Farm Credit Administration Chairman Michael Reyna is at the brink of a major confrontation with Congress over the FCA's National Chartering proposal. Under the chartering proposal, reckless FCS associations would be unleashed to lend anywhere within the US. However, the General Accounting Office opined in an October 17, 2000, letter that the FCA erred in not issuing its National Chartering proposal as a proposed rule, subject to public notice and comment. The GAO also said that the FCA erred by not submitting the proposal to Congress for its review under the Congressional Review Act.