Department of the Treasury

2021 Chief Freedom of Information Act Officer Report

to the Attorney General of the United States
2 

Message from the Deputy Assistant Secretary for Privacy, Transparency, and 

Records

On behalf of the Chief Freedom of Information Act Officer, I am 

pleased to present the Department of the Treasury’s (Treasury or 

Department1) 2021 Chief Freedom of Information Act Officer Report 

to the Attorney General of the United States. This report summarizes 

Treasury initiatives to comply with the Freedom of Information Act2

(FOIA) and to promote transparency and openness in its operations. 

This report covers the period of March 2020 through March 2021 (the 

reporting period). 

Inquiries about this report may be directed to the Office of Privacy, 

Transparency, and Records via phone at (202) 622-0930 or via e-mail 

at FOIA@treasury.gov. This report, as well as previous reports, can be found on the 

Department’s FOIA website under FOIA Reports. 

Ryan Law 

Deputy Assistant Secretary

Office of Privacy, Transparency, and Records 

U.S. Department of the Treasury

1 In this report, the “Department” or “Treasury” includes all of the Treasury Department’s bureaus and offices. 2 5 U.S.C. § 552
3

2021 Chief Freedom of Information Act Officer Report

To the Attorney General of the United States

Table of Contents

Message from the Deputy Assistant Secretary for Privacy, Transparency, and Records.............2

FOIA at the Department of the Treasury....................................................................4

Section I: Steps Taken to Apply the Presumption of Openness........................................6

Section II: Steps Taken to Ensure that Treasury has an Effective System in Place

 Responding to Requests....................................................................................9

Section III: Steps Taken to Increase Proactive Disclosures............................................10

Section IV: Steps Taken to Greater Utilize Technology................................................13

Section V: Steps Taken to Improve Timeliness in Responding to Requests and

 Reducing Backlogs.......................................................................................15
4

FOIA at the Department of the Treasury

FOIA administration is decentralized at the Department of the Treasury. In other words, the nine 

bureaus that comprise the Department separately receive and respond to FOIA requests:

1. Alcohol and Tobacco Tax and Trade Bureau (TTB)

2. Bureau of Engraving and Printing (BEP)

3. Bureau of the Fiscal Service (Fiscal Service)

4. Departmental Offices (DO)

5. Financial Crimes Enforcement Network (FinCEN)

6. Internal Revenue Service (IRS)

7. Office of the Comptroller of the Currency (OCC)

8. Treasury Inspector General for Tax Administration (TIGTA)

9. United States Mint (Mint)

Departmental Offices encompasses a number of Treasury program and policy offices,3

 

including, for example, the Office of Foreign Assets Control (OFAC). The Office of Privacy, 

Transparency, and Records (OPTR), situated within DO, functions as the centralized DO 

resource for FOIA administration. OPTR is also responsible for Treasury-wide policy, guidance, 

and compliance with the FOIA. The Deputy Assistant Secretary for Privacy, Transparency, and 

Records leads OPTR, and reports to the Assistant Secretary for Management, Treasury’s Chief 

FOIA Officer.

Treasury received 11,916 FOIA requests during Fiscal Year (FY) 2020. From FY 2011 through 

the present, Treasury received an average of 13,771 requests per fiscal year (See Figure 1).

3 DO also includes the Offices of the Secretary, Domestic Finance, Economic Policy, General Counsel, International 

Affairs, Legislative Affairs, Management, Public Affairs, Tax Policy, Terrorism and Financial Intelligence, and the 

Treasurer of the United States. DO statistics in this report also include requests made to the Financial Stability 

Oversight Council (FSOC, an entity chaired by the Secretary of the Treasury), the Treasury Inspector General 

(OIG), and the Office of the Special Inspector General for the Troubled Asset Relief Program (SIGTARP). For 

more information, please visit Treasury’s webpage at https://home.treasury.gov/about/generalinformation/organizational-chart.

16,776 16,610 15,040 14,107 13,992 12,368 12,434 12,535 11,936 11,916

0

10,000

20,000

FY11 FY12 FY13 FY14 FY15 FY16 FY17 FY18 FY19 FY20

Figure 1. Total Number of FOIA Requests Received at Treasury
5

In FY 2020, there was a wide disparity in the number of FOIA requests directed to individual 

Treasury bureaus. For example, IRS received 8,156 requests in FY 2020, or 68% of Treasury’s 

total FOIA requests. On the other hand, BEP, FinCEN, Mint, TIGTA, and TTB each received 

fewer than 250 requests during the same period (See Figure 2).

The Department closed 11,260 requests in FY 2020. BEP, Fiscal Service, TIGTA, and TTB 

closed as many or more requests than they received in FY 2020. 

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

9,000

IRS DO OCC Fiscal

Service

FinCEN TIGTA MINT TTB BEP

Received 8,156 1,368 1,349 382 211 209 113 91 37

Processed 7,773 1,121 1,325 401 187 212 109 91 41

Number of Requests

Figure 2. Number of FOIA requests received and processed during 

FY 2020 by Treasury Bureaus
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Section 1: Steps Taken to Apply the Presumption of Openness

A. FOIA Leadership

1. The FOIA requires each agency to designate a Chief FOIA Officer who is a senior official at 

the Assistant Secretary or equivalent level. Is your agency’s Chief FOIA Officer at this 

level?

