Report to the Attorney General and the OMB Director, Pursuant to 

Executive Order 13,392: Improving Agency Disclosure of 

Information 

On December 14, 2005, President George W. Bush issued Executive order 13,392, on 

"Improving Agency Disclosure of Information." The Executive order is intended to 

strengthen agency compliance with the Freedom of Information Act, 5 U.S.C. 552 

(FOIA). Pursuant to this Executive order, President Bush directed that each agency, 

among other things, conduct a review of the agency's FOIA operations and draft a plan 

for improvement with concrete milestones for FY 2006 and FY 2007. On December 30, 

2005, the Office of Management and Budget (OMB) issued memorandum M-06-04, 

which provided further clarification and direction. Accordingly, by June 14, 2006, each 

agency was required to send a report containing a summary of the review and the 

agency's FOIA improvement plan to the Department of Justice, with a copy to OMB, and 

post it to the agency's Web site. The report of the Farm Credit System Insurance 

Corporation prepared by its Chief Freedom of Information Act Officer is provided below. 
FCSIC Improvement Plan (June 6, 2006) 

REPORT TO THE ATTORNEY GENERAL AND THE OMB 

DIRECTOR, PURSUANT TO EXECUTIVE ORDER 13,392: 

IMPROVING AGENCY DISCLOSURE OF INFORMATION 

A. The overall nature of FCSIC's FOIA operations 

The Farm Credit System Insurance Corporation (FCSIC or Corporation) is an 

independent Federal corporation established to ensure the timely payment of 

principal and interest to investors in Farm Credit System (FCS or System) debt 

securities. The Corporation’s primary purpose, as defined by the Farm Credit Act 

of 1971, as amended (Act), is to insure the repayment of investors who purchase 

the bonds and notes issued by the System’s banks. The System is owned by the 

rural customers it serves, including farmers, ranchers, and other agricultural 

producers. Five Farm Credit System banks provide funding to the 96 

associations that make direct loans to their customers. The banks receive their 

funding through the issuance of Federal Farm Credit Banks Consolidated 

Systemwide Debt Securities by the Federal Farm Credit Banks Funding 

Corporation. Investors in these debt securities provide the funds the System 

lends to agriculture and rural America. 

Despite its important mission, the FCSIC has a staff of only 10 employees. 

Therefore, the Act directs the Corporation to use the personnel and resources of 

the Farm Credit Administration (FCA) to the extent practicable so as to minimize 

duplication of efforts and reduce costs. Thus, the FCSIC has delegated its duties 

under the Freedom of Information Act (FOIA) to the FCA.1

 The FCA administers 

the FOIA program for the FCSIC jointly with its own program. At the FCSIC’s 

request, the FCA completed the review and plan required by Executive order 

13,392 for the FCSIC. As the FOIA programs for the two agencies are 

administered jointly, this report pursuant to the Executive order is essentially the 

same as the report submitted by the FCA, except for the fact that the number of 

FOIA requests is lower for the FCSIC. 

The FCSIC strives to have an exemplary FOIA program, to process all FOIA 

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

FOIA and Executive order 13,392. We post information on the FOIA and how to 

make a FOIA request on the FCSIC’s Web site. As noted in FCSIC’s annual 

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 The FCA, which is housed adjacent to the FCSIC, is the safety and soundness regulator 

responsible for the examination, supervision, and regulation of each System institution. The FCA 

is an independent agency in the executive branch of the United States Government. The FCA 

derives its broad authorities from the Act; these include examination and enforcement authorities 

similar to those of commercial bank regulators. 

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FOIA Reports, which are posted on our homepage, the FCSIC typically receives 

approximately 10 FOIA requests per year from the public. 

The basic FOIA staff for FCSIC is housed in the Office of General Counsel of the 

FCA. It comprises one FOIA Officer and one Senior Counsel who advises the 

FOIA Officer on legal compliance with the FOIA. The FCSIC’s Chief Financial 

Officer serves as the FCSIC FOIA Appeals Officer. He receives legal guidance 

as necessary from another Senior Counsel who is not otherwise a part of the 

basic FOIA process. Consistent with Executive order 13,392, FCA’s Chief FOIA 

Officer, FOIA Public Liaison, and the FOIA Requester Service Center staffer 

perform the equivalent function for the Corporation. We post information 

explaining their roles and how to contact them on the FCSIC Web site. 

Because of the FCSIC’s size, conducting searches for records is a very simple 

and straightforward process. The FOIA staff strives to provide personal service 

to requesters, to communicate with them directly (usually by telephone), and to 

ensure that they receive records that are truly responsive to their needs, subject, 

of course, to applicable FOIA exemptions. The FOIA staff is able to conduct 

searches quickly, efficiently, and on time. We have no backlog. 

