◆ SpookStack

(3) ni the request, since requests for[_—__—_ information and 2 subscriber information are requested Separately by the FBI. BIE SEC 2 TO: [ rrom: Office of the General Counsel b7E Re: 278-HO-C1229736-V10, 12/12/2006. bl bic b7E b7D (S)} Upon review of the d provided to it was learned that the information{ provided, purs uant to the NSL, exceeded that which was requested. The error > waS apparently a misunderstandi on its part as to the nature o bl b7D reported that they returned[___ (U} Section 2.4 of Executive Order [(E,0.) 128623, dated 09/13/1993, mandates that Inspectors General and General Counsels of the Intelligence Community components (in the FBI, the Assistant Director, INSD, and the General Counsel, oaGc, respectively) report to the IOB “concerning intelligence activities that they have reason to believe may be unlawful or contrary to Executive order cr Presidential directive.” This language was adopted verbatim from £.0. 12334, dated 12/04/1981, when the IOB was known as the President's Intelligence Oversight Board (PIOB}. By longstanding agreement between the FBI and the IOB (and its predecessor, the PIOB), this language has been interpreted to mandate the reporting of any violation of a provision of the Attorney General Guidelines for National Security Investigations and Foreign Intelligence Collection (NSIG), or other guidelines or regulations approved by the Attorney General in accordance with E.O. 12333, dated 12/04/1981, if such provision was designed in full or in part to ensure the protection of the individual rights of U.S. persons. Violations of provisions that are essentially administrative in nature need not be reported to the IOB. The FBI is required, however, to maintain records of such administrative violations so that the Counsel to the IOB may review them upon request. (U} On 03/28/2006, the FBI's National Security Law Branch (NSLB) sent a letter te the Counsel for the IOB requesting their concurrence to treat third party errors as non-reportable, though NSLB would still require the field to continue to report