Yes.

2. Please provide the name and title of your agency’s Chief FOIA Officer.

Trevor Norris, Acting Assistant Secretary for Management.

B. FOIA Training

3. The FOIA directs agency Chief FOIA Officers to ensure that FOIA training is offered to 

agency personnel. See 5 U.S.C. § 552(a)(j)(2)(F). Please describe the efforts your agency 

has undertaken to ensure proper FOIA training is made available and used by agency 

personnel.

During the reporting period, Treasury employees participated in a variety of training 

presented in a virtual format. For example, IRS provided FOIA training to non-FOIA IRS 

employees on a reoccurring basis and upon request. Topics included conducting proper FOIA 

searches, review efforts when locating records in response to a FOIA request, and proactive 

disclosures to the public. 

The COVID-19 pandemic presented challenges to offering in-person training activities. 

Employees were encouraged to attend virtual DOJ FOIA training, participate in on demand 

FOIA training available in Treasury’s Integrated Talent Management System, and attend the 

Department’s annual FOIA summit. 

4. Did your FOIA professionals or the personnel at your agency who have FOIA 

responsibilities attend substantive FOIA training during the reporting period such as that 

provided by the Department of Justice?

Yes.

5. If yes, please provide a brief description of the type of training attended or conducted and the 

topics covered.

A number of Treasury FOIA professionals attended training opportunities provided by the 

Department of Justice (DOJ) including FOIA for Attorneys and Access Professionals, the 

Advanced FOIA Seminar, Introduction to the FOIA, and the Litigation Seminar. Treasury 

staff also participated in DOJ’s online training modules for FOIA Professionals. Numerous 

topics covered were, including but not limited to, the FOIA’s procedural requirements and 

exemptions, workshops on individual FOIA Exemptions, basic principles for processing 
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FOIA requests from start to finish, the FOIA’s proactive disclosure requirements, the 

interface between the FOIA and the Privacy Act, overview of the FOIA, receiving and 

acknowledging FOIA requests, initial processing, statutory protections for sensitive 

information, advanced considerations for Exemptions 6 and 7(C), FOIA case law 

developments and advanced litigation considerations, basic principles for processing FOIA

requests, communication with requesters, searching for and reviewing documents, preparing 

final determinations and responses, fee categories, foreseeable harm, reasonable searches and 

reasonable description of FOIA requests, and an Exemptions redaction workshop.

Several FOIA professionals attended the American Society of Access Professionals Virtual 

National Training Conference, which covered topics including FOIA procedures, FOIA 

Exemptions, FOIA litigation and recent court decisions, the Privacy Act, and foreseeable 

harm.

Also, Treasury’s FOIA Professionals received training through various continuing education 

opportunities and other workshops. For example, FinCEN and Mint staff attended 

International Association of Privacy Professionals (IAPP) training.

6. Please provide an estimate of the percentage of your FOIA professionals and staff with FOIA 

responsibilities who attended substantive FOIA training during this reporting period.

One hundred percent (100%) of FOIA professionals attended substantive FOIA training.

7. OIP has directed agencies to “take steps to ensure that all of their FOIA professionals attend 

substantive FOIA training at least once throughout the year.” If your response to the 

previous question is that less than 80% of your FOIA professionals attended training, please 

explain your agency’s plan to ensure that all FOIA professionals receive or attend 

substantive FOIA training during the next reporting year.

N/A

C. Outreach

8. Did your FOIA professionals engage in any outreach or dialogue with the requester 

community or open government groups regarding your administration of the FOIA? Please 

describe any such outreach or dialogue, and, if applicable, any specific examples of how this 

dialogue has led to improvements in your agency’s FOIA administration.

The Department continues to encourage open communication with the requester community 

and the practice of routinely reaching out to requesters to discuss FOIA processes and the 

specifics of FOIA requests. Treasury FOIA staff communicated regularly with the public to 

provide guidance and insight into Treasury’s FOIA processes, narrow the scope of a request 

to reduce or eliminate processing costs and reducing overall processing times, prioritize

document searches, ensure appropriate consent is on file, and other issues that facilitate 

efficient FOIA administration.

IRS continued to enhance their FOIA Library layout to make the site easier for the general 

public to use. IRS leveraged social media platforms such as Twitter and Facebook to provide 
8

outreach to the general public regarding the FOIA Library and information available to the 

public. 

Treasury continued to work and collaborate with OGIS to facilitate dialogue with various 

FOIA requesters.

D. Other Initiatives

9. Describe any efforts your agency has undertaken to inform non-FOIA professionals of their 

obligations under the FOIA. In particular, please describe how often and in what formats 

your agency provides FOIA training or briefings to non-FOIA staff.

Overall, Treasury has taken significant steps to ensure non-FOIA professionals have a full 

understanding of the FOIA requirements in order to provide every response with as much

openness and transparency as possible. Non-FOIA professionals are informed through 

several training methods, including one-on-one, case-by-case, and group training sessions. 

