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1 Farm Credit Crisis Communications Plan March 4, 2011

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Page 1: Farm Credit Crisis Communications Plan March 4, …c8a84a312090784baeb9-62cb9d4bf703273518ec4297fca66942.r46.…applicable) to take all necessary next steps outlined in this crisis

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Farm Credit Crisis Communications Plan

March 4, 2011

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SECTION PAGE

I. Introduction 3

II. Quick Start Guide 4 III. General Communications Response Protocol 5 IV. Farm Credit Key Messages 9

V. Communicating and Maintaining the Plan 10

APPENDIX

A. Core Communications Tips and Reminders 11

B. Non-Disclosure Agreement 12

C. Sample Crisis Scenario Introduction 13

D. General Guidance to Reacting to a Crisis 14

E. Sample 1: System Entity Financial Crisis or Failure 15

F. Sample 2: Allegations of Bank/Association Fraud 19

G. Sample 3: Widespread Delinquency or Foreclosure 23

H. Sample 4: Data Security Breach 27

I. Sample 5: Funding Crisis 31

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I. Introduction

With our unique structure, niche audience and expertise, the Farm Credit System has many opportunities – and challenges – to play an integral role in the success and promotion of agriculture. The 2008 Reputation Institute study commissioned by the President‟s Planning Committee (PPC) brought into focus the critical need for an overall reputation initiative to manage Systemwide efforts that:

Coordinates the System‟s key messages and national presence

Minimizes risk to the System‟s reputation

Leverages the System‟s strengths to maintain and improve its image in a crisis

The Reputation Committee was established to oversee the Reputation Management Program, and is committed to providing governance and oversight as the Farm Credit System establishes a stronger national brand identity and a coordinated communications approach. Although Farm Credit is geographically, functionally and demographically diverse, the Reputation Management Program seeks to help the System fulfill our mission by enabling message consistency, stability, and strength through collaborative communications processes. A crisis communications document exists to outline potential organizational threats, provide baseline process strategies to protect the organization‟s interests, ensure informed, timely and accurate responses, and guide day-to-day organizational activities. The scenarios in this plan are hypothetical and serve to clearly outline the way a collaborative and appropriate communications response can be created and articulated. Many of the recommended communications tools must be created in real-time at the time of an actual event to be timely and to address scenario-specific facts, positions and messages. One of the most important aspects to successfully managing through a crisis situation is to have already established effective communications procedures prior to a crisis occurring. Done effectively, many crisis responses allow for business challenges to be addressed as an extension of „business as usual.‟ Note: this is a communications process document and does not address business continuity or disaster recovery plans. Per FCA’s guidance, such plans should be maintained at the local level with information relevant to each System entity’s diverse physical location details. It is imperative that communications preparedness become an organizational priority to provide the foundation for effective crisis, and even proactive, public relations. The basic components of this document include knowing our audiences, identifying the most likely risk scenarios, and having the plans to manage and mitigate the risk scenarios. In addition, the document is designed to allow the organization to effectively manage and minimize the impact of large-scale issues with forethought, transparency and decisive action. Ensuring effective communication during times of crisis requires upfront investment before a crisis occurs and consensus across the System regarding the roles of the Reputation Committee, public relations professionals Systemwide, and System leadership. With that in mind, this plan outlines recommendations for creation of a static, „Core Communication Team,‟ that can establish scenario-specific „Event Crisis Teams‟ as needed to develop and execute a response strategy. Both teams would work closely with any „Operational Response Teams‟ that are established to handle elements of the crisis beyond communications.

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II. Quick Start Guide 1. When a crisis occurs or is imminent, immediately alert/engage the Core Communication Team,

which will work with appropriate parties (including any Operational Response Teams as applicable) to take all necessary next steps outlined in this crisis communications plan.

Reputation Management Program Staff Lead

Leigh Picchetti, VP of PR, FCCServices

[email protected] 303-721-3281 or 720-218-1686

Reputation Committee Chair

Bob Frazee, president and CEO of MidAtlantic Farm Credit

[email protected] 410.848.1033 or 410-259-2004 cell

Reputation Committee Vice Chair

Arthur Hodges, VP of Corp. Comm., CoBank

[email protected] 303-740-4061 or 720-255-6597

FC Council Reputation Committee Member

Ken Auer, Pres./CEO, Farm Credit Council

[email protected] 202-879-0843 or 202-309-2602

Funding Corp. Reputation Committee Member

Regina Gill, VP at Funding Corp.

[email protected] 201-200-8064 or 201-978-3379

2. The Event Crisis Team, once assembled, will assess major risks and opportunities and evaluate

the scope and the potential impact on the System. 3. The Event Crisis Team will identify and prioritize key audiences, specific environmental factors

that apply to the situation, and determine specific response protocol depending on crisis level and expected impact.

4. The Event Crisis Team will confirm and engage key spokespersons including System

spokespersons and external experts and advocates. 5. The Event Crisis Team will work with identified spokespersons to choose and/or create specific

communications tools and materials as dictated by crisis level and expected impact. Team Definitions

Operational Response Team: likely to be among the first to know that a potential crisis has arisen. This team may include representatives from the executive leadership, legal or human resources teams at the impacted entities or may be comprised of existing cross-entity leadership committees.

Core Communication Team: responsible for helping to initiate the communications preparation process. Comprised of the Reputation Management Program staff lead, the chair and vice chair of the Reputation Committee, and the Reputation Committee representatives from the Farm Credit Council and the Federal Farm Credit Banks Funding Corporation.

Event Crisis Team: members identified by the Core Communication Team, likely with feedback from the PPC and any Operational Response Teams. This team is comprised of experts on a variety of topics directly related to the situation at hand and will make decisions about the proactive versus reactive nature of the appropriate communications response, the communications tools to use, the primary spokespersons, etc.

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III. General Communications Response Protocol

All System representatives should proactively engage their entity‟s leadership when a crisis or potential crisis appears imminent. Under all circumstances, and regardless of scope, all System organizations should adopt a standard reporting process beginning with their individual organization leadership and appropriate internal legal counsel, and following the proper reporting protocol as outlined in your employee policy manual or handbook. It is recognized that many potential crises will come to the attention of the System‟s operational leaders first. It is therefore requested that all potential crises with Systemwide impact be immediately referred to the Reputation Committee’s Core Communication Team. The System‟s communications goals in a crisis should include facilitating an open, two-way dialog between the communications and operational responders.

The Core Communication Team consists of the following individuals:

Reputation Management Program Staff Lead (Currently Leigh Picchetti, Vice

President of Public Relations at FCCServices, [email protected], 303-721-3281 or 720-218-1686) o Out-of-office back-up Margaret Fogarty, Communications Director, National Public

Relations at FCCServices, [email protected], 303-721-3284 or 720-935-1324.