B. Areas selected for review 

We have reviewed the FCSIC’s FY 2005 and FY 2006 (through May) 

performance in the following areas: 

• Tracking capabilities 

• Searching for documents, including the cooperation of program staff 

• Processing time/use of electronic technology 

• Preparing and completing the FOIA Annual Report 

• Web site 

• Staff training 

• Affirmative and proactive disclosures 

• Communications with the public 

• FOIA Reference Guide

C. Narrative statement summarizing the results of our review 

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We reviewed the FCSIC’s performance for FY 2005 and for the first eight months 

of FY 2006. The results of our review follow: 

• Tracking capabilities: All FOIA requests were appropriately date stamped 

and entered into a paper log that indicates: requester’s name, date of receipt 

of request, date the response is due, exemptions claimed, number of pages 

released, fees charged, fees paid, date that the response is completed, and 

the information that is sought. The log enables the FCSIC to track the status 

of each FOIA request and appeal and to provide immediate information to a 

submitter on the status of his or her request. Given the small number of FOIA 

requests per year – FCSIC received 8 requests and 0 appeals in FY 2005 

and 1 request and 0 appeals thus far in FY 2006 -- the paper FOIA log is 

adequate to track our FOIA requests; we have concluded that a computerized 

log is not necessary and would be no more efficient. 

• Searching for documents, including the cooperation of program staff: Based 

on our review, we concluded that the FOIA Officer conducted appropriate 

searches, obtained legal advice whenever necessary, and consulted with 

FCSIC staff. As a member of the Office of General Counsel staff, the FOIA 

Officer has an ongoing working relationship with the Senior Counsel charged 

with providing legal counsel. This ensures constant and clear 

communication. Program staff has been trained to appreciate the importance 

of FOIA compliance and has been fully cooperative in conducting searches. 

FCSIC employees are routinely assigned to assist the FOIA Officer with 

searches and appropriate redactions of records. Typically, the FOIA Officer 

and Senior Counsel begin to process a FOIA request on the day of or day 

after arrival. They forward the request to appropriate program staff, which is 

ordinarily expected to produce any responsive documents within 10 business 

days. If the request poses any unusual problems, the FOIA staff works 

actively with the program staff to resolve them. As explained above, the 

FCSIC’s small size and the accessibility of its records make it easy and 

efficient to conduct searches of FCSIC records. The focused nature of the 

FCSIC’s mission also facilitates the search and redaction process; all 

employees know what records FCSIC keeps and where to find them. 

• Processing time/use of electronic technology: In the time period we 

examined, the FCSIC responded to all FOIA requests and FOIA appeals 

within the requisite 20 business days of receipt. In fact, as reported in 

FCSIC’s last annual FOIA report, the FCSIC’s median response time for 

FY 2005 was 4 business days. The FCSIC had no backlogs, and we do not 

remember there ever being one in prior years. As a result, expedited or multitrack processing has not been an issue. Because the FOIA staff responds to 

FOIA requesters within the statutory time frame, they do not send 

acknowledgment letters. Typically, the FOIA staff contacts the requester 

directly by telephone if any questions arise. 

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To enhance the accessibility of records, the FCSIC receives and responds to 

electronic FOIA requests received via e-mail. This is a simple and efficient 

way for the public to submit FOIA requests. The FCSIC has no plans at 

present to use automated FOIA processing, i.e., electronic scanning of 

responsive records and redacting of electronic records. FCSIC’s current 

procedures produce timely responses, and electronic scanning and redacting 

may not be cost-effective given the small number of FOIA requests the 

FCSIC receives. 

• Preparing and completing the FOIA Annual Report: The FOIA Annual 

Report is drafted by the FOIA Officer and reviewed by the Senior Counsel 

charged with FOIA compliance, as well as by other FCSIC personnel, as 

necessary. The paper FOIA log discussed above provides the information 

on which the Annual Report is based. The FY 2005 Annual Report was 

completed and posted on the FCSIC Web site on February 1, 2005, as 

required. 

 

• Web site: The FOIA page on the Web site is accurate. It effectively 

communicates with the public by providing information on the FCSIC, the 

FOIA, and how to make a FOIA request. It also provides all information 

required by Executive order 13,992, i.e., information pertaining to the Chief 

FOIA Officer, Public Liaison Officer, and the FOIA Requester Service Center. 

FOIA requests can be made on the FCSIC Web site through a direct link to 

the e-mail address of the FOIA Officer. 