Additionally, there are other avenues of informing non-FOIA professionals of their 

obligations under the FOIA, such as an issuance of a memorandum that reiterates a 

commitment to openness in the government and reinforcing every employee’s responsibility 

to promote transparency; displaying FOIA awareness posters in offices and messages on TVs 

throughout Treasury’s different locations; utilizing newsletter and electronic rotator 

announcements; new employees on-boarding training; supervisory-level training specific to 

their roles and responsibilities in the FOIA process; internal FOIA guides or quick reference 

guides; and attending mandatory briefings through presentations addressing FOIA 

obligations, e.g. proactive disclosures, documenting search efforts. 

10. Optional -- If there are any other initiatives undertaken by your agency to ensure that the 

presumption of openness is being applied, please describe them here.

Within Treasury, there are continuing initiatives to ensure openness throughout the 

Department. For example, the Secretary’s calendars are posted to provide the public with 

detailed information regarding day-to-day activities of the Treasury Department and the 

Secretary. These calendars reflect scheduled meetings, calls, and events that occurred, 

including clarifying information. Also, Treasury publishes a list of individuals and 

companies owned or controlled by, or acting for or on behalf of, targeted countries. It also

lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated 

under programs that are not country specific. 

Openness is communicated effectively through official social media accounts and internal 

communications channels that distribute records; public datasets used to improve public 

knowledge of Treasury and its operations, such as weekly electronic newsletters and Industry 

circulars; reviews of investigatory and inspection records; and through the use of Treasury’s 

FOIA Libraries. 

The FOIA Libraries are another essential avenue of ensuring openness with the public by 

proactively posting training material, updated instruction manuals, and records requested by 

three or more requesters. Additionally, the Department has proactively posted records, 
9

regardless of the criteria to post records requested by three or more requesters as required 

under 5 U.S.C. 552 (a)(2), in order to provide the public with the most current information on 

Treasury’s activities. These efforts have generated a considerable amount of traffic to 

Treasury’s FOIA Libraries and has helped to cut down on the number of FOIA requests 

received. 

Section II: Steps Taken to Ensure that Treasury Has an Effective 

System in Place for Responding to Requests

1. For Fiscal Year 2020, what was the average number of days your agency reported for 

adjudicating requests for expedited processing? Please see Section VIII.A. of your agency's 

Fiscal Year 2020 Annual FOIA Report.

Treasury’s average number of days to adjudicate requests for expedited processing was less 

than 1 calendar day.

2. If your agency's average number of days to adjudicate requests for expedited processing was 

above ten calendar days, please describe the steps your agency will take to ensure that 

requests for expedited processing are adjudicated within ten calendar days or less.

N/A

3. During the reporting period, did your agency conduct a self-assessment of its FOIA 

program? If so, please describe the methods used, such as reviewing Annual Report data, 

using active workflows and track management, reviewing and updating processing 

procedures, etc.

Yes. The types of methods used to conduct a self-assessment during the reporting period 

included the DOJ OIP FOIA Self-Assessment Toolkit, reviews of annual FOIA report data, 

the review of monthly case inventories, and assessments of FOIA tracking systems, tools, 

and internal processing procedures.

4. Standard Operating Procedures (SOPs): Having SOPs can improve the consistency and 

quality of an agency’s FOIA process. In addition, describing an agency’s standard practices 

for handling FOIA requests on agency FOIA websites can help requesters better understand 

how their request will be handled. 

a. Does your agency have SOPs that outline general processes for handling FOIA 

requests and appeals? 

Treasury offices have SOPs that outline general processes for handling FOIA requests 

and appeals except for the Mint. 

b. If not, does your agency have plans to create FOIA SOPs?

Mint has made plans to create FOIA SOPs.
10

c. If yes, how often are they reviewed/updated to account for changes in law, best 

practices, and technology? 

The review of SOPs varies by Treasury Bureau and ranges from annual reviews to 

being reviewed on an as needed basis when substantial changes in law occur. 

d. In addition to having SOPs, does your agency post or otherwise describe your 

standard processes for handling requests on your website?

BEP, FinCEN, Fiscal Service, IRS, OCC, and TIGTA posts or otherwise describes 

standard processes for handling FOIA requests on their websites. 

5. The FOIA Improvement Act of 2016 requires additional notification to requesters about the 

services provided by the agency’s FOIA Public Liaison. Please provide an estimate of the 

number of times requesters sought assistance from your agency’s FOIA Public Liaison 

during FY 2019 (please provide a total number or an estimate of the number).

Treasury’s FOIA Public Liaisons received more than 1,000 inquiries during the reporting 

period of which 76% were directed to the IRS’ FOIA Public Liaison.

6. Does your agency frequently receive common categories of first-party requests? If so, please 

describe the types of requests and if your agency has explored establishing alternative means 

of access to these records outside of the FOIA process?

Yes. Categories of records requested include individual debt and Treasury payment records; 

first-party tax transcripts and copies of tax returns; coin order history records; complaint and 

investigatory records on first party requesters; and Federal Alcohol Permit and or other tax 

information. The Department has developed alternative means for access to the records 

outside of the FOIA process by establishing websites and call centers for making information 

requests. These practices significantly decrease the turnaround time to obtain the requested 

information, with some requests taking 24 hours or less. 

7. The FOIA Improvement Act of 2016 required all agencies to update their FOIA regulations 

within 180 days. Has your agency updated its FOIA regulations in accordance with the 

FOIA Improvement Act of 2016? If not, what is your agency's plan to update your 

regulations?

Yes.