Reputation Committee Chair (Currently Bob Frazee, PPC Regulatory, Legislative and

Public Relations Committee Chair and president and CEO of MidAtlantic Farm Credit, [email protected] ,410.848.1033 or 410-259-2004 cell) o Back-up contact PPC Chair (Currently Doug Stark President/CEO at Farm Credit

Services of America, [email protected], Office: 402.348.3333 Cell: 402.657.9284)

Reputation Committee Vice-Chair (Currently Arthur Hodges, Vice President, Corporate Communications Division at CoBank, [email protected], 303-740-4061 or 720-255-6597) o Back-up contact Kyle Henley, Corporate Communications Manager at CoBank,

[email protected], 303-694-5862 or 720-333-0771

Farm Credit Council Reputation Committee Member (Currently Ken Auer, President and CEO at the Farm Credit Council, [email protected], 202-879-0843 or 202-309-2602) o Back-up contact Jeff Shipp, Executive Vice President at the Farm Credit Council,

[email protected] or 202.879.0851 or 202-309-2603. Federal Farm Credit Banks Funding Corporation Reputation Committee Member

(Currently Regina Gill, Vice President Marketing/Investor Relations at the Federal Farm Credit Banks Funding Corporation, [email protected], 201-200-8064 or 201-978-3379) o Back-up contact Dan Bienz, Vice President, Financial Management Division at the

Federal Farm Credit Banks Funding Corporation, [email protected], 201-200-8070

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1. Immediately upon learning of a crisis, the Core Communication Team will begin coordinating a communications response plan via conference call. If an individual outside the Core Communication Team alerts the group about the crisis and has special access or knowledge, they may become a de facto member of the Core Communication Team as appropriate. Note: In many cases, an Operational Response Team may be established that is comprised of System leaders at the entities directly impacted. Operational leaders may be the first to recognize a potential crisis and are asked to alert the Core Communication Team that a situation requiring communications support has arisen. The Core Communication Team will ask themselves:

Is this a minor, moderate or severe crisis?

Are we in reactive or preemptive mode?

What are the facts and how can we obtain more information?

How much time do we have?

2. The Core Communication Team will formally notify the PPC Chair that they have convened to evaluate a potential crisis situation and provide a high-level assessment based on the answers to the questions above. The PPC Chair will provide recommendations for notifying the full PPC and will further provide guidance for the overall System response strategy and protocol for alerting other System staff leaders and directors.

3. The Core Communication Team will determine, based on the details of the specific

situation at hand, which System individuals will comprise an Event Crisis Team and will initiate a conference call. The Event Crisis Team should include potential spokespersons and may include legal counsel, risk management, subject-matter experts or other relevant leaders appropriate to speak on behalf of the System with media, Members of Congress, the Farm Credit Administration or other key audiences. This team will be determined on a case-by-case basis. Upon identification of this team, a communication to the PPC and the Farm Credit Council board will identify the members of the Event Crisis Team.

4. The Event Crisis Team will:

Review the following plan scenarios to help rationally assess risk, determine which communications strategies are pertinent and immediately executable, and identify specific next steps.

Determine the need for alerting other System representatives (including officers and primary points of contact for media relations) and implement next steps (including confirming and prioritizing key audiences, selecting proactive or reactive communications strategies, and providing ongoing support as appropriate to the impacted entity/ies). NOTE: System entities are strongly encouraged to avoid allowing media coverage

to become the delivery mechanism for information to employees and directors during a crisis. If media coverage is likely or definite, each institution should have a plan for communicating high-level key messages to internal representatives in a timely manner. A variety of distribution lists for System employee and director contacts are housed in the Farm Credit Council‟s Vocus database.

Ensure that a Federal Farm Credit Banks Funding Corporation representative takes the lead on communications to investors; a Farm Credit Council representative takes

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the lead on communications to the Farm Credit Administration and Members of Congress; and otherwise ensure that outreach activities are conducted by the appropriate System representatives.

5. As appropriate, an e-mail alert will be distributed to:

The remaining members of the Reputation Committee summarizing the situation and outlining the action plan.

Non-impacted System entity CEOs and media relations contacts to alert them that a potential crisis has arisen and providing direction for handling media inquiries and communicating with other stakeholder groups.

Flow of Events for Communications Engagement in a Systemwide Crisis

Core Communications Team Engaged

Event/Crisis Occurs or is Anticipated

Operational Response team Assembled as Appropriate

PPC Consulted

Event Crisis Team Convened

Action Steps Identified Additional Parties Notified as

Appropriate

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Team Definitions

Operational Response Team: likely to be among the first to know that a potential crisis has arisen. This team may include representatives from the executive leadership, legal or human resources groups at the impacted entities or may be comprised of existing cross-entity leadership committees.

Core Communication Team: responsible for helping to initiate the communications preparation process. Comprised of the Reputation Management Program staff lead, the chair and vice chair of the Reputation Committee, and the Reputation Committee representatives from the Farm Credit Council and the Federal Farm Credit Banks Funding Corporation.

Event Crisis Team: members identified by the Core Communication Team, likely with feedback from the PPC. This team is comprised of experts on a variety of topics directly related to the situation at hand and will make decisions about the proactive versus reactive nature of the appropriate communications response, the communications tools to use, the primary spokespersons, etc.

Media Protocol The System‟s public relations professionals will often be at the forefront of local issues and pending crises. To ensure strong communication and consistency across the System, the following protocol should be used:

A. Local crisis:

System public relations representatives in the impacted community will be the primary point of contact with local media if the situation impacts a single association.

Local representatives should contact the Farm Credit Vice President of Public Relations/FCCServices (Currently Leigh Picchetti, 303-721-3281) if the crisis has the potential to impact the System on a broader level.

Refer to the Additional Resources: A Local Look within the appropriate crisis scenario and review the Core Communications Tips and Reminders section in this plan‟s appendix.

B. Regional or National crisis:

System public relations representatives will work with the Farm Credit Vice President of Public Relations/FCCServices (currently Leigh Picchetti, 303-721-3281) to understand the plan, identify spokespersons, coordinate interview availability, and obtain approved talking points, communications tools and press materials.

Local PR contacts will manage incoming local and regional media requests and refer all national and trade media requests to the Farm Credit Vice President of Public Relations/FCCServices.

A public relations professional should staff all interviews and report post-interview results as well as track and share any local coverage with the Farm Credit Vice President of Public Relations/FCCServices as it appears.

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IV. Farm Credit Key Messages Derived from Reputation Institute survey findings about core reputation drivers for the System, the following high-level key messages are most likely to resonate with the target audiences. Situational and topical key messages should be crafted to support these overall themes.

Farm Credit is a stable and dependable source of credit and related services for agriculture and rural America. We offer support that has been providing value to our customers for nearly a century, through good times and bad.

Farm Credit was created by Congress to provide sound and dependable credit and related services to agriculture and rural America. Farm Credit is committed to transparency and the appropriate financial and credit discipline essential to preserving our ability to fulfill our mission

Farm Credit understands agriculture and rural America today and tomorrow, and we focus on one thing - leveraging the expertise of our directors and employees to meet the unique needs of agriculture and rural America.

