◆ SpookStack

To: Counterterrorism From: Office of the General Counsel Re: 319X%-HQ-A1l487720-O0GC 04/11/2006 bs Further, to the extent that bills for reimbursement submitted by carriers in the past have been paid by field offices, they presumably have been done so on the theory that payment will encourage cooperation and responsiveness to an NSL request. Inasmuch as the NSL statutes were revised by the USA PATRIOT Act Improvement and Reauthorization Act of 2005 to provide for an enforcement mechanism, there is less of a need for the FBI to seek voluntary cooperation of carriers by providing payment to which the carriers are not legally entitled. Enclosed is a model letter that field offices may want to use in response to requests for payment. These letters may assume particular importance when addressed to carriers who to date have received reimbursement and suddenly find themselves cut off from reimbursement under the new FBI policy. Reimbursement of Costs Incurred by FCRA Section 168]ly NSL Recipients At the current time, Transunion does not charge for 168lv NSL requests. Reimbursement of Costs Incurred by FCRA Section 1681u NSL Recipients While FCRA Section 168lu provides for compensation for NSLs, there has yet to be promulgated a schedule of such fees. Inasmuch as a Separate fee schedule has not been adopted, it is logical that the fee schedule adopted for RFPA NSLs be the basis of ” a b7E offices handle such bills. We recommend that they coordinate with one another