8. Please explain how your agency worked to mitigate the impact of the COVID-19 pandemic 

on FOIA processing. Examples could include, but are not limited to: altering workflows, 

implementing new technology, providing notices and instructions or otherwise 

communicating directly with requesters.

With the unprecedented COVID-19 pandemic, the Department of the Treasury worked hard 

to evaluate all FOIA workflows to ensure that requests were responded to within the limits 

imposed by the statute. A priority was made to continue to provide the requester community 
11

with quality customer service while the majority of the Department’s workforce was placed 

in a remote status. For example:

• IRS and TIGTA placed notices on their websites about potential delays in the 

processing of requests due to the COVID-19 pandemic.

• BEP, BFS, TIGTA, and DO worked with their IT departments to develop processes 

for rerouting telephone calls, converting faxes into e-mails, and developing efficient 

ways to scan hardcopy mail into an electronic format.

• DO, IRS, and TIGTA modified and converted FOIA letters to an electronic format to 

ensure their continued use, along with listing language about the effects of the 

COVID-19 pandemic on the processing of requests.

• DO began working to integrate Pay.gov into its FOIA processing software to accept 

electronic FOIA fee payments. 

• OCC rethought the process of providing certified bank records electronically –

without special paper, and gold seals. The OCC also slashed the cost for providing 

such records. As a result, the OCC has received much positive feedback from the 

disclosure community. 

9. Optional – Please describe.

• Best practices used to ensure that your FOIA system operates efficiently and effectively.

To ensure the agency’s FOIA system operates effectively and efficiently and requesters 

receive responses as quickly as possible, Treasury decentralized its FOIA process to each 

Bureau and to certain specific Program Offices within DO. Once a request is received,

an analysis of what the requester is seeking is conducted and terms are generated to 

conduct a search. After completing a search for records, analysts are assigned to 

determine responsiveness and provide recommendations to release to the appropriate

authority. Upon approval, responses are submitted electronically to requesters. There is

some variance among Treasury’s Bureaus in how they process FOIA requests. However, 

each bureau collaborates with information technology experts, legal communities,

internal organizations, as well as requesters to ensure the best releasable product is 

provided and made available to the public. Their electronic tracking systems are updated 

or being updated to ensure data is accurate in order to produce timely responses, track 

performance, and address backlog. Additionally, coordinating with Records Officers 

provides added value to the effectiveness of records searches, preserving information and 

retention policy, and identifying records for proactive disclosure.

In October 2020, DO launched commercial-off-the-shelf (COTS) FOIA processing and 

tracking software to replace its legacy system. The software has allowed DO to reimagine 

its processes and create efficiencies for responding to FOIA requests. For instance, FOIA 

requestors can submit requests on FOIA.gov or through Treasury’s FOIA website and the 

request is automatically created in the database. This eliminates much of the frontend 

data entry that was previously required by the FOIA staff. Also, the COTS product allows 

for all processing activities to occur within one system which helps to improve records 

management. The all-in-one system allows the staff to quickly identify the status of a 

request, thus improving the timeliness and quality of status updates for the requester 
12

community. The Department has set a goal to launch the software to most of its Bureaus 

by Q4 of FY 2021.

• Any challenges your agency faces in this area.

FOIA requests continue to increase in overall complexity with the types of records being 

sought resulting in high volumes of documents being produced. Often these large 

document sets require a manual review and redaction of the files as Treasury lacks robust 

eDiscovery technology to automate these processes. This results in an increase in 

processing times and potential litigation.

Section III: Steps Taken to Increase Proactive Disclosures

1. Provide examples of any material that your agency has proactively disclosed during the past 

reporting year, including records that have been requested and released three or more times 

in accordance with 5 U.S.C. § 552(a)(2)(D). Please include links to these materials as well.

Some examples of records proactively posed during the reporting period include the

following:

• 2018 Office of Chief Counsel Report on Professionalism

• 2020 American Eagle Silver Bullion Coin Production

• Active Enrolled Agents Listing

• Appeals Coordinated Issues (ACI)

• Calendars and Travel of the Secretary

• Country-by-Country Reporting Guidance 

• Document 6209

• Federal Alcohol Administration Act List of Permittees

• FinCEN FOIA Logs

• IRS FOIA Logs

• IRS General Record Schedules

• Matured, Unredeemed Debt and Unclaimed Moneys Reports

• Monthly FHA Debenture Reports

• Petition to Establish the San Luis Obispo Coast and SLO Coast American Viticultural Area

• Petition to Establish the Yucaipa Valley American Viticultural Area

• Quarterly FOIA Logs

• Quarterly Marijuana Banking Reports

• Return Preparer PTIN Listing

• Taxpayer First Act (TFA) Training and Reference Resources

• The Alcohol and Tobacco Tax and Trade Bureau Adverse Actions Handbook

• The Tax Exempt and Government Entities Division Report 2005-10-161

• The Tax Exempt and Government Entities Division Report 2003-10-217

• Third Party Data Store (TPDS) Extracts

• TIGTA Calendar Year 2019 FOIA Log
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2. Beyond posting new material, is your agency taking steps to make the posted information 

more useful to the public, especially to the community of individuals who regularly access 

your agency’s website?

Yes.

3. If yes, please provide examples of such improvements. In particular, please describe steps 

your agency is taking to post information in open, machine-readable, and machineactionable formats, to the extent feasible. If not posting in open formats, please explain why 

and note any challenges.