• Staff training: The FOIA staff obtains appropriate training each year to ensure 

that all members maintain up-to-date knowledge of the law pertaining to the 

FOIA. The FOIA staff has access to an electronic newsletter that reports on 

the latest FOIA and information law developments, which the FOIA staff 

routinely uses. Additionally, the FOIA staff attends training provided by the 

Department of Justice and a leading professional organization, the American 

Society of Access Professionals. The Senior Counsel, who provides the 

overwhelming majority of legal advice on the FOIA, has been providing legal 

counsel on the FOIA for 20 years. She continues to train the FOIA staff in the 

Office of General Counsel. A new FOIA Officer was designated in 2006 and 

is in the process of being trained. The former FOIA Officer held the position 

for ten years. Unlike other agencies, there has not been a high turnover in 

FOIA staff. 

• Affirmative and proactive disclosures: The Corporation posts on its Web site 

numerous documents of interest to the public, including its regulations, policy 

statements, financial statements, and annual reports. 

• Communications with the public: The FOIA staff establishes effective and 

helpful lines of communication with FOIA requesters. The FOIA Officer and 

other FOIA staff will telephone requesters to clarify any ambiguities that a 

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6

request may present and to apprise them of any costs that may be involved. 

This personalized service helps ensure that the requester has the opportunity 

to clarify and, if necessary, better identify the records that he or she wants. 

Requesters are sometimes able to reduce FOIA fees through this process, 

and it can also speed response time. FCSIC’s Web site provides the public 

with useful information and, as discussed above, promotes direct 

communication with the Corporation. 

• FOIA Reference Guide: FCSIC’s FOIA Reference Guide is up-to-date. 

D. Improvement area(s) for FCSIC’s plan 

Although the FCSIC is fully compliant with the FOIA, as a consequence of our 

review we plan to: 

I. Establish written procedures in the form of a Procedures Manual to 

enhance consistency, reinforce accountability, and ensure continuity in the 

event of staff changes 

II. Emphasize the importance of continued politeness and courtesy by FOIA 

staff 

III. Promote intra-agency and inter-agency cooperation 

IV. Enhance FOIA training 

V. Provide customer feedback to FOIA staff 

VI. Conduct a semi-annual review of the FOIA homepage 

E. For each improvement area we provide the following 

improvement areas: 

See Tabs I through VI. 

F. For the entire plan, group the improvement areas into the 

following time periods: 

See the attached graph. 
TAB I 

1. Name: Create a FOIA Procedures Manual 

2. Brief statement of goal(s)/objective(s) 

Our objective in creating a Procedures Manual is to spell out in detail the 

effective, efficient, customer-friendly, and legally correct procedures that the 

FOIA staff currently uses, thus helping to ensure continued compliance with the 

FOIA. The Manual will emphasize timely responses and continued 

responsiveness to FOIA requesters. It will help in training new staff and serve as 

a written record that clearly and specifically articulates the FCSIC’s expectations 

with respect to the handling of FOIA requests. As a result, it should reinforce 

staff accountability. 

3. List of all distinct steps planned to be taken 

The Procedures Manual will contain, at a minimum, the following: 

• Description of administrative actions for staff, e.g., date stamp request, 

logging in and out, reminders to staff 

• Designations 

• Paper log 

• Outline of form letter to requesters 

• Approved sample letters, especially for more complicated legal issues 

• Relevant reports, e.g., FOIA Annual Report, reporting under Executive 

order 13,392 

• Governing laws and regulations 

• Discussion of fee waivers, discretionary releases, and similar topics 

• Background materials 

• FCSIC points of contact for additional assistance with search and 

redaction 

• Training materials, e.g., electronic FOIA course for new employees 

• External training and consulting resources, e.g., training by DOJ and the 

American Society of Access Professionals, DOJ’s FOIA Helpline 

4. Time milestones 

The Procedures Manual will be completed by June 30, 2007. 

5. Means of measurement of success 

We will measure success by whether the Procedures Manual is completed on 

time and by whether, following its adoption, the FCSIC continues to process all 

FOIA requests and appeals on time. 
TAB II 

1. Name: Emphasize the importance of continued politeness and 

courtesy by FOIA staff 

2. Brief statement of goal(s)/objective(s) 

We will clearly articulate our goal of continuing to treat our FOIA requesters with 

politeness and courtesy. 

3. List of all distinct steps planned to be taken 

• We will draft a memorandum to the FOIA staff that will, at a minimum, 

remind them of expectations regarding politeness and courtesy. 

• We will hold brief meetings to follow up with staff regarding this 

memorandum. 

• We will assess the FOIA’s staff treatment of FOIA requesters during the 

annual performance evaluation process. 

4. Time milestones 

We will take each of these steps by September 30, 2006, except for the 

performance evaluations, which will be by December 31, 2006. 

