The following are the comments the NACS Board sent to FSA on the proposed CBS structure.
NACS FSA CBS Structure Comments
The National Association of Credit Specialist of FSA has founding principles based upon service to rural America being our number one priority. NACS supports the modernization of FSA delivery systems;however, maintaining and strengthening the current elements of the Farm Loan Programs model that are resulting in quality loans and expansion of opportunities is essential.
Farm Loan Programs has been delivered using a similar structure of Type 1, 2 and 3 offices and offering FLP programs to multiple counties from a Central office location using a team of Farm Loan Program employees (FLM/SFLO, FLO, LA and FLP PT)
Most states have recently reevaluated their delivery of FLP in Type 1,2 and 3 offices based on current workload and the location of Type 1FLP offices should be considered when states are choosing locations of Central offices.
It should be recognized as the demand for Farm Loans provided by FSA is projected to increase given the increased funding and the continued decline in available credit from commercial lenders
In consideration of these factors, NACS would encourage the following in a Modernization plan for FSA:
1. Management of the Farm Loan Program and Loan Approvals should be done by GS employees hired under the federal employee system with farm loans being their area of specialty and full time responsibility.
2. Delivery of Farm Loan Programs in field offices should be done through Credit Teams managed by a Farm Loan Manger.
3. Placement of Farm Loan Teams in Central offices has to be based upon the existing workload in the area served by the Central office. The result may be not all central offices will have a farm loan team. NACS does not support staffing all Central offices with a FLP team. Workload does not support it and current staffing numbers would not allow it. The goal of the agency has to be to do the best job possible of not reducing service to an area but to have a plan in place that allows for increased service if an area shows a need for more service.
4. The CBS structure will result in a reduced foot print of FSA in rural areas. The result is that FLP delivery needs increased resources so that more can be accomplished remotely, ie mobile connectivity.
5. All current employees of FSA should be given the opportunity to compete for Farm Loan vacancies under the GS system, allowing pay retention while completing the Farm Loan Training program.
6. All FSA offices under the CBS structure should offer a minimum level of service to include release of normal income security, receiving loan payments, and providing application information. The services can be provided by GS and/or CO employees.
7. States should include state employee associations when developing state plans.
8. As states prepare their plans, they need to minimize the disruption of borrower/ loan officer relationships. When a loan is made to a customer, it becomes a long term relationship.
The National Association of Credit Specialists appreciates the opportunity to provide input on the proposed modernization of FSA via field realignment (CBS) and hopes that you will contact our Association for clarification and additional input.
Allen D. Hall
The images we old steadfastly in our minds over the years are not illusions; they are the patterns by which we are able to mold our own destinies. - Nathaniel Hawthorne
LeAnn is a Farm Loan Chief from New Mexico. She was elected NACS President at the June 2019 Convention.