◆ SpookStack

National Security Letlers - NSLB - OGC Page 10 of 14 3/09/2006 delegation contains all the relevant NSL delegations, it is not referenced in the model EC. This is a change from the previous model ECs. If you need to view the statutory authority for these NSLs, copies of the ECPA, RFPA, and FCRA statutes can be found on the OGC main library website. In addition, the 2001 and 2005 Patriot Acts are also on the OGC main library website, APPROVAL STANDARD FOR NSLS a NSLs are reviewed by CDCs at the field office level, At headquarters, they are reviewed by NSLB. At all leveis, they must meet the legal standards set forth above, namely relevanc be HIE Otherwise, 95 a teléphone or a bank account is subject to an NSL. And that is not the standard for issuance of an NSL, The model EC now states that a full recitation of the reason for initiating and maintaining the investigation is necessary in order to justify an NSL. The reason is common sensical - there can be no reason to issue an NSL if the subject matter or issue to which it supposedly relates is not worthy of investigation or if the investigation is bas Amendment rights. er words, in order for an NSL to meet the legal standard set forth in the statutes, the reviewing party has to assure that there is a proper reason for investigating the target and not an improper reason, for instance, exercising First Amendment rights.. Moreover, the legal review that is done by the CDCs is consistent with the factual review that should be done by SACs in certifying that the NSL is relevant to an authorized national security investigation and that the investigation is not based on the exercise of First Amendment rights by a U.S.P, An SAC can no more make the required certification than the CDC can make the required legal review if presented only with barebones information of the existence of an investigation and a target's telephone or bank account. Thus, the recitation of facts about the reason for initiating and maintaining an investigation serves to support _ | b2 oo