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:

9 A statement that your request is being submitted under Section 515 of Public Law 106-554.

9 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.

9 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.

9 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. 

9 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 wellestablished 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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