Chief FOIA Officer Report of the Farm Credit Administration FY 2018

Chief FOIA Officer and Senior Counsel: Jane M. Virga

The FCA is an independent agency in the executive branch of the U.S. Government. It is 

responsible for regulating and examining the banks, associations, and related entities of the 

Farm Credit System (System), including the Federal Agricultural Mortgage Corporation. The 

System is a nationwide network of borrower-owned financial institutions that provides credit to 

farmers, ranchers, and agricultural and rural utility cooperatives. Originally created in 1933 by 

an Executive order, the Agency derives its powers and authorities from the Farm Credit Act of 

1971, as amended. 

The FCA strives to have an exemplary Freedom of Information Act (FOIA) program, to process 

all FOIA requests within the statutory time frames, and to comply with all aspects of the FOIA. 

The FCA is a small Agency, with approximately 250 employees, and receives less than 50 

requests per year. FCA’s FOIA staff conduct its records searches quickly and efficiently. We have 

no backlog. The basic FOIA office is housed in the Office of General Counsel. The FOIA Officer 

processes all FOIA requests. FCA’s Director of the Office of Administrative Services, who is not a 

member of the Office of General Counsel, serves as the FOIA Appeals Officer. 

Our measure of success is two-fold: (1) FOIA processing times are within the statutorily 

mandated time of 20 days; and (2) the professionalism and training of our FOIA staff.

Applying the Presumption of Openness

The FCA applies the presumption of openness. Whenever possible we waive any applicable 

exemptions. As a matter of discretion during the reporting year we have made numerous 

proactive disclosures. For instance, we disclosed a number of internal personnel policies and 

waived the deliberative process. 

FCA Has an Effective System in Place to Respond to Requests

To ensure timely and appropriate responses, the FOIA staff attends annual training and 

provides training to all FCA staff. At the end of the fiscal year the FOIA Officer did an internal 

control review, which looked at internal policies and procedures, receipt of requests, response 

time, and rate and success of appeals. The review concluded that the FOIA Office complied with 

the law and that there was an efficient and effective program.

In Fiscal Year 2018, we responded to all requests within 20 business days and we adjudicated 

requests for expedited processing in less than ten calendar days. The FOIA staff continuously 

assesses our processes to ensure that our FOIA system operates efficiently and effectively. 

Therefore, FCA has an effective system in place for responding to FOIA requests.
Increase of Proactive Disclosures

The FCA has a distinct process to identify records for proactive disclosure. The Office of 

Congressional and Public Affairs (OCPA) identifies such records. The Assistant Director for OCPA 

directs the posting of such records to the Agency’s website and consults with the FOIA staff as 

necessary. The Agency strives to continuously expand and improve in this regard. Examples of 

posted material include: testimony of FCA officials, informational memoranda, frequently asked 

questions, and proposed and final regulations. The FCA has an FCA News Email List that allows 

the Agency to highlight proactive disclosures for public awareness. By subscribing to this list, 

the public can receive email alerts of items as the following: News releases, Informational 

Memoranda, Bookletters, Policy Statements, Reports, FCA Handbook updates, and Federal 

Register notices. 

Greater Utilization of Technology

We post almost all records in “portable document format” (.pdf), which is a universal format so 

users can easily view, save, print, or forward the document. For all requesters who provide an 

email address, FOIA staff use email to communicate, demonstrating a spirit of cooperation. 

Also, for these requesters, all agency FOIA responses are sent via email, with responsive 

documents in pdf format. This process takes full advantage of technology. 

Improving Timeliness in Responding to Requests

We find frequent, substantive, and effective communications when working through the 

processing of FOIA requests expedite processing and reduce miscommunications. We work with 

requesters to identify efficiencies and to reduce fees in processing the requests. 

Reducing Backlogs

The Agency has no backlog.

Administering FOIA in a Spirit of Cooperation

FCA ensures that the FOIA is administered in a “spirit of cooperation.” We strive for good 

communication and good customer service when working with requesters. We communicate 

with requesters via their preferred methods: email, telephone, or mail. We provided electronic 

records whenever available.