Comment on FR Doc # 2011-17781

Director, Product Administration and Standards Division Risk Management Agency United States Department of Agriculture P.O. Box 419205 Kansas City, MO 64133-6205 Re: ARPI Regulations and proposed rule Cornerstone Insurance Group appreciates the opportunity to comment on the proposed Area Risk Protection Insurance (ARPI) plan. We agree that combing the GRP and GRIP plans into this one new plan is a good idea and this will reduce duplication in paperwork and resources. We strongly disagree, however, with Section 407.2 (b) which allows “agents of the USDA” to offer these contracts to producers. In order to offer the new ARPI program, FSA personnel would not only have to undergo extensive training on this new program but, they would also have to undergo extensive training on the differences between this plan and the existing Revenue Protection and Yield Protection plans. Independent agents already have a working knowledge of the numerous products offered by the FCIP and, therefore, they are more qualified to offer producers the product that will offer the most protection for their individual operation. Training FSA employees unfamiliar with these policies, particularly with respect to the extremely detailed technology programs used to execute these policies, will be extremely expensive and will most likely delay successful sales of the new product. Also, these programs are offered on a per crop basis. So, if a producer wanted to go with the new ARPI policy on their corn and a Revenue Protection plan on their soybeans, the FSA personnel would not be able to offer both plans. This could result in confusion for the producer. Currently the FSA is not permitted to sell crop insurance. Therefore, we would respectfully request that the lines in Section 407.2 of the proposed rule, which permit the FSA to sell ARPI contracts, be stricken from the rule to reflect the current FCIP sales environment. Sincerely, Ben Royal GM Cornerstone Insurance Group