There are several on-going efforts to ensure the posted materials are Section 508 complaint 

and searchable. For example:

• IRS completed an initiative to promote the FOIA Library through numerous methods 

such as social media outreach, newsletters to tax practitioners, and IRS.gov 

announcements. Information associated with the IRS FOIA Library is, to the extent 

feasible, posted in machine-readable format and made Section 508 compliant.

• TIGTA’s Disclosure Branch posts documents in commonly accessed formats, including 

PDF, CSV, and other popular Microsoft Office formats. TIGTA has also made 

documents searchable using Optical Character Recognition and includes relevant 

metadata when posting to the FOIA Library. 

4. Optional -- Please describe:

• Best practices used to improve proactive disclosures.

• IRS established a forum to meet quarterly with IRS business unit points of contact to 

discuss proactive disclosure requirements and FOIA processing. IRS also conducted 

a review of Internal Revenue Manuals to ensure procedural changes are appropriately 

disclosed on the FOIA Library. The IRS Disclosure Policy team has been involved in 

discussions with many IRS offices regarding the Taxpayer First Act and trending 

issues such as the Coronavirus Aid, Relief and Economic Security (CARES) Act to 

ensure that documents are posted proactively in a timely manner. The IRS Chief 

Privacy Officer issued the “FOIA Obligations and Transparency” memo to all IRS 

employees to remind them of their responsibilities in proactively disclosing

information as well as releasing information directly to requesters who have a right to 

that information.

• Any challenges your agency faces in this area

• IRS and TTB FOIA requests primarily deal with records protected under Title 26,

United States Code, §6103. These records are legally required to be protected and 

cannot be proactively disclosed.

• Most requests directed to TIGTA seek law enforcement records on or about 

individuals, which cannot be disclosed publicly (i.e. information on complaints or 

investigations protected by the Privacy Act).
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Section IV: Steps Taken to Greater Utilize Technology

1. Please briefly describe the types of technology your agency uses to support your FOIA 

program. In addition, please highlight if your agency is leveraging or exploring any new 

technology that you have not previously reported. If so, please describe the type of 

technology. 

Yes. Treasury implemented a new COTS FOIA request tracking system and processing tool

and is working to rollout the software to various Bureau offices during calendar year 2021. 

The new FOIA solution will enhance compliance with FOIA and Privacy Act laws, including 

the FOIA Improvement Act of 2016, as well as records retention policies. This system will 

replace Treasury’s legacy FOIA software, increase operation efficiencies in processing FOIA 

cases, improve customer service by reducing response time to customer requests, enrich 

customer experience by allowing the public to submit and track FOIA cases, then receive 

documents via Treasury FOIA public website, provide interoperability with National FOIA 

Portal (FOIA.gov) and Pay.gov, enhance transparency through simplified release of 508-

compliant documents to the public, and improve Treasury’s annual and ad-hoc reporting 

process via automation and standardization. 

Additionally, DO, OCC, and Mint utilize eDiscovery software to assist with reviewing 

voluminous records in FOIA litigation cases. OCC has leveraged this capability to create an 

IT group that is responsible for conducting agency-wide e-mail searches and deduplicating emails when conducting searches for FOIA requests.

TIGTA leverages a wiki, which allows the search of Disclosure policies and procedures by 

key words to locate instructions, training materials, templates, standard language, and 

guidance. The wiki continues to be a valuable research tool with all staff members 

contributing new content updates as needed. 

2. OIP issued guidance in 2017 encouraging agencies to regularly review their FOIA websites 

to ensure that they contain essential resources, and are informative and user-friendly. Has 

your agency reviewed its FOIA website(s) during the reporting period to ensure it addresses 

the elements noted in the guidance?

Yes.

3. Did your agency successfully post all four quarterly reports for Fiscal Year 2020?

Yes.

4. If your agency did not successfully post all quarterly reports, with information appearing on 

FOIA.gov, please explain why and provide your agency’s plan for ensuring that such 

reporting is successful in Fiscal Year 2021.

N/A, all quarterly reports were successfully posted.
15

5. The FOIA Improvement Act of 2016 requires all agencies to post the raw statistical data 

used to compile their Annual FOIA Reports. Please provide the link to this posting for your 

agency’s Fiscal Year 2019 Annual FOIA Report and, if available, for your agency’s Fiscal 

Year 2020 Annual FOIA Report.

Treasury’s raw data for the Fiscal Year 2019 and 2020 Annual FOIA Reports are available

on Treasury’s website at https://home.treasury.gov/footer/freedom-of-information-act/foiareports.

6. Optional -- Please describe:

• Best practices used in greater utilizing technology.

TIGTA collaborated with its information technology staff to conduct email queries on all 

Bureau employee email, using specific key words or email addresses to locate responsive 

records. This process is a much more effective and efficient in use of the agency’s 

resources with quicker turnaround times.

IRS leveraged its FOIA processing software’s capabilities to modernize the FOIA 

process in areas such as automating searches for, and redaction of, sensitive information 

more consistently than manual processes of search and redacting previously used by 

FOIA professionals, tracking requests for documents, applying exemptions and 

documenting case processing actions. IRS Disclosure consistently works with 

Information Technology (IT) database administrators to ensure FOIA professionals have 

tools necessary to work complex requests, requests with voluminous responsive records 

or with responsive records provided on media other than paper. IRS continues to utilize 

Microsoft SharePoint to transfer documents between areas quickly and to ensure training 

is accessible to FOIA professionals on a continuous basis.

