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SECRET b2 tof __fieta Office BIE From: ice of the General Counsel Re: 278-HQ-C1229736-VI0O, 07/17/2006 (S) bl Uh - -(S¢ The Attorney General's Guidelines for FBI Foreign Intelligence Collection and Foreign Counterintelligence Investigations (NSIG) provision regarding the duration of Preliminary Investigations is primarily administrative in Nature. It was designed in part to protect the rights of United States persons by limiting the length of time that the FBI can conduct a PI without periodic oversight by the proper authorities. 4 In this inegtance, OGC is not required to report the ial IOB error because the only investigative activity which [undertook with respect to the non-USPER subject was to have he i served NSLs analyzed. b2 bIE bl (U) Based upon these facts, in accordance with the terms implementing the reporting requirements of Section 2.4 of EO 12863, it is our opinion that any error which may have been committed by Atlanta need not be reported to the IOB. (U) OGC requests that the Inspection Division retain a record of the report of a potential IOB matter for three years, together with a copy of this opinion for possible review by the Counsel to the IOB. SEQRET 3a