◆ SpookStack

SECRET To: a From: Office of the General Counsel Re: 278-HO-C1229736-VI0, 3/02/07 deemed to have been designed to ensure the protection of individual rights are generally not reported to the IOB,. The FBI Inspection Division is required, however, to maintain records of such administrative violations for three years so that the Counsel to the IOB may review them upon request. The determination as to whether a matter is "administrative in nature" must be made by OGC. Therefore, such administrative violations must be reported as potential IOB matters. (U}- my NSLs are a specific type of investigative tool that allows the FBI to obtain certain limited types of information without court intervention: {1) telephone and email communications record from telephone companies and internet service providers (Electronic Communications Privacy Act, 18 U.S.C. § 2709; (2) records of financial institutions (which is very broadly defined) (Right to Financial Privacy Act, 12 U.$.C.§ 3414 (a) (5) (A); (3) a list of financial institutions and consumer identifying information from a credit reporting company {Fair Credit Reporting Act, 15 U.S.C. §§n 168iu(a) and (b); and (4) full credit report in an international terrorism case (Fair Credit Reporting Act, 15 U.S.C. § 168v). NSLs may be issued in conformity with statutory requirements, including 18 U.S.C. § (S) Here, during an authorized investigat} in response to the properly served NSL, the FBI obtained containing information beyond what it is legall Orize oO receive. The FBI, having ascertained [____"re beyond the scope of the NSL, forwarded the unaske or information to the ADC for sequestering and redacted their files to reflect only information responsive to the NSL. (U) +. 6 By agreement with the Counsel to the IOB, it is Our opinion that this error is not reportable to the IOB. A record of this decision should be maintained in the control file for future review by the Counsel to the IoB. SECRET 3 bl bl b7D