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V. Communicating and Maintaining the Plan

A strong plan is only effective if it‟s properly introduced, maintained and regularly incorporated into day-to-day operations. As such, this plan will be made available to all System entities and each entity should devote time to review the plan, discuss its local application and provide feedback to the Reputation Committee. The Reputation Committee will serve as a resource for training, questions, and changes to the plan.

The Reputation Committee will provide multiple opportunities to facilitate awareness of

and access to the plan in a timely manner. This could include Systemwide webinars to provide updates and orientation, or training-the-trainer facilitation for System entity human resources and public relations contacts to learn how to do individualized training within each entity. Training guidance will be provided by the PPC.

The plan will be housed on the password-protected portion of the national Web site at www.farmcredit.com and will be accessible to System employees and directors.

System entities are encouraged to be considerate of the recommendations contained in this plan in their day-to-day operations. This plan will be reviewed on a quarterly basis for accuracy in contact information and communications protocol and annually for message consistency and the potential inclusion of new scenarios. In addition, a review will be conducted after a crisis occurs. Individual System entities are encouraged to have local crisis communications, business continuity and disaster recovery plans in place and up-to-date. Media Training Through the Reputation Management Program, the System will provide media training for System representatives who will represent a broad System perspective or who will work directly with national media. To inquire about media training for individual System spokespersons or subject matter experts, please contact Leigh Picchetti, 303-721-3281.

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APPENDIX A. Core Communications Tips and Reminders

System employees who are aware of a crisis situation with Systemwide implications should ensure that all communications (internal and external) are led by their entity management at the direction of the Core Communications Team, the Event Crisis Team and the Reputation Committee.

All Farm Credit entities should adopt a formal protocol that authorizes specific spokespersons who may talk with the media. The System‟s public relations vice president at FCCServices (currently Leigh Picchetti, 303-721-3281) should coordinate interactions with the national media.

Employees who are not in a public relations role should be reminded/instructed not to take media calls or speak with media, even if it‟s „off the record.‟ Any comment to the media is „on the record.‟

Talking with the press requires preparation and experience to ensure that your entity, our borrower-owners, and other Farm Credit entities are represented accurately and consistently. For information about media training, contact the System‟s public relations vice president at FCCServices (currently Leigh Picchetti, 303-721-3281).

Speaking without the proper authority and preparation can have an adverse impact on the Farm Credit image, reputation and business results.

Remember that the media landscape is changing daily. Maintain a current list of media and media contacts and include reputable bloggers, citizen journalists and others who may have access to large publics that include your target audience.

When contacted by the media, apply the following tips:

DO find out the reporter's name and phone number.

DO ask for the name of the media outlet and program he/she represents.

DO determine the topic the reporter wants to discuss.

DO ask for the reporter's deadline.

DO advise that someone will get back to the reporter.

DO contact the System‟s public relations vice president at FCCServices (currently Leigh

Picchetti, 303-721-3281) with national media inquiries, or your local designated media

spokesperson for local or regional inquiries.

DO NOT speculate or offer an opinion on a subject outside your expertise.

DO NOT offer personal opinions if you are speaking on behalf of and as a representative

of the System.

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B. Non-Disclosure Agreement

If utilizing outside experts, agencies or other support, the following non-disclosure agreement

should be signed by all third parties before proceeding. This ensures any confidential

information shared, including this crisis plan, remains confidential.

Farm Credit System Services Non-Disclosure Agreement

(Name)_______________________acknowledge that I may have access to The Farm Credit

System‟s confidential and proprietary information. Such confidential information may include,

without limitation: i) business and financial information; ii)business methods, documents and

practices; iii) customer lists; iv) technologies and technological strategies; v) marketing

strategies, crisis plan documents and other such information as Farm Credit and/or System

entities may designate as confidential (“Confidential Information”). I agree not to disclose to any

other person (unless required by law) or use for personal gain any Confidential Information at

any time during or after my association with Farm Credit and System entities, unless Farm

Credit and/or System entities grants express written consent prior to such disclosure or use. In

addition, I will use my best efforts to prevent any such disclosure. Confidential Information will

not include information that is in the public domain, unless such information falls into public

domain through my unauthorized actions.

Signature__________________________________ Date________________________

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C. Sample Crisis Scenario Introduction

Due to the diverse nature of our System, many of the scenarios described below could play out in isolated situations across the country. However, the integration of the System (and the integrated nature of agriculture) requires us to keep the following potential correlations top of mind and alert the Core Communication Team if a crisis happens in your back yard. Regional/geographic scale – A crisis brought on by weather or disease will often be concentrated in a particular region and impact certain members of the System. When faced with an isolated incident, we should always be prepared to ask “is this happening to my neighbors?” Commodity/asset similarities – It goes without saying that borrower-owners with similar assets, operations and products face many of the same crisis risks. Given that many System banks and associations service or participate in loans to specific niches within the agriculture industry, issues within a segment can have exponential impact to other System entities. “Domino Effect” – In a down economy, one challenge often begets another. It‟s typical for multiple market factors to be in play at once, and the right combination of factors can have an exponential impact on our borrowers, banks and associations. The most successful business people help to avert a crisis before it happens by thinking broadly when alerted to signals or examples of trouble, by always asking „who else?‟, „where else?‟ and, most importantly, by communicating those issues and concerns. Many times, issues will indeed be confirmed as isolated but the vision you provide your System peers by alerting them to a potential future challenge benefits the System as a whole – now and in the future.

With that in mind, the following hypothetical situations represent some potential System crises.

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D. General Guidance to Reacting to a Crisis While it is impossible to predict or accurately assess the full range of potential crises that could impact the Farm Credit System, the same general protocol should be followed in any potentially damaging situation. 1. When a crisis occurs or is imminent, immediately alert/engage the Core Communication Team,

which will work with appropriate parties (including any Operational Response Teams as applicable) to take all necessary next steps outlined in this crisis communications plan.

Reputation Management Program Staff Lead

Leigh Picchetti, VP of PR, FCCServices

[email protected] 303-721-3281 or 720-218-1686

Reputation Committee Chair

Bob Frazee, president and CEO of MidAtlantic Farm Credit

[email protected] 410.848.1033 or 410-259-2004 cell

Reputation Committee Vice Chair

Arthur Hodges, VP of Corp. Comm., CoBank

[email protected] 303-740-4061 or 720-255-6597

FC Council Reputation Committee Member

Ken Auer, Pres./CEO, Farm Credit Council

[email protected] 202-879-0843 or 202-309-2602

Funding Corp. Reputation Committee Member

Regina Gill, VP at Funding Corp.

[email protected] 201-200-8064 or 201-978-3379

2. The Event Crisis Team, once assembled, will assess major risks and opportunities and evaluate

the scope and the potential impact on the System. 3. The Event Crisis Team will identify and prioritize key audiences, specific environmental factors

that apply to the situation, and determine specific response protocol depending on crisis level and expected impact.

