◆ SpookStack

Approximately a year ago, when we were unable to tick and lie numbers in the database to previously reported numbers, we recognized that our technology was woefully inadequale. We began at that point to develop an automated system Lo improve our ability to collect this data. That system, in addition to improving data collection, will automatically prevent many of the errors in NSLs that we will discuss today by automating much of ihe work associated with preparing NSLs. The system will also allow us to automatically ensure that required reporting data is accurately collected. The NSL system is being designed so that the FBI employee requesting an NSL will enter daia only once. For example, an agent or analyst who wishes to get telephone toll billing records will only have to tell the system that he is seeking an ECPA NSL for toll records and type the telephone number once. The system will then automatically populate the appropriate fields in the NSL and the authorizing electronic communication. The system will ensure that the two documents match exactly and will minimize the opportunity for transcription errors that gave rise to unauthorized collections. Agents and analysts will still be required to provide the narrative necessary to explain why the NSL is being sought, the factual basis for making a determination that the information is relevant to an appropriately predicated national security investigation, and the factual basis for any determination that the NSL should include a nondisclosure provision. CAPRONI: We're optimistic that we'll be able to pilot the system this summer and roll it out to all the field offices by the end of the year. At that point, I will be much more confident thal in the future the data we provide to Congress is as accurate as humanly possible. In the meantime, we're taking several steps to correct (he numbers we previously reported, We've discussed our methodology with the LG. and we will offer him the opportunity to review our work. We're striving to have the corrected reports to Congress as soon as possible. The next significant finding of the LG. I would like to discuss this moming involved the use within one unit at headquarters of so- called exigent letters. These letters, which numbered in excess of 700, were provided to telephone companies with requests for toll billing information. All of the letters stated that (here were exigent circumstances. And many stated that federal grand jury subpoenas had been requested for the records, even though, in fact, no such requests for grand jury subpoenas has been made. From an audit and internal control perspective, the FBI did not document the nature of the emergency circumstances, did not keep copies of all of the exigent letters it provided to telephone companies, and did not keep records to track whether it had subsequently provided further legal process. Moreover, some employees told the I.G. that there was not always an emergency relating to the documents that were sought.