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The Institute for Agriculture and Trade Policy (IATP)1 appreciates this opportunity to provide input to the draft FY 2022-2026 Strategic Plan. FCA instructs “(For cybersecurity reasons, please do not include hyperlinks to websites.)” This instruction imposes an unfortunate limitation to our comment and those of other commenters. FCA will be unable to verify responses in this and other letters efficiently by referring to the original hyperlinked documentation of cited sources. The instruction is alarming, since it implies that the FCA’s cybersecurity is markedly more vulnerable to hacking, malware and other forms of abuse than the computer systems of other federal financial regulators that impose no such limitations to commenters on the use of hyperlinked sources.

If FCA is vulnerable to cybersecurity threats from hyperlinked information sources, FCA should prioritize improving its cybersecurity while ensuring that measures taken do not prevent the agency from engaging fully with the public. Because FCA does not receive a federal appropriation but depends almost entirely on assessments from the Farm Credit System institutions for bank examinations and other services, FCA should levy an annual cybersecurity assessment to pay for needed hardware, software, testing and training to help fulfill FCA’s safety and soundness mandate. Although cybersecurity costs will increase FCA’s operating expenses, those who communicate with FCA will appreciate the enhanced cybersecurity, particularly when communications include confidential business information.

Overall considerations for drafting the Strategic Plan FY 2022-2026

As FCA is aware, on March 24 the Office of Management and Budget (OMB) announced that it would rescind measures taken by OMB in the previous administration to reduce strategic planning and performance evaluation planning. The March 24 memo states,

Agency heads and Chief Operating Officers (COOs), supported by Performance Improvement Officers, are instructed to align their strategic goals and objectives, including Agency Priority Goals, with the Administration’s policy priorities, in particular continuing to meet the health, welfare, and economic challenges of the COVID-19 pandemic, advance equity, and address climate change. Agencies are encouraged to form partnerships proactively in areas where programs from multiple agencies must work together to achieve a common outcome and to submit proposals for joint Agency Priority Goals to OMB where appropriate.2

IATP believes the March 24 memo and subsequent OMB guidance should help FCA develop a robust Strategic Plan with a corresponding performance evaluation plan. Implementing the OMB instruction on strategic planning will help the agency report on progress in meeting Strategic Plan objectives, forming relevant partnerships and requesting resources from other agencies as needed to advance Biden administration policy priorities.

The FCA should draft this Strategic Plan for an administration that has clearly stated its expectations for strategic planning and agency performance evaluation. The antipathy of the previous administration to detailed strategic planning and to evidence-based performance evaluation and accountability is a thing of the past. To reduce the possibility that OMB might require FCA to redraft the FY 2022-2026 Strategic Plan, FCA should include a review of the FY 2018-2013 Strategic Plan objectives and assumptions made to help determine those objectives.

For example, among the assumptions in the latter plan was this: “The [Farm Credit] System must adapt to changes in traditional agriculture and embrace new approaches, such as urban, specialty, and organic farming. These changes will challenge the System to find creative ways to balance safety and soundness with opportunities to serve new or emerging market segments.”3 To what extent was FCS able to adapt to provide credit and other services to farm and ranch operators who are not traditional row crop and livestock farmers and ranchers? If FCS was not able to realize this FCA stipulated adaptation, what factors impeded it from doing so? If the System successfully managed this adaptation, with what new programs or policies did it do so? Will the FY 2022-2026 Strategic Plan likewise commit to serving non-traditional farmers and ranchers and indicate how it will do so?

To continue reading the letter and view the endnotes, please view a PDF of the letter.