4. The Event Crisis Team will confirm and engage key spokespersons including System

spokespersons and external experts and advocates. 5. The Event Crisis Team will work with identified spokespersons to choose and/or create specific

communications tools and materials as dictated by crisis level and expected impact. Team Definitions

Operational Response Team: likely to be among the first to know that a potential crisis has arisen. This team may include representatives from the executive leadership, legal or human resources teams at the impacted entities or may be comprised of existing cross-entity leadership committees.

Core Communication Team: responsible for helping to initiate the communications preparation process. Comprised of the Reputation Management Program staff lead, the chair and vice chair of the Reputation Committee, and the Reputation Committee representatives from the Farm Credit Council and the Federal Farm Credit Banks Funding Corporation.

Event Crisis Team: members identified by the Core Communication Team, likely with feedback from the PPC and any Operational Response Teams. This team is comprised of experts on a variety of topics directly related to the situation at hand and will make decisions about the proactive versus reactive nature of the appropriate communications response, the communications tools to use, the primary spokespersons, etc.

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E. SAMPLE 1: System Entity Financial Crisis or Failure Synopsis: During historical downturns in the economy where some lenders have required bail-outs or other rescue efforts – or have closed their doors – Farm Credit System banks and associations have continued to carefully manage growth and set aside funds for loan losses. Due to focused risk management, the System has weathered these financial storms. System entities have stringent guidelines on portfolio management and the organization‟s exposure is typically well-controlled due to strong risk mitigation processes. However, no market is immune to the cyclical nature of a global economy and Farm Credit should be prepared for response in the event of a significant System entity crisis or failure. Communications Approach: As applicable, the Operational Response Team will alert the Core Communications Team that a situation requiring communications preparation has arisen. The Core Communication Team will review the details of any pending/developing situation, will assemble an Event Crisis Team, and will make recommendations to proceed with the appropriate response based on the immediacy and severity of the crisis. Proactive: If a System entity financial crisis or failure is eminent, or there is wide, well-publicized speculation of such a crisis that could spark investor panic, a proactive investor and media relations, public policy and employee communications approach may be required.

Hypothetical Example: Continued economic distress has led to borrowers in multiple associations being unable to repay loans. Several of the System banks and associations are facing a growing number of loan defaults that could endanger the viability of System banks and associations.

Key Audiences: Immediate, proactive communications materials should be created and distributed to: o Borrower-owners o Select System employees as appropriate o Media o Investors o The Farm Credit Administration o Members of Congress o Others as appropriate

Communications Tactics and Materials: The Event Crisis Team should develop appropriate communications tools including: o Talking points and FAQ o Press releases o Customer and employee letters o System and third-party media statements, interviews, bylined articles, blog post, Web site

updates and Tweets

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o One-on-one phone calls or meetings with key audiences, such as Funding Corporation officials and key investors, borrowers, Members of Congress, FCA officials, etc.

Situational Talking Points: The specific details of the real event or crisis will help to shape the appropriate talking points. The Event Crisis Team should identify key facts to complete the following: o Explain that the current System entity financial situation is driven by (background/cause),

and is being addressed by (positive factor that has or will support a correction of the situation).

o Put the situation in context by outlining the size/extent of the System entity financial crisis shortfall in comparison to the overall amount of lending that the System has done in the current year/quarter, or in this segment of the agriculture industry, or in comparison to some other relevant metric.

o Put into context who is impacted by this System entity financial crisis (specific associations, System members, investors, global bank community, others).

o Outline any plans that are/will be in place to help minimize the length or severity of the situation.

o Outline how the System is helping members get through this time.

Topical Talking Points: The Event Crisis Team should utilize and bridge back to the following general System talking points at every opportunity: o The Farm Credit System is federally-mandated to lend only to qualified borrowers in the

agricultural and rural sectors, and is subject to other lending restrictions. o Due to strong risk management practices, the System has collectively built strong earnings,

good credit quality and robust capital levels. o In preparation for challenging financial times, the System has set aside (insert current dollar

amount) for loan losses this year. o System management made strategic decisions to ensure that risk levels remain

manageable during economic and financial crises. o The System learned critical lessons from the severe economic turbulence in agriculture

during the mid-1980s and put into place improved lending standards and a financial reserve program to avoid similar situations in the future.

Responsive: If one or more financial indicators are present that may be signs of a future crisis, a reactive or responsive response is appropriate. In this case, the Funding Corporation along with other appropriate System leaders will focus efforts on crisis avoidance.

Hypothetical Example: A distressed economy has led to a small number of borrowers being unable to repay loans, placing a minimal strain on the System. The affected banks and associations are monitoring the situation and working with affected borrowers to avoid future loan defaults.

Key Audiences: Communications materials should be created to address a targeted audience that may include: o Affected borrower-owners o Investors o Ratings agencies o Dealers o Select System employees as appropriate

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o Others as appropriate

Communications Tactics and Materials: The Event Crisis Team should develop appropriate communications tools including: o Talking points and FAQs o Internal communications

Talking Points: Both the situational and topical talking points utilized in the proactive scenario can also be utilized in a responsive situation.

Questions To Consider: Below are some questions that could potentially be asked and should be considered when preparing talking points, FAQs and media interview requests. Note: use good judgment in determining the types of questions that are appropriate for use in an external document.

When and how did this financial crisis begin?

What were the factors contributing to the crisis?

What is the extent of the crisis on the financial stability of the impacted bank or association?

How many System entities are affected by this financial loss?

Are the lending standards of the bank, association or overall System too risky?

If this is a bank or association failure, what will happen to the assets and liabilities of borrower-owners and investors?

How will customers and investors be made whole again?

How is the institution insured?

As a result of this crisis/failure, what will the System do to minimize chances that this could happen again?

Additional Resources: A Local Look: A Systemwide crisis will have local and community implications. As appropriate, banks and associations may need to localize their response as part of the larger, overall national crisis plan. Questions to consider at the local level include:

Have you consulted the Event Crisis Team to take advantage of Systemwide messaging that can support your efforts?

What are the most immediate impacts to existing borrower-owners in your area?

What type of information do you need to address their immediate concerns?

Is there a local expert who can provide data that would be relevant to your local media?

Is there something about your local community or borrower demographics that makes you particularly vulnerable to this issue?

Are there implications for your community that would make it undesirable for you to be quoted and should you therefore direct media to a third party?

Does this have implications beyond your association or district and should you engage others within the Farm Credit System for assistance?

Are there local producers in your community who are heavily impacted by this that might contribute to negative media coverage for your association or the System?

Do you have plans in place that could help your association manage through this crisis?

Do you expect to be in the position of turning new borrowers away soon or in the short term?

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If pending or future borrowers will be adversely impacted in the near future, what contacts within the System or local resources can you identify to assist with messaging and lending alternatives?

Are there local or state resources for statistics on financial funding challenges, and market factors contributing to them? Can you use these statistics to bring perspective to current financial funding trends, recovery and resolutions?

