After summarizing the background and some of the egregious cases in the past, their own analysis includess:
"By limiting the use of farm managers to multiply payments, the proposed changes appear to address many of the concerns with the current rules. A few notable issues remain and are briefly discussed here for the reader's consideration. As an initial matter, the differential treatment of entity types when it comes to payments is not addressed here because it is provided for in the statute and may need Congressional action to change it. [by definition--my comment] The proposed changes create differential treatment for farm managers without much explanation or justification. USDA could provide more clarity on how the changes apply to the first farm manager. USDA may also want to explain or justify exempting the first farm manager from the new definitions applied only to the additional managers.
A similar issue arises with the recordkeeping requirement. Again, the proposed rule provides different treatment for the first farm manager than for additional managers. In addition to reconsidering treating all farm managers the same, USDA might also want to consider whether this recordkeeping should also come with a reporting requirement. The long-standing concerns about this issue would seem to counsel verification of compliance with the regulation."
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