®: CRE Regulatory Action of the Week
CRE Submits Supplemental Comments on "Reproducibility" Standard in OMB's Data Quality Guidelines
October 29, 2001
Ms. Brooke J. Dickson
Re: Supplemental Comments on OMBís Interim Final Data Quality Guidelines
Dear Ms. Dickson:
The Center for Regulatory Effectiveness (CRE) would like to take this opportunity to supplement its comments dated October 26, 2001, to include the following additional points related to the "capable of being substantially reproduced" standard in OMB's "Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies," 66 Fed. Reg. 49718 (September 28, 2001).
Inclusion of Financial Information in the Definition of "Statistical Information"
- Associations of financial professionals have developed accepted principles of operations designed to ensure the accuracy and reliability of their work, including Generally Accepted Accounting Principles (GAAP) and Generally Accepted Auditing Standards (GAAS).
- Financial information may be subject to standards imposed by federal and state securities laws governing disclosures of financial data on publicly-traded companies.
- Independent organizations also exist that analyze public financial information and publish ratings and opinions of it.
... In a scientific or statistical context, the original or supporting data shall be generated, and the analytical results shall be developed, using sound statistical and research methods.
i. If the results have been subject to formal, independent, external peer review, the information can generally be considered of acceptable objectivity.
In a scientific, financial, or other statistical context, the original or supporting data shall be generated, and the analytical results shall be developed, using sound statistical or financial research methods.
Need to Clarify an "Acceptable Degree of Imprecision" in a Manner that Reflects the Effect of the Imprecision
10. "Capable of being substantially reproduced" means that independent reanalysis of the original or supporting data using the same methods would generate similar analytical results, subject to an acceptable degree of imprecision.
- For example, a federal agency may decide, based upon its scientific, financial, or statistical information, whether a person or entity could be subject to an adverse regulatory action. Such adverse regulatory action could include a rating, a categorization, or a notice.
- In any event, the agency's information would be subject to the "substantially reproducible" standard, and it would be allowed an acceptable degree of imprecision.
CRE appreciates this opportunity to provide additional comment, and we would be pleased to further assist the agency regarding Data Quality Act implementation, as appropriate. Please feel free to contact me, should you have any questions or require further clarification.