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F. SAMPLE 2: Allegations of Bank/Association Fraud Synopsis: Farm Credit‟s unique structure and governance model helps to ensure all member organizations behave ethically, are open and transparent, and comply with all laws and regulations. The Farm Credit Administration (FCA) regulations detail institution, director and employee responsibilities and standards of conduct, specific prohibited conduct (such as conflicts of interest, disclosure of confidential information, etc.), reporting requirements, and requirements for establishing System policies and procedures. These regulations are designed to ensure that System entities do not allow, facilitate or enable acts of fraud or other unethical or illegal activities. The System also recognizes that the ethical and legal behavior of its employees, directors and partners are the biggest driver of a well-run and ethical organization. To that end, people present the most significant risks, as well as opportunities, to protect against fraud and crime. Communications Approach: As applicable, the Operational Response Team will alert the Core Communications Team that a situation requiring communications preparation has arisen. The Core Communication Team will review the details of any pending/developing situation, will assemble an Event Crisis Team, and will make recommendations to proceed with the appropriate response protocol based on the immediacy and severity of the crisis. Proactive: If fraudulent activity is severe or moderate, a proactive media relations and employee communications approach may be required.

Hypothetical Example: An employee embezzles millions from a System association and is arrested for the theft.

Key Audiences: Immediate, proactive communications materials should be created and distributed to: o Media o Investors o Borrower-owners o Select System employees as appropriate o The Farm Credit Administration o Members of Congress o Others as appropriate

Communications Tactics and Materials: The Event Crisis Team should develop appropriate communications tools including: o Talking points and FAQs o Customer and employee letters o Press releases o System and third-party media statements, interviews, bylined articles, blog posts, Web site

updates and Tweets o One-on-one phone calls or meetings with key audiences, such as Funding Corporation

officials and key investors, borrowers, Members of Congress, FCA officials, etc.

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Situational Talking Points: The specific details of the real event or crisis will help to shape the appropriate talking points. The Event Crisis Team should identify key facts to complete the following: o Clarify that the employee embezzlement occurred (how/when), and is being addressed by

(positive factor such as how the bank’s security procedures identified the theft quickly). o Put the situation in context by outlining the size/extent of the embezzlement loss in

comparison to the overall System assets. o Put into context who is impacted by this fraud (borrower-owners, specific associations,

others). o Outline any plans that are/will be in place to eliminate the opportunity for a similar fraud to

be perpetrated again.

Topical Talking Points: The Event Crisis Team should utilize and bridge back to the following general System talking points at every opportunity: o [Impacted organization] is committed to behave ethically, is open and transparent and

complies with all laws and regulations. o [Impacted organization] has a zero-tolerance policy for unethical or illegal behavior and has

a long track record of taking swift, decisive action in the rare case that fraud is discovered. o [Impacted organization] has an extensive system of checks and balances that contributed to

the discovery of the unauthorized activity. o [Impacted organization] is working closely with law enforcement, FCA and the Department of

Justice to determine key facts in this case and bring the issue to resolution, including a process by which [impacted borrowers or other parties] will be made whole.

o The System monitors and embraces anti-fraud rules and procedures, which align with its commitment to safeguarding financial funds and the financial health of the System.

o Due to strong risk management practices, the System has built a significant base of strong earnings, good credit and robust capital levels to mitigate the impact of any perpetrated fraud.

Responsive: If the fraudulent activity is minor, a reactive or responsive mode is appropriate, and may be referred back to the impacted bank or association for local management.

Hypothetical Example: A borrower collaborates with a System employee to obtain an unfair advantage or favorable financial terms not normally available to System borrowers.

Key Audiences: Communications materials should be created and distribution prioritized based to relevant/impacted audiences, which may include: o Select System employees as appropriate o Others as appropriate

Communications Tactics and Materials: The Event Crisis Team should develop appropriate communications tools including: o Internal talking points o Updates to fraudulent activity documents

Situational Talking Points: The situational topical talking points utilized in the proactive scenario can also be utilized in a responsive situation.

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Topical Talking Points: The Event Crisis Team should utilize and bridge back to the following general System talking points at every opportunity: o The System has a zero tolerance for fraudulent activity of any kind, and will vigorously

pursue every available legal option to punish the perpetrators of these crimes. o System banks and associations are federally regulated entities with a positive history of

stability, close oversight and secure funds. o The System monitors and embraces anti-fraud rules and procedures, which align with its

commitment to safeguarding financial funds and the financial health of the System. o Due to strong risk management practices, the System has built a significant base of strong

earnings, good credit and robust capital levels to mitigate the impact of any perpetrated fraud.

Questions To Consider: Below are some questions that could potentially be asked and should be considered when preparing talking points, FAQs and media interview requests. Note: use good judgment in determining the types of questions that are appropriate for use in an external document.

What is the size or extent of this fraud?

Who is impacted by the fraud? The bank or association? Borrowers? Others?

If so, are borrowers or others aware of the fraud and its level of impact? (i.e. In terms of overall dollars involved, the amount in relation to their overall participation in the System, and in relation to their personal financial situation, if known)?

Does it involve only one bank or association or others?

To what extent does the situation impact the entity‟s day-to-day operations? Its longer-term operations? How? Does it materially impact the financial soundness of the organization?

Can the alleged fraud be „cured?‟ If so, in what time period and by what means? If not, why not? What are next steps toward recovery for impacted parties?

Who is involved in perpetrating the fraud? A high-ranking organization official? An employee? A borrower? A person outside the organization?

How many individuals are involved?

Were System policies and safeguards to prevent fraud in place and being followed? If not, what were the key break-downs?

Additional Resources – A Local Look: A Systemwide crisis will have national, local and community implications. As appropriate, banks and associations may need to localize their response as part of the larger, overall national crisis plan. Questions to consider at the local level include:

Do you have a resource (such as the Web sites of state banking authorities or state attorney general office) for local statistics on financial fraud? Are these statistics appropriate to use to bring perspective to the overall incidence of fraud in the state, or to the association‟s specific fraud incident?

What are the most immediate impacts to existing borrower-owners in your area? And what type of information do you need to address their immediate concerns?

What actions have been taken, or cooperation has been offered by your organization to help resolve the situation and help the association and/or borrowers recover?

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Are there System or local experts available for interviews or quotes in local news releases/response statements?

Are there credible local third parties (i.e. state attorney general‟s office, local chamber of commerce official, local police department, etc.) who can reinforce bank or association messaging in a news release or response statement?

Can you/should you identify and include statistics on the local impact of this fraud locally (number of incidents, types, amount defrauded, etc.) in your messaging?