• Any challenges your agency faces in this area.

IRS is required to protect any information that meets the criteria of Title 26, United States 

Code, §6103. This results in potential delays and complications with any technology that 

does not meet Information Technology standards to also protect the information.

Section V: Steps Taken to Improve Timeliness in Responding to 

Requests and Reducing Backlogs

A. Simple Track

1. Does your agency utilize a separate track for simple requests?

The Department uses a separate track for simple requests, except IRS.
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2. If your agency uses a separate track for simple requests, was the agency overall average 

number of days to process simple requests twenty working days or fewer in Fiscal Year 

2020?

Yes.

3. Please provide the percentage of requests processed by your agency in Fiscal Year 2020 that 

were placed in your simple track.

At Treasury, 22% of requests processed were in the simple track.

4. If your agency does not track simple requests separately, was the average number of days to 

process all non-expedited requests twenty working days or fewer?

For the one Treasury Bureau (IRS) that does not track simple requests, the average number of 

days to process all non-expedited requests was 36.

B. Backlogs

BACKLOGGED REQUESTS

5. If your agency had a backlog of requests at the close of Fiscal Year 2020, did that backlog 

decrease as compared with the backlog reported at the end of Fiscal Year 2019?

No.

6. If not, did your agency process more requests during Fiscal Year 2020 than it did during 

Fiscal Year 2019?

No.

7. If your agency’s request backlog increased during Fiscal Year 2020, please explain why and 

describe the causes that contributed to your agency not being able to reduce its backlog. 

When doing so, please also indicate if any of the following were contributing factors:

• An increase in the number of incoming requests.

• A loss of staff.

• An increase in the complexity of the requests received. If possible, please provide 

examples or briefly describe the types of complex requests contributing to your backlog 

increase.

• Any other reasons – please briefly describe or provide examples when possible.

Although Treasury received 20 fewer requests in FY 2020 than in FY 2019, two Bureaus 

received more requests: DO received 173 more requests and IRS received 28 more requests. 

Treasury closed 661 fewer requests in FY 2020 than in FY 2019, a decrease of 6%. Except 

for the Fiscal Service, all Treasury Bureaus closed fewer FOIA requests in FY 2020. This 

shortfall was due, in part, to staff vacancies and processing delays caused by the pandemic.
17

8. If you had a request backlog please report the percentage of requests that make up the 

backlog out of the total number of requests received by your agency in Fiscal Year 2020.

Treasury’s backlog percentage is 18 percent. 

BACKLOGGED APPEALS

9. If your agency had a backlog of appeals at the close of Fiscal Year 2020, did that backlog 

decrease as compared with the backlog reported at the end of Fiscal Year 2019?

Yes. Treasury’s backlog of FOIA appeals decreased 51% from 100 in FY 2019 to 49 in FY

2020.

10. If not, did your agency process more appeals during Fiscal Year 2020 than it did during 

Fiscal Year 2019?

N/A.

11. If your agency’s appeal backlog increased during Fiscal Year 2020, please explain why and 

describe the causes that contributed to your agency not being able to reduce its backlog.

When doing so, please also indicate if any of the following were contributing factors:

• An increase in the number of incoming appeals.

• A loss of staff.

• An increase in the complexity of the requests received. If possible, please provide 

examples or briefly describe the types of complex requests contributing to your backlog 

increase.

• Any other reasons – please briefly describe or provide examples when possible

N/A.

12. If you had an appeal backlog please report the percentage of appeals that make up the 

backlog out of the total number of appeals received by your agency in Fiscal Year 2020.

Treasury’s appeal percentage is 30 percent.

C. Backlog Reduction Plans

13. In the 2020 guidelines for Chief FOIA Officer Reports, any agency with a backlog of over 

1000 requests in Fiscal Year 2019 was asked to provide a plan for achieving backlog 

reduction in the year ahead. Did your agency implement a backlog reduction plan last year? 

If so, describe your agency’s efforts in implementing this plan and note if your agency was 

able to achieve backlog reduction in Fiscal Year 2020?

In FY 2019 Treasury had a backlog of 1,427 requests and implemented a backlog reduction 

plan for FY 2020. Treasury established and communicated bureau-specific goals and targets, 

encouraged Bureaus to conduct FOIA self-assessments using DOJ’s FOIA self-assessment 

toolkit, and made plans to establish a rapid response team of FOIA Analysts to address 
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significant and high-profile cases. Treasury’s FOIA Officer identified challenges affecting 

the backlog and focused resources on reducing the overall number of backlogged requests, 

with specific emphasis on the ten oldest requests, appeals, and consultations. In addition, the 

FOIA Officer conducted outreach to program areas and followed up with programs who had 

overdue search responses.

14. If your agency had a backlog of more than 1,000 requests in Fiscal Year 2020, please 

explain your agency’s plan to reduce this backlog during Fiscal Year 2021.

At the end of FY 2020, Treasury had a backlog of 2,123 requests, Treasury’s Chief FOIA 

Officer will take the following actions targeted to reduce the backlog of pending requests:

• Implement a new FOIA request tracking system.

