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[Cover Letter]
Center for Regulatory Effectiveness
11 Dupont Circle, NW
Washington, DC 20036
Mr. Robert E. Feldman
Executive Secretary
Federal Deposit Insurance Corporation
Washington, DC 20429
RE: CRE Comments on Proposed Data Quality Guidelines
Dear Mr. Feldman:
I am writing on behalf of the Center for Regulatory Effectiveness (CRE) to share
with you the Center's comments on your agency's recently proposed information
quality guidelines, issued pursuant to the Data Quality Act (44 U.S.C. § 3516,
note). As you may be aware, the Center had a leading role in passage of the Act
and maintains a strong ongoing interest in this important issue. I invite you to
visit the CRE web site (www.TheCRE.com) for further details.
In light of the deference the public pays to governmental information and its
significant role in regulation and resource allocation in both the public and
private sectors, the quality of the federal government's information is a matter
of critical importance. Consequently, CRE appreciates this opportunity to
provide its views and recommendations to the agency in order to achieve the
intent of Congress in enacting this new "Good Government" law and of
OMB in promulgating its guidelines containing government-wide Data Quality
standards (67 Fed. Reg. 8452, Feb. 22, 2002).
To assist the agency in meeting its obligations under the Data Quality Act and
OMB's guidelines, CRE has prepared and enclosed the following attachments:
(1) CRE General Comments to All Federal Agencies Related to Data Quality
Guidelines
This paper outlines a number of cross-cutting issues related to Data Quality
guidelines which are applicable to all agencies and contains CRE's
recommendations on how such issues should be addressed.
CRE strongly believes that proper action on these key issues will help ensure
that the guidelines issued by the agency are workable, effective, and in keeping
with the requirements of both the statute and the government-wide standards set
by OMB.
In the paper, CRE identifies and evaluates a number of agency approaches to
these cross-cutting issues. Such examples include positive agency proposals
which might be emulated, as well as problematic agency proposals which should be
avoided.
(2) Legal Memorandum on the Data Quality Act's Applicability to All Public
Information
CRE has been troubled by several agencies' attempts in their proposed guidelines
to exempt certain categories of public information from the Data Quality Act's
standards. Consequently, CRE retained Multinational Legal Services (MLS) to
examine this important issue. Attached is a legal memorandum which summarizes
the MLS inquiry into the Data Quality Act's applicability to all public
information. In short, MLS found:
Analysis of the Data Quality Act, the Public Information provisions of the
Paperwork Reduction Act, and legislative history demonstrate that Congress
intended Data Quality Act standards to apply to all public information.
Thus, neither OMB nor any other federal agency has discretion to violate this
legislative intent by exempting categories of information from the standards set
forth pursuant to the Data Quality Act.
Finally, CRE believes that in light of the ongoing importance of the Data
Quality issue, all federal agencies should adopt Data Quality as a Performance
Goal in its Performance Plan under the Government Performance and Results Act.
Not only would this assist the agency in regularly monitoring and improving its
information quality activities, but it would also serve to increase the
transparency of the agency process for Congress and the interested public.
CRE would be happy to answer any questions you might have related to its
comments and supporting materials. Please contact us at (202) 265-2383, if we
might be of further assistance.
Sincerely
Jim J. Tozzi
Member, CRE Board of Advisors
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