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G. SAMPLE 3: Widespread Delinquency or Foreclosure Crisis Synopsis: The Farm Credit System holds a significant percentage of U.S. agriculture loans, making it the leading agricultural lender in the country. Strong, focused underwriting standards and risk management have positioned the System to weather financial downturns with a significant capital base, good earnings and fewer foreclosures than many other financial entities. The System‟s historical non-performing loan rates are low, but global financial challenges could put pressure on the industry. The interrelated nature of the agriculture industry means that any significant domestic or international financial situation, resulting from extended recessions, depressed housing and real estate markets, growing unemployment rates, and declines in commodity prices, could have a broad impact across many industry sectors. While some agricultural producers may be better positioned against global financial crises, experts agree that significant financial downturns may prove to be too much for other borrowers, resulting in a widespread customer delinquency or foreclosure crisis. Communications Approach: As applicable, the Operational Response Team will alert the Core Communications Team that a situation requiring communications preparation has arisen. Because a delinquency/foreclosure crisis has the potential to impact the entire System, any anticipated or pending crisis should be immediately addressed. The Core Communication will review the details of each situation, as outlined below, will assemble an Event Crisis Team, and will make recommendations to proceed. Proactive: If a delinquency/foreclosure crisis is widespread or well-publicized, inciting customer or investor panic, a proactive investor and media relations and employee communications approach is required.

Hypothetical Example: A dramatic drop in ethanol, livestock, poultry, dairy and forestry commodity prices have resulted in massive System loan delinquencies and losses.

Key Audiences: Immediate, proactive communications materials should be created and distributed to: o Borrower-owners o Select System employees as appropriate o Media o Investors o Dealers o Ratings agencies o The Farm Credit Administration o Members of Congress o Others as appropriate

Communications Tactics and Materials: The Event Crisis Team should develop appropriate communications tools including: o Talking points and FAQs o Press releases

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o System and third-party media statements, interviews, bylined articles, blog post, website updates and Tweets

o Speaking engagements o One-on-one phone calls or meetings with key audiences

Situational Talking Points: The specific details of the real event or crisis will help to shape the appropriate talking points. The Event Crisis Team should identify key facts to complete the following: o Explain that the current System entity financial situation is driven by (explain the

background/cause), and is being addressed by (positive factor that has or will support a correction of the situation).

o Put the situation in context by outlining the size/extent of the System entity delinquency/foreclosure in comparison to performing assets.

o Attempt to answer the question as to whether the delinquency/foreclosure can be cured. If so, what time period and by what means?

o Put into context who is impacted by this crisis (specific associations, investors, global bank community, others).

o Outline any plans that are/will be in place to help minimize the length or severity of the situation

o Outline how the System is helping members get through this time.

Topical Talking Points: The Event Crisis Team should utilize and bridge back to the following general System talking points at every opportunity: o The System manages credit risk through a thorough assessment and monitoring of an

individual borrower‟s credit risk profile based on their credit history, repayment capacity, financial position and collateral.

o Repayment capacity focuses on the borrower‟s ability to repay the loan based on cash flows from operations or other sources of income.

o We closely monitor large outstanding loan performance and qualty within each bank District and communicate across the System to obtain a full picture of the largest loan exposures.

o The System is recognized for its diversity in loan participations and other avenues to limit our exposure to a crisis in a specific commodity segment

o The System has extensive programs in place to protect borrowers‟ rights in the unfortunate event of foreclosure. These programs ensure that System lenders and borrowers explore numerous options to refinance or restructure loans, thus allowing borrowers to maintain assets and continue making payments on their loan.

** Also refer to credit risk management practices in the Annual Information Statement to build

additional key messages based on what’s already been publicly disclosed. Responsive: If the delinquency/foreclosure crisis is evident by one or more financial indicators, a reactive or responsive approach is appropriate, and the System leadership will focus most efforts on crisis avoidance.

Hypothetical Example: Other credit and lending businesses are experiencing higher levels of foreclosures and delinquencies, garnering increased media attention and analyst scrutiny. This has motivated media, investors and other third-party entities to begin inquiring about the state of the System and the likelihood of a similar, major crisis.

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Key Audiences: Immediate, proactive communications materials should be created and distributed to: o Borrower-owners o Media o Investors o Members of Congress o Select System employees as appropriate o Others as appropriate

Communications Tactics and Materials: The Event Crisis Team should develop appropriate communications tools including: o Talking points and FAQs o Internal communications

Situational Talking Points: o Strong, focused underwriting standards and risk management practices have positioned

Farm Credit to weather financial downturns with a significant capital base, good earnings and fewer foreclosures than many other financial entities.

o Our non-performing assets remain relatively low as a percentage of all System loans and continue to be better than the commercial banking industry as a whole.

o Many of our borrowers are diversified in their operations and many have secondary and tertiary cash flow sources that can help them weather the storm, thus reducing the overall number of foreclosures, especially compared to borrowers in other industries.

o We closely monitor large outstanding loan amounts within each bank District and communicate across the System to obtain a full picture of the largest loan exposures.

o Based on all of this, Farm Credit is confident in our ability to avoid large foreclosures/delinquencies.

Topical Talking Points: o We are a federally regulated entity with a positive history of close oversight, as well as

sound and prudent management. o We manage credit risk through a thorough assessment and monitoring of an individual

borrower‟s credit risk profile based on their credit history, repayment capacity, financial position and collateral.

o Repayment capacity generally focuses on the borrower‟s ability to repay the loan based on cash flows from operations or other sources of income.

o We have taken strategic action to ensure that System risk levels remain manageable during economic and financial crisis situations.

o We closely monitor large outstanding loan amounts and credit ratings within each bank District and communicate across the System to obtain a full picture of the largest loan exposures.

o The System employs diversity in loan participations and other avenues to limit our portfolio exposure to a crisis in a specific commodity segment

o The System has extensive programs in place to protect borrowers‟ rights in many situations and help to avoid the unfortunate event of foreclosure. These programs ensure that System lenders and borrowers exhaust numerous options to refinance or restructure loans, thus allowing borrowers to maintain assets and continue making payments on their loan.

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Questions To Consider: Below are some questions that could potentially be asked and should be considered when preparing talking points, FAQs and media interview requests. Note: use good judgment in determining the types of questions that are appropriate for use in an external document.

What is the impact of delinquencies/foreclosures in terms of number of impacted borrowers and dollars?

What is the percentage of delinquencies/foreclosures in relationship to the total revenues of the System or to individual System associations and banks?

What is the extent and impact of the delinquency/foreclosure crisis in terms of investors, customers employees, others?

Is there any particular System entity that has been more heavily impacted? Which one? How?

What region has been most vulnerable to delinquencies/foreclosures? Least vulnerable?

What safeguards do you have in place to reduce delinquencies/foreclosures?

How is current government legislation impacting the System‟s delinquency/foreclosure rates?

How have delinquencies impacted the organization? Is it financially sound?

How did the System get in this delinquency/foreclosure situation? Did you see it coming?

What has been the overall impact on the System? Is it financially sound?

What programs do we have in place and how can we take to help our borrowers understand their options?

Additional Resources – A Local Look: A Systemwide crisis will have national, local and community implications. As appropriate, banks and associations may need to localize their response as part of the larger, overall national crisis plan. Questions to consider at the local level include:

Are there statistics that will bring perspective to the overall incidence of delinquencies/ foreclosures in your community?

Who are the System experts that could be available for interviews or quotes on delinquency/ foreclosure?

Are there implications for your community that would make it undesirable for you to be quoted and should you thus direct media to a third party?

