◆ SpookStack

the requested material so there was, in fact, no collection of information to which we were not entitled.) The balance of the 12 potential violations identified by the OIG do not, in our view, rise to the same level of seriousness as those 4. The rematning 8 involve errors thal are best characterized as arising from a lack of attention to detail, and did not result in the FBI seeking or obtaining any information to which it was not entitled. Those 8 potential violations involved errors such as using the wrong certification language im an NSL (although the appropriate certification is not materially different) and having the NSL and the EC seeking the NSL not entirely consistent. We do not excuse such lack of attention to detail, but we do net believe that such mistakes result in or cause a risk to civil liberties. In short, approximately 1° of the NSLs examined by the OIG had significant errors that were attributable to FBI actions and that had not been, but should have been, reported as PIOBs. While a 1% error rate is not huge, it is unacceptable, and we have taken steps to reduce that error rate. First, we are very concerned that of all the potential IOBs involving mistakes in NSLs attributable to the FBI (whether previously reported or not), 3 involved the same mistake: namely, issuimg au NSL for a full credit report in a counterintelligence investigation. In order to ensure that this particular error is fully rectified, the FBI ordered all field offices to examine all counterintelligence files in which Fair Credit Report NSLs have been issued since January 1, 2002 in order to ascertain Whether the file contains a full credit report. If it does, the credit report must be removed from the file, sequestered with the field office’s attorney, and a PIOB must be reported to OGC. The results from that search are due to headquarters by April 16, 2007. Several other steps we have taken will, we believe reduce the ltkelthood that the FBI will commut the other mistakes in the future. First, as indicated previously, the FBI is developing an