Comment Submitted by Jeremy Ross

I am writing in support of the proposed approval of the Farm Credit System Lending Institutions' ("FCSLI") participation in the FHA Mortgage Insurance Programs. I have several years experience in the trading and servicing of defaulted mortgage loans including rural loans. In my experience, standard banking institutions are woefully ill-equipped to judge the value (or lack thereof) of rural properties due to the lack of available comparable properties and an inadequate understanding of local markets and the unique concerns that accompany rural markets. Because of this information deficit, banks are increasingly hesitant to loan to borrowers in rural areas. This problem is further compounded in the case of the often unusual circumstances of farm properties that may generate income. By allowing the FCLSI to participate in FHA Mortgage Insurance Programs thereby making the FCLSI's member institutions more competitive lenders, we are encouraging job creation. FLCSI member institutions are uniquely positioned to loan to rural borrowers, particularly those who farm. The availability of more loans and more competitive loans to rural farmers will undoubtedly shore up their capital and reduce barriers to entry, thereby increasing the prevalence of these smaller farms. It is not hard to see that increasing the prevalence of more local farms will increase jobs in suffering rural economies. For the aforementioned reasons, I support the proposed rule FR-5416-P-01 Approval of Farm Credit System Lending Institutions in FHA Mortgage Insurance Programs.