Is there a third party who can reinforce the System association or bank messaging in a news release or response statement?

Is there something about your local community that makes you particularly vulnerable to this issue?

Does this issue have implications beyond your district?

Are there experts at your local land grant university that could help?

Are there local producers in your community who are heavily impacted by this that might contribute to negative media coverage for your association or the System?

Have you consulted the Event Crisis Team to take advantage of System-wide messaging that can support your efforts?

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H. SAMPLE 4: Data Security Breach Synopsis: Despite companies‟ best efforts to protect their information and assets, data breach is on the rise. Nearly all U.S. states and the District of Columbia have enacted legislation requiring notification of security breaches involving personal information. While these laws vary by state, all require immediate notification of affected parties and a prompt investigation of the occurrence. While the Farm Credit System has established guidelines to safeguard member information, the types of security procedures System banks and associations employ today are varied. A data security breach would have a major impact on the System and its borrower-owners and trust of the brand and the organizations would be compromised. The potential financial impact could be significant. Given state laws, as well as the need to protect the System‟s brand, rapid communications strategies must be enacted to meet state requirements. In addition, communications must reassure stakeholders that the data vulnerabilities have been corrected and stringent controls are effectively in place. Communications Approach: As applicable, the Operational Response Team will alert the Core Communications Team that a situation requiring communications preparation has arisen. Because a data security breach has the potential to negatively impact the entire System, any crisis must be immediately addressed. The Core Communication Team will review the details of each situation, as outlined below, assemble an Event Crisis Team, and make recommendations to proceed. Proactive: If a major data or security breach has occurred, with severe impacts to the privacy and integrity of System and borrower information, a proactive approach including media relations, public policy and employee communications is required.

Hypothetical Example: The System‟s IT infrastructure is compromised and sensitive, personal data of borrower-owners is stolen or accidentally released.

Key Audiences: Immediate, proactive communications materials must be created and distributed to: o Borrower-owners (as required by any applicable state laws and before any media outreach) o Investors o The Farm Credit Administration o Members of Congress o Select System employees as appropriate o Consumer reporting agencies (as required by the state in which the fraud occurred and the

number of affected customers) o Third party/external stakeholders o Media commensurate with severity o Others as appropriate

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Communications Tactics and Materials: The Event Crisis Team should develop appropriate communications tools including: o Customer notification materials including statement, FAQs, contact information o News release and fact sheet o Talking points o Third party expert quotes/statements o Web site statement o Internal communications

Situational Talking Points: The specific details of the real event or crisis will help to shape the appropriate talking points. The Event Crisis Team should identify key facts to complete the following: o Confirm state law(s) for affected state(s) regarding data breach notification requirements o Put the situation in context by outlining the extent of the breach, what is known, and a

summary of the investigation taking place o Put into context who is impacted by the data breach and what communication is happening

with them o Outline any plans that are/will be in place that will correct the cause of the data breach and

ensure it won‟t occur in the future o Outline communications efforts to potentially affected entities in accordance to state law(s)

Topical Talking Points: The Event Crisis Team should utilize and bridge back to the following general System talking points at every opportunity: o Farm Credit‟s strong risk management processes ensure prompt discovery and reporting of

issues of this nature. o Farm Credit‟s security meets the highest industry standards and its professional teams

constantly monitor and manage changes in data technology. o Farm Credit has an extensive redundancy program in place to ensure protection of

customers‟ data.

Responsive: If a potential data or security breach has been identified, but has been cured, and no borrowers or public entities have been harmed, a reactive or responsive mode is appropriate. In this case, System leadership will focus efforts on reviewing and implementing security changes and communicating strategies to affected employee groups.

Hypothetical Example: The security team identified a potential data breach and it was communicated internally. While no data was compromised or any borrower or customer information affected, a review of the system and processes is necessary.

Key Audiences: Immediate, proactive communications materials must be created and distributed to: o Select System employees as appropriate

Communications Tactics and Materials: The Event Crisis Team should develop appropriate communications tools including: o Internal talking points o Updates to process documents and data security standard information o Training of any new changes to processes or systems

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Situational Talking Points: The specific details of the real event or crisis will help to shape the appropriate talking points. The Event Crisis Team should identify key facts to complete the following: o Put the situation in context by outlining the extent of the breach, what is known, and a

summary of the investigation taking place o Outline any plans that are/will be in place that will correct the cause of the data breach and

ensure it won‟t occur in the future o Outline communications plans for internal audiences that need to be aware of what occurred

and the action plan to resolve

Topical Talking Points: The topical talking points utilized in the proactive scenario can also be utilized in a responsive situation.

Questions To Consider: Below are some questions that could potentially be asked and should be considered when preparing talking points, FAQs and media interview requests. Note: use good judgment in determining the types of questions that are appropriate for use in an external document.

When was this security breach discovered?

How was it discovered?

By whom was it discovered?

What is the extent of the breach in terms of data exposed/funds lost/other damage to the System and/or borrowers?

Who is involved in the breach? Customers? Employees? Others?

If the breach was intentional, has anyone been arrested?

If the breach was intentional, how were they able to perpetrate this crime?

How will this impact the organization? Is it financially sound?

What are the state(s) requirements for investigation and notification of affected parties?

What safeguards did the organization have in place to ensure against security breaches?

As a result of this incident, what will the organization do to ensure it doesn‟t happen again? Additional Resources – A Local Look: A Systemwide or Districtwide crisis will have national, local and community implications. As appropriate, banks and associations may need to localize their response as part of the larger, overall national crisis plan. Questions to consider at the local level include:

Have you consulted the Event Crisis Team to take advantage of Systemwide messaging that can support your efforts?

Do you have a resource (such as the Web sites of state banking authorities or state attorney general) for local statistics on data security breaches? Are these statistics appropriate to use to bring perspective to the association or bank‟s current situation?

What are the most immediate impacts to existing borrower-owners in your area? And what type of information do you need to address their immediate concerns?

What actions have been taken by your organization to help resolve the situation and help the association and/or borrowers recover?

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Are there System or local experts available for interviews or quotes in local news releases/response statements (consider technology, crime and data security experts, as appropriate)?

Are there credible local third parties (i.e. state attorney general‟s office, local chamber of commerce official, local police department, etc.) who can reinforce System messaging in a news release or response statement?

Can you/should you identify and include statistics on the local impact of this breach (number of incidents, types, amount defrauded, etc.) in your messaging?

