Office of Comptroller of the Currency …

                    Office of Comptroller of the Currency
    Procedures for Implementation of Section 515 Information Quality Act
                             (Public Law 106-554)

Introduction

Section 515 of the Treasury and General Government Appropriations Act for Fiscal Year 2001,
Public Law 106-554, (Section 515) requires federal agencies to issue procedures to ensure and
maximize the quality, utility, objectivity, and integrity of disseminated information. As a
Department of the Treasury (Treasury) bureau, the OCC follows the Treasury guidelines.

Purpose

The Office of the Comptroller of the Currency (OCC) charters, regulates, and supervises national
banks to ensure a safe, sound, and competitive banking system that supports the citizens,
communities, and economy of the United States. The OCC disseminates information on a
variety of banking and economic topics to a broad spectrum of individuals and organizations.
The goal of the OCC's procedures is to share the processes that the OCC uses to ensure the
quality of disseminated information and to provide a method by which affected persons may seek
or obtain correction of information that the OCC disseminates.

Scope

These procedures apply to information disseminated to the public in any medium, whether
printed, electronic, or other form.

Examples of Information Covered by these Procedures:

   -    Speeches and reports on various banking and economic topics that communicate official
        OCC positions
   -    Statistical releases
   -    Research and staff studies initiated or sponsored by the OCC
   -    Educational brochures, booklets, and pamphlets

Examples of Information Not Covered by these Procedures

   -    Press releases
   -    Correspondence with individuals or persons
   -    Public filings
   -    Research and staff studies not initiated or sponsored by the OCC
   -    Hyperlinks to information that others disseminate

The effective date of these procedures is October 1, 2002. These procedures will cover
information disseminated by the OCC on or after the effective date, regardless of when the
information was first disseminated.
The OCC procedures are offered only as guidance and are not intended to be, and should not be
construed as, legally binding regulations or mandates. They are not legally enforceable and do
not create any legal rights or impose any legally binding requirements or obligations on the OCC
or the public. Nothing in these procedures affects any otherwise available judicial review of
agency actions.

Information Quality Procedures

The OCC takes pride in the quality, objectivity, utility, and integrity of the information that it
disseminates to the public. Existing information dissemination processes provide for rigorous
internal review and approval of information products prior to their dissemination to ensure that
the quality of information released to the public is useful, accurate, appropriate, and
uncompromised.

Utility

The OCC ensures the utility or usefulness of information disseminated to its intended users,
including the public, by reviewing analytical and statistical publications and other resources to
ensure topics and issues addressed remain relevant and timely. The OCC's subject matter
experts are fully involved in issues related to the business of banking. This permits them to
respond in a timely manner to changing needs in the banking industry through issuance of new
information products or the discontinuation of information products that are no longer useful or
relevant to the OCC's intended users.

Objectivity

The OCC disseminates information only after ensuring that the substance of the information is
accurate, reliable, and unbiased and that it is presented in such a manner. The OCC achieves
objectivity by using reliable data sources and sound analytical techniques, having information
products prepared by qualified people using proven methods, and carefully reviewing the content
of information products.

The OCC's data sources include, but not limited to, data reported to the OCC by its regulated
entities, information obtained from other government agencies, and information provided by
other reliable outside sources. After receiving information from external sources, the OCC
assigns qualified personnel to carefully review the content of all information. The OCC's
information systems include rigorous quality checks including complex business rules,
reasonability checks, and checks for redundancies. The OCC's methods of verifying the
substance of information will, in general, be transparent to the user, except in situations in which
it must protect proprietary or confidential information. Transparency is achieved by referencing
sources, identifying the statistical methods employed, and utilizing sound research and analytical
techniques. These systems and processes enable the OCC to substantiate the quality of
information it disseminates.




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Influential Information, Reproducibility, and Transparency

The term influential, when used in the phrase "influential scientific, financial, or statistical
information," means that the OCC can reasonably determine that the dissemination of the OCC's
information does have or will have a genuinely clear and substantial impact at the national level
and on major public and private policy decisions as they relate to the OCC's mission of ensuring
the safety and soundness of national banks.

Influential information is subject to reproducibility and transparency requirements.
Reproducibility of information refers to the ability, in principle, for a qualified individual to use
the documentation of methods, assumptions, and data sources to achieve substantially the same
information, subject to an acceptable degree of imprecision. Transparency means that the
sources, methods, procedures, references, and assumptions employed to create the information
are provided, except in circumstances where information is confidential and therefore cannot be
released to the public.

Integrity

The OCC protects disseminated information from unauthorized access or revision and ensures
that information has not been compromised through corruption or falsification. The OCC
maintains a comprehensive security program to protect critical systems. This program includes
comprehensive information security policies and safeguards designed to protect information
assets from unauthorized access, modification, destruction, or disclosure. The OCC has
implemented specific technologies, including virus detection systems, to secure its internal
network from external attacks. An intrusion detection system continuously monitors the OCC's
network and flags possible unauthorized access. Servers housing the data use specialized
software that determines if an unauthorized modification has taken place.

Procedures to Seek Correction of Information Under Section 515

In accordance with Section 515, the OCC has developed procedures to allow affected persons to
seek and obtain correction of information that the OCC disseminates. Overall, the Office of
Management and Budget (OMB), which developed and provided policy and procedural guidance
to federal agencies pursuant to Section 515, does not envision an administrative mechanism that
would burden agencies with frivolous claims. Instead, the correction process would serve to
address the genuine and valid needs of the OCC and its constituents without disrupting bureau
processes. In making determinations of whether or not to correct information, the OCC may
reject claims made in bad faith or without justification. The OCC is required to undertake only
the degree of correction that it concludes is appropriate for the nature and timeliness of the
information involved and explain such practices in the annual fiscal year report to Treasury.

