FR 2025-05334

General Summary

The recent notice from the Federal Bureau of Investigation (FBI)'s Criminal Justice Information Services (CJIS) Division outlines a proposal to gather information through the use of the FBI Expungement and Sealing Form (FD-1114). This process involves making a formal request to the Office of Management and Budget (OMB) for approval, in line with the Paperwork Reduction Act of 1995. The form is designed to maintain the accuracy, integrity, and security of identity history information managed by the FBI's systems. Public comments on this proposal are invited until April 28, 2025. The forecast identifies around 147,610 respondents and estimates an annual burden of consumption exceeding 8,611 hours.

Significant Issues and Concerns

The document, while comprehensive, presents several issues. Firstly, the basis for projecting the number of respondents and calculating the annual burden in hours lacks transparency. Further clarification on how these figures were derived would promote understanding and support public and stakeholder confidence in the proposal.

Moreover, there is a section labeled as containing the term 3.5, which could confuse readers. Clarifying this as "3.5 hours" would eliminate any ambiguity.

Additionally, the abstract's complexity may pose challenges for readers unfamiliar with legal jargon and technical language. Simplification of this section could make the information more accessible to a wider audience. Moreover, details about the methodology used for cost and time estimates are not disclosed, leaving room for potential misunderstanding or misinterpretation.

Impact on the Public

The implementation of this information collection initiative ensures that identity history records are handled with accuracy and confidentiality, aligning with federal regulations. As such, it is essential for the accuracy and reliability of national records, fostering public trust in governmental data management practices.

However, the projected respondent base primarily consists of government entities, and the effective implementation of this proposed program may indirectly require public entities to increase their resource allocation to comply with new guidelines. While there is no financial cost reported, this could translate into a time and resource burden for these participants.

Impact on Specific Stakeholders

The document impacts several groups, notably state, local, tribal, and federal governments. These bodies are mandated to participate, given their responsibility for ensuring data accuracy as per federal regulations. While beneficial in terms of maintaining accurate records, this obligation could strain resources, requiring adjustments to existing processes or the implementation of new technologies.

For members of the public concerned with privacy rights and data accuracy, the proposal could provide an assurance of improved accountability and reliability in data management across FBI systems. Enhancing the clarity of how these systems manage expungement and sealing requests could reinforce public confidence in governmental operations concerning personal data privacy.

In conclusion, while the initiative itself aligns with maintaining accurate and secure data systems, its success hinges on clear communication and transparency in methodology and impact evaluations. Addressing these issues could improve the implementation process and client-stakeholder relations.

The document outlines the proposed collection of information regarding the FBI Expungement and Sealing Form (FD-1114) and provides an insight into how financial allocations are discussed within this context.

The notable financial reference within the document states that the total estimated annual other costs burden associated with this information collection is $0. This implies that there are no additional financial expenses anticipated for executing this collection process, thereby indicating that the primary burdens are non-monetary, primarily consisting of time and administrative efforts.

This point leads to questions about transparency and the methodology behind the estimation of costs and time. It raises important considerations about how these estimates are derived, specifically, how the time burden translates into financial implications even if no direct cost is anticipated.

The document further mentions that the total estimated number of respondents is 147,610, with an estimated time per respondent of 3.5 hours, leading to a total estimated annual time burden of 8,611 hours. While monetary costs are stated as non-existent, the substantial time commitment indirectly translates to a significant allocation of human resources. Each respondent dedicates 3.5 hours, culminating in a collective investment of over eight thousand hours annually. Such a significant time expenditure reflects the true cost absorbed by the responding entities, whether they are state, local, tribal, or federal governmental bodies.

Moreover, the document does not delineate how the absence of financial costs impacts the broader agency operations or resources. In the context of government procedures and functions, the allocation of human resources and the dedication of thousands of hours can impose indirect costs, such as productivity loss or the need for additional administrative support, which might not be evident in direct monetary terms but can have operational consequences.

In summary, while the document explicitly states that the financial cost burden is $0, the associated non-financial costs, in the form of administrative time and effort, present a more nuanced understanding of the true burden of this information collection initiative. This raises issues about whether the methodology and transparency regarding these financial assumptions are sufficiently detailed to provide a clear understanding to stakeholders and the general public.