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I. SAMPLE 5: Funding Crisis Synopsis: The Farm Credit System and the Federal Farm Credit Banks Funding Corporation have a major impact on credit and liquidity for America‟s agriculture industry. The System‟s strong risk management practices and significant base of capital, good earnings and credit quality creates a stable position. This, along with the fact that investors are protected by the assets of the self-funded Farm Credit System Insurance Fund, helps to protect the System from a funding crisis. However, global and U.S. market conditions constantly fluctuate and during a downturn can have an impact on even the most stable and secure organizations. The Funding Corporation and System leadership continue to closely monitor the legislative, regulatory and market environment. A variety of market or credit events could create potential risk, challenges or changes to our Government Sponsored Enterprise status. Communications Approach: As applicable, the Operational Response Team will alert the Core Communications Team that a situation requiring communications preparation has arisen. The Core Communication Team will review the details of any pending/developing situation, will assemble an Event Crisis Team, and will make recommendations to proceed with the appropriate response based on the immediacy and severity of the crisis. Proactive: If a funding crisis is imminent, or there is wide, well-publicized speculation of a funding crisis or investor panic, a proactive investor and media relations, public policy and employee communications approach is required.

Hypothetical Example: A major investor exodus results in a significant credit freeze that impacts many or all System banks and associations, and ultimately the ability to lend to borrowers.

Key Audiences: Immediate, proactive communications materials should be created and distributed to: o System Banks and Associations o Media o Investors o Farm organizations and commodity groups o Ratings agencies o Dealers o The Farm Credit Administration o Members of Congress o Federal Reserve o U.S. Department of Treasury o Borrower-owners o Select System employees as appropriate o Others as appropriate

Communications Tactics and Materials: The Event Crisis Team should develop appropriate communications tools including:

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Talking points and Q&A

Customer and employee letters

Press releases

Dealer briefings

System and third party media statements, interviews, bylined articles, blog posts, Web site updates and Tweets

Advocate engagement – such as letter writing campaign

Traditional and online advertising

Speaking engagements

One-on-one phone calls or meetings with key audiences, such as Funding Corporation officials, key investors, borrowers, Members of Congress, FCA officials, etc.

Situational Talking Points: The specific details of the real event or crisis will help to shape the appropriate talking points. The Event Crisis Team should identify key facts to complete the following:

Explain that the current funding situation is driven by (explain the background/cause), and is being addressed by (positive factor that has or will support a correction of the situation).

Put the situation in context by outlining the size/extent of the funding shortfall in comparison to the overall amount of lending that the system has done in the current year/quarter, or in this segment of the agriculture industry, or in comparison to some other relevant metric.

Put into context who is impacted by this funding crisis (specific System districts, investors, global bank community, others).

Outline any plans that are/ will be in place that will help to minimize the length or severity of the situation.

Outline how the System is raising its profile and investments among new investors to infuse additional funds into the System.

Topical Talking Points: The Event Crisis Team should utilize and bridge back to the following general System talking points at every opportunity:

Due to strong risk management practices, the System has built a significant base of strong earnings, good credit and robust capital levels.

The Federal Farm Credit Banks Funding Corporation is recognized for its diversity in debt security products that complement the many different loan demands of the agricultural community.

U.S. agriculture plays a vital role in maintaining the health of the overall economy in the United States and around the world.

The System bonds have a long legacy of providing a stable investment for investors due to solid financial reporting, strong ethics and responsiveness to the System‟s mission.

The System‟s co-op structure is an important advantage and source of stability in these tough economic conditions. The System plays an integral part in helping create jobs and support incomes in rural areas.

The FCA‟s tightening of capital and risk management requirements in recent years, and the steps taken to ensure continuous funding of the System‟s needs, have helped mitigate the impact of the problems.

Responsive: If one or more indicators are present, which may be signs of a future crisis, a reactive or responsive response is appropriate. In this case, the Federal Farm Credit Banks Funding Corporation, along with other appropriate System leaders, will focus efforts on crisis avoidance.

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Hypothetical Example: A reduction in the Funding Corporation‟s ability to utilize its array of fundraising tools fully puts a moderate strain on its ability to infuse new lendable funds into the System, but does not rise to the state of a severe credit freeze.

Key Audiences: Communications materials should be created and distribution prioritized based to select audiences, which may include:

Key investor sources, dealers and ratings agencies

Select impacted or soon-to-be-impacted borrower owners

The most heavily impacted System banks and associations

Affected System employees

Communications Tactics and Materials: The Event Crisis Team should develop appropriate communications tools including:

Development of talking points and Q&A if necessary

Customer and employee letters

Distribution of a geographically or industry-targeted media statement may be appropriate to promote key facts and to preempt misinformation or additional concerns in the market place

Situational Talking Points: The specific details of the real event or crisis will help to shape the appropriate talking points. The Event Crisis Team should identify key facts to complete the following:

The current funding situation is driven by (explain the background/cause), and is being addressed by (positive factor that has or will support a correction of the situation).

Put into context who is impacted by this funding situation (specific associations, industries, borrowers).

Put the situation in context by outlining the size/extent of the isolated funding issues in comparison to the overall health and strength of the System (consider facts like the amount of lending that the system has done in the current year/quarter, or in this segment of the agriculture industry, or in comparison to some other relevant metric).

Outline any plans that are/will be in place that will help to minimize the length or severity of the situation.

Topical Talking Points: The Event Crisis Team should utilize and bridge back to the following general System talking points at every opportunity:

Due to strong risk management practices, the System has built a significant base of strong earnings, good credit and robust capital levels.

The Funding Corporation is recognized for its diversity in debt security products that complement the many different loan demands of the agricultural community.

Questions To Consider: Below are some questions that could potentially be asked and should be considered when preparing talking points, FAQs and media interview requests. Note: use good judgment in determining the types of questions that are appropriate for use in an external document.

Does the U.S. Government guarantee the Farm Credit Debt Securities?

What is the impact of the funding crisis in terms of investors, borrowers, employees, others?

Is there any particular bank or Association that has been more heavily impacted?

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What plans do you have in place to alleviate the crisis?

Will the U.S. Government offer the System a „bailout‟ as a result of this crisis? Additional Resources: A Local Look: A Systemwide crisis will have national, local and community implications. As appropriate, banks and associations may need to localize their response as part of the larger, overall national crisis plan. Questions to consider at the local level include:

Have you consulted the Event Crisis Team to take advantage of Systemwide messaging that can support your efforts?

What are the most immediate impacts to existing borrowers in your area?

What type of information do you need to address their immediate concerns?

Is there a local expert who can provide data that would be relevant to your local media?

Is there something about your local community or borrower demographics that make you particularly vulnerable to this issue?

Are there implications for your community that would make it undesirable for you to be quoted and should you therefore direct media to a third party?

Does this have implications beyond your district and should you engage others within the Farm Credit System for assistance?

Are there experts at your local land grant university that could help you to respond to this issue, or serve as a spokesperson or other resource?

Is there a local producer in your community who is heavily impacted by this or could serve as an expert?

Do you have alternative funding streams in place that could help your association manage through this crisis?

Do you have loan applications in progress for which the outcome will be impacted by this crisis?

Do you expect to be in the position of turning new borrowers away soon or in the short term?

If pending or future borrowers will be adversely impacted in the near future, what contacts within the System or local resources can you identify to assist with messaging and lending alternatives?

Are there local or state resources for statistics on financial funding challenges, and market factors contributing to them? Can you use these statistics to bring perspective to current financial funding trends, recovery and resolutions?