The OCC's procedures permit affected persons to seek, and obtain where appropriate, correction
of information disseminated by the OCC that does not comply with Treasury guidelines.
"Affected persons" are people who may benefit or be harmed by the disseminated information.
The benefit or harm must be actual (not conjectural or hypothetical) and must be directly caused
by the information distributed by the OCC. Affected persons include groups, organizations, and



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corporations. If you are an affected person and you believe that information disseminated by the
OCC does not comply with Treasury guidelines, you may submit a request for correction of the
information. You may submit your request for correction to the OCC by mail, personal delivery,
fax, or e-mail using the following contact information.

Mailing Address:
Comptroller of the Currency
Customer Assistance Group
1301 McKinney Street, Suite 3450
Houston, Texas 77010-9050
Fax : 713-336-4301

1-800 Number:
Consumer Hot Line 1-800-613-6743

E-Mail Address:
customer.assistance@occ.treas.gov

A request for correction of information must contain the following information:

   A statement that your request is being submitted under Section 515 of Public Law 106-554.
   Contact information, including name, mailing address, fax number or e-mail address,
   telephone number, and organization affiliation (if any). The OCC needs this information to
   respond to your request and to contact you, if required.
   A description of the report, data set, or other document that contains the information you
   seek to have corrected, including, when applicable, the number or title of the document(s) in
   question, the date of release and manner disseminated.
   A description of the specific information you believe should be corrected, a detailed
   explanation of how or why the information does not comply with Treasury guidelines, a
   detailed statement of the reasons you believe the information is wrong, and a statement about
   how it should be corrected.
   A detailed explanation of how the disseminated information affects you, identifying what
   benefit or harm may come to you directly as a result of the information, and how correction
   would benefit you.

Review of Requests by the OCC

You are responsible for presenting a full and specific basis for a Section 515 request for
correction. As a preliminary matter, the OCC may determine that your request does not meet the
threshold requirements for processing. Examples of requests that may not meet threshold
requirements include: requests that do not contain sufficient information to process the request,
requests that are not from affected persons, or requests to correct information or data not subject
to these procedures. If contact information has been provided, the OCC plans to respond within
14 business days to a request for correction that is either incomplete or requires that additional
information be provided.




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Upon receipt of a properly filed request for correction, the Customer Assistance Group will
forward the request to the appropriate OCC Unit. That unit will carefully review the substance
of each request, and any supporting material, and will consider whether any change or correction
to the information or data is warranted.

Requests normally will be processed in the order in which they are received. The OCC's goal is
to respond in writing to properly filed requests within 60 calendar days of receipt. If the request
requires more than 60 calendar days to resolve, the OCC will inform you that more time is
required and indicate the reason why and an estimated response date. If the time is extended, the
OCC will notify you by mail, telephone, or e-mail.

The format of the OCC's response will depend on the character and volume of requests. For
example, if the OCC receives numerous requests about the same information, it may provide a
response through a press release or on its web site. Other requests may receive an individual
response by letter or e-mail.

Requester's Right to Appeal

If you disagree with the OCC's response to your request, you may submit a written request for
reconsideration to the OCC's Ombudsman, using the same address provided above, for
evaluation and final response. Your request may be submitted by mail, personal delivery, fax, or
e-mail. You must submit it to the OCC within 45 calendar days of the date of the OCC's initial
response to your request. You should state the reasons why the OCC should reconsider its
response, and relevant facts that, for good cause shown, were not previously presented to the
OCC. The OCC's goal is to respond in writing to a request for reconsideration within 60
calendar days of receipt. If the request for reconsideration requires more than 60 calendar days
to resolve the OCC will inform you that more time is required and indicate the reason why and
an estimated decision date. If the time is extended, the OCC will notify you by mail, telephone,
or e-mail.

Information For Which the OCC Requested Public Comments

On occasion, the OCC may disseminate a study, analysis, or other information in connection
with the issuance of a notice of proposed rulemaking or other action that involves well-
established procedures for obtaining, considering, and responding to comments from the public.
Generally, the administrative mechanisms described in these procedures do not apply to such
information. However, in unusual circumstances, the OCC will consider a Section 515 request
for correction of information disseminated in connection with the issuance of a notice of
proposed rulemaking or other action where: 1) the OCC determines that a response in advance
of the final agency action would not unduly delay issuance of the agency action; and, 2) you
demonstrate a reasonable likelihood that you will suffer actual harm from the OCC's
dissemination if the OCC does not resolve your request for correction prior to the final agency
action.




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Compliance Reporting

The OCC reports annually to the Treasury's Deputy Assistant Secretary for Information Systems
and Chief Information Officer on the number and nature of requests for correction received
regarding compliance with the Treasury guidelines concerning the quality, objectivity, utility,
and integrity of information, and how such requests for correction were resolved. The OCC
submits compliance reports to Treasury no later than November 1 following the end of each
fiscal year, with the first report due November 1, 2003. Periodically, there will be an internal
review and update of the procedures to ensure and maximize the quality of disseminated
information.

Privacy Act Statement

Collection of this information is authorized by Section 515 of the Treasury and General
Government Appropriations Act for Fiscal Year 2001, Public Law 106-554. The information
will be used to process your request for correction of information. In some circumstances, the
OCC may disclose information you submitted to a congressional office in response to an inquiry
made on your behalf; to the Department of Justice, a court, or other tribunal when the
information is relevant and necessary to litigation; or to a contractor or another federal agency to
help accomplish a function related to this process. Supplying this information is voluntary, but
failure to provide all the information may cause a delay in the processing of your request.




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