria, Va. 22320. If your bank belongs to the American Bankers Association (ABA), you can enjoy a free email subscription to Farm Credit Watch or you can read it monthly online at www.aba.com . To receive Farm Credit Watch by email or to manage your subscription, visit ABA Member Email Bulletins at www.aba.com/Tools/Ebulletins/Pages/default.aspx. For other inquiries, please contact Barbara McCoy at the ABA at (800) BANKERS or bmccoy@aba.com .  Bert Ely — continued from page 21 Teller Cash Recyclers – When it comes to Branch Transformation, enhancing e ciencies and increasing productivity are essential. Teller Cash Recyclers help achieve this and more. Not only do TCRs improve teller productivity by eliminating the time needed to balance drawers and count cash, but they also signi cantly reduce wait times and improve customer satisfaction. Utilizing the latest technology, TCRs allow for cash to be handled less often and with more accuracy, reducing the amount of exposed cash in your branch. Take your employees’focus away from counting cash and let them put their attention on what’s most important to your business – the customers. Key Features – • Simplifies and accelerates cash transactions • Reduces teller cash balancing time and cash exposure • Offers enhanced banknote authentication, increased sorting capabilities and reduced risk of robbery or potential loss Make the most of your branch’s time and money with Teller Cash Recyclers. Make the most of your branch’s time and money using Teller Cash Recyclers. NuSource Financial Inc. || www.nusourcefinancial.com || 952.942.9191 • Banking & Finance • Municipal Law • Bankruptcy • Employment Law • Business & Commercial Law • Sanitary & Improvement Districts 2120 South 72nd Street, Suite 1200, Omaha, NE 68124 (P) 402.391.6777 (F) 402.390.9221 www.crokerlaw.com Croker,Huck,Kasher,DeWitt, Anderson & Gonderinger,L.L.C. AT T O R N E Y S AT L AW Providing quality legal services to businesses and individuals in such areas as: • Real Estate • Estate Planning • Probate • Taxation • Litigation • Tax Foreclosure