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®: CRE Regulatory Action of the Week

Failure to Withdraw Flawed Proposals and Drafts Raises Cross-cutting Data Quality Issue
In its recent memorandum to all federal agencies on Data Quality issues, OMB indicated concern with situations where agencies continue to disseminate information for an unusually long time which does not meet the new Data Quality Act standards. OMB recognized that even though such information may be labeled as "draft" or"proposed," if it remains outstanding for an extended period, it can have deleterious effects which should be remedied. However, apparently, none of the agencies have addressed this issue in their draft Data Quality guidelines. Agency guidelines should state that once it becomes apparent that a proposal or draft is flawed, or final action is deferred due to recognized problems with the proposal or draft, it will be unequivocally withdrawn rather than being consigned to indefinite status as a deferred proposal, draft, or interim position. If the problems are later resolved, the agency can then issue a new proposal or draft.

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