Are Farm Subsidy Payment Limits Working?
Federal law caps most commodity payments at $125,000 per person per year. Yet the top recipients in the USDA database have collected millions. How?
Key Finding
The top 20 recipients averaged $58.6M each — more than 469x the annual cap. At least 1,000 recipients in our database exceeded $125K in total payments.
The $125,000 Cap — In Theory
Since the 1970s, Congress has tried to limit how much any single recipient can collect. The current cap for most commodity programs is $125,000 per "person" per year. For married couples, it's $250,000. Emergency programs like the Coronavirus Food Assistance Program had their own, often higher, limits.
The LLC Loophole
The key word is "person." Under USDA rules, an LLC or partnership qualifies as a "person." Each member of a partnership can claim their own $125K limit. A family operation structured as three separate LLCs with two partners each could theoretically collect $750,000 — six times the "limit."
In our data, 241 of the top recipients are LLCs, partnerships, or corporations, collecting a combined $1.07B.
The Top 20 Recipients
| # | Recipient | Location | Total | Payments |
|---|---|---|---|---|
| 1 | FLORIDA DEPT OF EMERGENCY MANAGEMENT | TALLAHASSEE, FL | $346.6M | 6 |
| 2 | AMERICAN CRYSTAL SUGAR CO | MOORHEAD, MN | $82.3M | 1 |
| 3 | COTTON COUNCIL INTERNATIONAL | WASHINGTON, DC | $69.3M | 66 |
| 4 | THE WESTERN SUGAR COOPERATIVE | DENVER, CO | $69.2M | 1 |
| 5 | US MEAT EXPORT FEDERATION | DENVER, CO | $66.8M | 81 |
| 6 | SOUTHERN MINNESOTA BEET SUGAR COOPERATIVE | RENVILLE, MN | $52.8M | 1 |
| 7 | FOOD EXPORT ASSOCIATION OF THE MIDWEST USA | CHICAGO, IL | $47.2M | 556 |
| 8 | MINN-DAK FARMERS COOPERATIVE | WAHPETON, ND | $46.4M | 1 |
| 9 | AGHERITAGE | STUTTGART, AR | $45.1M | 5,133 |
| 10 | FOOD EXPORT USA NORTHEAST | PHILADELPHIA, PA | $40.2M | 316 |
| 11 | US GRAINS COUNCIL | WASHINGTON, DC | $37.9M | 125 |
| 12 | WESTERN US AGRICULTURE | VANCOUVER, WA | $37.0M | 1,049 |
| 13 | WINE INSTITUTE | SAN FRANCISCO, CA | $32.2M | 177 |
| 14 | SOUTHERN US TRADE ASSOCIATION | NEW ORLEANS, LA | $30.7M | 434 |
| 15 | AGRIFUND LLC | AMARILLO, TX | $28.9M | 2,391 |
| 16 | AGRIFUND LLC | RAYVILLE, LA | $28.7M | 3,318 |
| 17 | AMERICAN HARDWOOD EXPORT COUNCIL | RESTON, VA | $28.0M | 156 |
| 18 | MICHIGAN SUGAR COMPANY | BAY CITY, MI | $27.9M | 1 |
| 19 | US DAIRY EXPORT COUNCIL | ARLINGTON, VA | $27.7M | 84 |
| 20 | US WHEAT ASSOCIATES INC | WASHINGTON, DC | $26.5M | 166 |
Why Limits Don't Work
Payment limits have three structural weaknesses: entity restructuring (splitting into multiple LLCs), program stacking (limits apply per-program, not across all programs), and emergency exceptions (disaster programs often have separate or no limits). Until Congress addresses all three, the $125K cap will remain more aspiration than reality.
📊 Data Sources
USDA Farm Service Agency payment data (1995–2024). Recipient names and amounts from FSA payment files. See the full list on our Top Recipients page.