5. Means of measurement of success 

We will measure success by whether these steps are taken on time and by 

reviewing feedback received from FOIA requesters, including any feedback 

received by the FOIA Requester Service Center, the FOIA Public Liaison, or the 

Chief FOIA Officer. 
TAB III 

1. Promote continued intra-agency and inter-agency cooperation 

2. Brief statement of goal(s)/objective(s) 

Although there is excellent cooperation between the Corporation and FCA staff 

with respect to FOIA searches, we want to ensure that this continues. We want 

to improve intra-agency and inter-agency cooperation to ensure accurate and 

speedy searches for records and appropriate redactions. This will help maintain 

our track record of meeting the 20 business day FOIA response requirement. 

3. List of all distinct steps planned to be taken 

• We will provide written guidance to both the FOIA staff and FCSIC staff 

that will explain, at a minimum, the importance of the FOIA, permissible 

time periods for processing FOIA requests, and the renewed emphasis on 

timely FOIA responses. We will also introduce the new FOIA Officer and 

explain the function of this office. 

• We will forward appropriate written FOIA guidance to FCSIC staff. 

• We will invite FCSIC staff to FCA’s FOIA Day. 

4. Time milestones 

We will meet this milestone by September 30, 2006, except for the FOIA Day, 

which will be by June 30, 2007. 

5. Means of measurement of success 

We will measure success by completing the steps listed above and by assessing 

feedback we receive from Corporation staff, and monitoring the cooperation we 

receive from staff. 
TAB IV 

1. Name: Enhance FOIA training 

2. Brief statement of goal(s)/objective(s) 

To ensure the continued success of our FOIA program, we plan to enhance FOIA 

training for all staff, and especially for the FOIA staff. We will ensure that all new 

employees receive electronic training in FOIA upon starting employment. 

3. List of all distinct steps planned to be taken 

• We will review and revise, if necessary, the content of our current FOIA 

training. 

• We will ensure that all new employees receive relevant electronic training 

in FOIA. 

• FOIA staff will continue to receive both in-house training, as well as 

training from outside sources. 

• We will survey staff on the usefulness of our training materials. 

4. Time milestones 

We will meet this milestone by December 31, 2006. 

5. Means of measurement of success 

We will measure success by completing the steps listed above and by reviewing 

the results of training surveys. 
TAB V 

1. Name: Provide customer feedback to FOIA staff 

2. Brief statement of goal(s)/objective(s) 

We plan to provide feedback to FOIA staff based on any complaints, comments, 

or positive responses received from our FOIA requesters. Our goals are to 

reinforce the importance of clear and courteous communications with customers 

and to learn how to improve our processes. 

3. List of all distinct steps planned to be taken 

• Create a form to be used by the FOIA Requester Service Center, the 

FOIA Public Liaison, and the Chief FOIA Officer to document any 

complaints, comments, or positive responses. 

• Ensure that customer feedback is shared with the relevant parties. 

• Maintain these forms and use them as a basis for improvement, if 

applicable. 

4. Time milestones 

We will meet this milestone by December 31, 2006. 

5. Means of measurement of success 

We will measure success by completing the steps listed above and reviewing the 

feedback we receive. 
TAB VI 

1. Name: Conduct a semi-annual review of the FOIA homepage

2. Brief statement of goal(s)/objective(s) 

We plan to conduct a semi-annual review of the FOIA homepage. 

3. List of all distinct steps planned to be taken 

• Ensure the information is relevant and timely. 

• Update as necessary. 

• Check all links. 

• Ensure affirmative disclosures are posted. 

• Write a memorandum outlining the steps taken and results found. 

4. Time milestones 

We will meet this milestone by December 31, 2006, and by June 30, 2007, and 

semi-annually thereafter. 

5. Means of measurement of success 

We will measure success by completing the distinct steps listed above. 
IMPROVEMENT AREAS FOR 

AGENCY PLAN 

AREAS ANTICIPATED TO BE COMPLETED

BY 

SEPT 30, 2006 

BY 

DEC 31, 2006 

BY 

JUNE 30, 2007 

BY 

DEC 31, 20

1. Establish written procedures in the form of a Procedures Manual to enhance staff accountability and ensure continuity in the event of staff changes. 

√ Review an

update 

2. Ensure continued politeness and courtesy by FOIA staff. 

• Draft a memorandum • Hold a brief meeting • Assess 

√√

√

Ongoing 

3. Improve intra-Agency cooperation. 

• Provide written guidance • Publish periodic articles • Hold a FOIA Day 

√√

√

Ongoing 

4. Enhance FOIA training. √ Ongoing 5. Provide customer feedback to Agency FOIA staff. 

√ Ongoing 

6. Conduct a semi-annual review of the FOIA homepage. 

√ √ Ongoing