• Establish and communicate bureau-specific goals for backlog reduction.

• Encourage Bureaus to complete FOIA self-assessments using DOJ’s FOIA selfassessment toolkit.

• Identify challenges impacting the backlog and focus resources on reducing the overall 

number of backlogged requests, with specific emphasis on the ten oldest requests, 

appeals, and consultations. 

• Conduct targeted training and outreach to improve the timeliness of searches.

D. Status of Oldest Requests, Appeals, and Consultations

OLDEST REQUESTS

15. In Fiscal Year 2020, did your agency close the ten oldest pending perfected requests that 

were reported in Section VII.E. of your Fiscal Year 2019 Annual FOIA Report?

No.

16. If no, please provide the number of these requests your agency was able to close by the end 

of the fiscal year, as listed in Section VII.E of your Fiscal Year 2019 Annual FOIA Report. If 

you had fewer than ten total oldest requests to close, please indicate that.

Treasury closed 6 of its 10 oldest requests in Fiscal Year 2019.

17. Beyond work on the ten oldest requests, please describe any steps your agency took to reduce 

the overall age of your pending requests.

Treasury FOIA staff worked closely with subject matter experts, attorneys, and program staff 

to obtain and process records for the oldest pending requests. In many cases, Treasury made 

multiple interim releases of records in cases where there were voluminous records.

TEN OLDEST APPEALS

18. In Fiscal Year 2020, did your agency close the ten oldest appeals that were reported pending 

in Section VII.C.5. of your Fiscal Year 2019 Annual FOIA Report?
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No.

19. If no, please provide the number of these appeals your agency was able to close by the end of 

the fiscal year, as listed in Section VII.C.(5) of your Fiscal Year 2019 Annual FOIA Report. 

If you had fewer than ten total oldest appeals to close, please indicate that.

Treasury closed 8 of its 10 oldest appeals in Fiscal Year 2019.

20. Beyond work on the ten oldest appeals, please describe any steps your agency took to reduce 

the overall age of your pending appeals.

Treasury FOIA staff worked closely with subject matter experts, attorneys, and program staff 

to review and process the oldest pending appeals. Within DO, which demonstrated a 54% 

decrease in its FOIA backlog, the appeals official conducted a comprehensive review of 

pending FOIA appeals and took action to resolve the oldest pending appeals.

TEN OLDEST CONSULTATIONS

21. In Fiscal Year 2020, did your agency close the ten oldest consultations that were reported 

pending in Section XII.C. of your Fiscal Year 2019 Annual FOIA Report?

No.

22. If no, please provide the number of these consultations your agency was able to close by the 

end of the fiscal year, as listed in Section XII.C. of your Fiscal Year 2019 Annual FOIA 

Report. If you had fewer than ten total oldest consultations to close, please indicate that.

Treasury closed 6 of its 10 oldest consultations in Fiscal Year 2020.

E. Additional Information on Ten Oldest Requests, Appeals, and Consultations & Plans

23. Briefly explain any obstacles your agency faced in closing its ten oldest requests, appeals, 

and consultations from Fiscal Year 2019.

Treasury continues to experience challenges closing its ten oldest requests, appeals, and 

consultations. Many of the requests require multiple searches, additional coordination 

internally or externally through consultation, collaboration on the use of exemptions, and 

determining records for proactive disclosure. Additionally, Treasury possesses a significant 

number of records that are classified and contain national security, law enforcement, or 

confidential business sensitivities, as well as materials that originate from other federal 

agencies. These complexities affect the timeliness of reviews and how quickly the agency 

responds to requesters. Other challenges include: an increase in the volume and complexity 

of requests, an increase in the number of requests subject to litigation, and FOIA staff 

turnover due to retirements and different job opportunities.
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Also, financial institutions and other entities are often required to provide or submit 

confidential business information to Treasury, which could cause business submitters 

substantial competitive harm if inappropriately released. Based on the additional review 

required by the FOIA under the ‘submitter notice’ process, substantial time is added to the 

processing of these requests, particularly when multiple notices are required and/or there are 

a voluminous number of records.

24. If your agency was unable to close any of its ten oldest requests because you were waiting to 

hear back from other agencies on consultations you sent, please provide the date the request 

was initially received by your agency, the date when your agency sent the consultation, and 

the date when you last contacted the agency where the consultation was pending.

N/A

25. If your agency did not close its ten oldest pending requests, appeals, or consultations, please 

provide a plan describing how your agency intends to close those “ten oldest” requests, 

appeals, and consultations during Fiscal Year 2021.

During FY 2021, Treasury will take the following actions targeted to reduce the backlog of 

pending requests, appeals, and consultations:

• Implement a new FOIA request tracking system.

• Establish and communicate bureau-specific goals for backlog reduction.

• Encourage Bureaus to complete FOIA self-assessments using DOJ’s FOIA selfassessment toolkit.

• Identify challenges impacting the backlog and focus resources on reducing the overall 

number of backlogged requests, with specific emphasis on the ten oldest requests, 

appeals, and consultations. 

• Conduct targeted training and outreach to improve the timeliness of searches.

• Monitor metrics and increase the frequency of case status updates on the oldest ten 

requests, appeals, and consultations.

F. Success Stories

Out of all the activities undertaken by your agency since March 2020 to increase 

transparency and improve FOIA administration, please briefly describe here at least one 

success story that you would like to highlight as emblematic of your agency’s efforts. The 

success story can come from any one of the five key areas but should not be something that 

you have reported in a prior year. As noted above, OIP will highlight these agency 

success stories during Sunshine Week. To facilitate this process, all agencies should use 

bullets to describe their success story and limit their text to a half page. The success story 

is designed to be a quick summary of key achievements. A complete description of all your 

efforts will be contained in the body of your Chief FOIA Officer Report.

Internal Revenue Service
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The COVID-19 pandemic presented challenges to the ways that FOIA training was

traditionally presented. Limits to travel caused delays in training along with the 

implementation of IRS’ new FOIA processing system. Without the ability to travel, IRS 

created an entirely new training plan to help with implementing the new FOIA software in 

a timely fashion, and to allow for the further modernization of the FOIA process. IRS 

FOIA professionals and trainers adapted to an entirely new format of training for both new 

and experienced FOIA professionals. Training occurred virtually in various locations 

across the country, requiring countless hours of hard work by numerous employees. 

Despite these challenges, IRS successfully trained over 130 employees on the new FOIA 

processing system and has fully implemented the tool for all current and future FOIA 

requests.

Treasury Inspector General for Tax Administration

TIGTA’s early adoption of electronic record keeping facilitated a smooth transition to 

remote work for an extended period during the COVID-19 pandemic. Efforts such as 

increasing the use of videoconferencing software, providing virtual internal FOIA training, 

and listing early and informative notifications on public facing webpages about the 

expected delays caused by the pandemic led to a successful year. TIGTA finished FY

2020 closing 97% of all FOIA cases within 20 business days of receipt and maintained an 

average processing time of eleven (11) days. 

Alcohol and Tobacco Tax and Trade Bureau

TTB continued proactively posting American Viticultural Area (AVA) records in a 

dedicated reading room on TTB’s website. In the past, AVA petitions, notices of proposed 

rulemaking (NPRMs), public comments, and Treasury Decisions were only made available 

to those who submitted a FOIA request. To make the information more useable and 

informative, TTB created an AVA Map Explorer to display the boundaries of all 

established and proposed AVAs. The Map Explorer contains information about each AVA, 

including its state and county, when it was established, what other AVAs it contains or is 

within, and a link to its codified official boundary description. 

Office of the Comptroller of the Currency

Due to the restrictions imposed by the COVID-19 pandemic, OCC had to rethink how 

bank records were certified. Without the ability to hand-emboss certificates, featuring the 

signature of the head of the agency with gold seals and printed on special paper for a fee of 

$100 per seal, OCC developed a process to produce and deliver the documents 

electronically. These efforts cut the price of producing the certificates from $100 per seal 

to $10 per seal and allowed for these highly sought-after documents to be more accessible 

to the public. The response from the public on this updated process has been exceedingly 

positive. 

Mint
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Mint historically receives numerous FOIA requests related to the American Eagle (AE) 

silver bullion coins when they are produced. With coin production limitations imposed at 

the West Point Mint stemming from the COVID-19 pandemic, the Philadelphia Mint was 

tasked with producing a limited number of AE silver bullion coins. Later in the year, the 

San Francisco Mint was also tasked with producing a limited run of AE silver bullion 

coins.

When the FOIA office learned of these plans, understanding the historical volume of FOIA 

requests received on this topic and anticipating future requests, they contacted staff in the 

Numismatics and Manufacturing departments and asked that records documenting the 

production of the coins be provided to the FOIA office for proactive disclosure in the 

Mint’s FOIA Library. These actions led to three positive results. First, they satisfied the 

information needs of the public, namely coin collectors and dealers who are interested in 

the Mint’s coins. Second, the FOIA office helped Mint staff avoid having to engage in 

after-the-fact document searching by proactively posting the records before the coins were 

minted. Finally, the FOIA office familiarized Mint offices with the benefits of proactive 

disclosures. 

Departmental Offices

In FY 2020, DO undertook a major effort to procure and launch new FOIA software to 

replace its legacy system. Employing an enterprise FOIA software solution provides 

numerous benefits to include increasing productivity, enhanced reporting capabilities, 

interoperability with FOIA.gov and Pay.gov, and the ability to streamline many manual 

processes. This effort required the collaboration between FOIA staff and personnel within 

various Treasury offices. Major efforts commenced to migrate all case information from 

the legacy system into the new software to allow for a one-stop-shop for FOIA information 

management. Coinciding with this effort, Treasury updated its public facing webpages to 

make it clear to FOIA requestors on where to submit a request to each of the various 

Bureaus. 

DO launched the new FOIA software in Q1 FY 2021 and immediately began to see

improvements to FOIA processing times and the elimination of several manual functions 

of the process. This has freed up resources to provide support to other areas focused on 

backlog reduction efforts. The effort has also cut down on the number of misdirected FOIA 

requests submitted throughout the Department which has also helped to improve response 

times. While the system is still being proven, DO is confident that these efforts will help to 

improve the overall metrics while providing a high-quality work product to the public. The 

Department has set a goal to launch the software to most of the Bureaus by Q4 of FY 2021 

and to decommission its legacy system in FY 2022.