Information Quality Guidelines

The OCC is committed to integrating the principle of information quality into every step of the OCC's development of information, including creation, collection, maintenance, and dissemination. The OCC will comply with all legal and policy rules, regulations, directives, and guidance at every step of the process. High quality information must be a performance goal for all OCC information that is disseminated.

Utility

In assessing the usefulness of information disseminated to the public, consider the uses of the information from the perspective of the public. When transparency of information is relevant for assessing information's usefulness from the public's perspective, address transparency when developing and reviewing the information. (Transparent refers to the clear, obvious, and precise nature of the information.)

Objectivity

Objectivity involves two distinct elements, presentation and substance:

A. Presentation:

• Disseminate information in an accurate, clear, complete, and unbiased manner. This involves presenting information within a proper context.
• Where appropriate, data should have full, accurate, and transparent documentation, and should identify and disclose error sources affecting data quality.
• Sometimes, in disseminating certain types of information to the public, other information must also be disseminated in order to ensure an accurate, clear, complete, and unbiased presentation.
  1. Identify the sources of the disseminated information (to the extent possible, consistent with confidentiality protections).
  2. In a scientific, financial, or statistical context, identify the supporting data and models so that the public can assess for itself whether there may be some reason to question the objectivity of the sources.

B. Substance:

• Focus on ensuring accurate, reliable, and unbiased information.
• In a scientific, financial, or statistical context, generate the original and supporting data, and develop the analytic results, using sound statistical and research methods.
  1. If data and analytic results have been subjected to formal, independent, external peer review, the information may generally be presumed to be of acceptable objectivity.
  2. If agency-sponsored peer review is employed to help satisfy objectivity, the review process shall meet the general criteria for competent and credible peer review, namely
     1. peer reviewers must be selected primarily on the basis of necessary technical expertise;
     2. peer reviewers must be expected to disclose to agencies prior technical/policy positions they may have taken on the issues at hand;
     3. peer reviewers must be expected to disclose to agencies their sources of personal and institutional funding (private or public sector); and
     4. peer reviews must be conducted in an open and rigorous manner.
• When disseminating influential scientific, financial, or statistical information, include a high degree of transparency about data and methods to facilitate the reproducibility of such information by qualified third parties.
  1. Department and division offices may identify, in consultation with the relevant scientific and technical communities, those types of data that can practicably be subjected to a reproducibility requirement, given ethical, feasibility, or confidentiality constraints. Reproducibility of data is an indication of transparency about research design and methods and thus a replication exercise (i.e., a new experiment, test, or sample) is not required prior to each dissemination.
  2. Concerning analytic results, provide sufficient transparency about data and methods so that a qualified member of the public could undertake an independent reanalysis. These transparency standards apply to agency analysis of data from a single study as well as to analyses that combine information from multiple studies.
  3. The guidelines do not override other compelling interests such as privacy, trade secrets, intellectual property, and other confidentiality protections.
     1. In situations where public access to data and methods will not occur due to other compelling interests, apply especially rigorous robustness checks to analytic results and document what checks were undertaken.
     2. Disclose the specific data sources that have been used and the specific quantitative methods and assumptions that have been employed.
     3. Define the type of robustness checks, and the level of detail for documentation, appropriate for the nature and multiplicity of issues for which the agency is responsible.

Influential Data

At the OCC, influential data/information is that which has a genuinely clear and substantial impact at the national level and on major public and private policy decisions as they relate to federal financial issues. The accuracy of this information is significant due to the critical nature of these decisions. An example of influential data within the OCC would be the Semiannual Risk Perspective report. Semiannual Risk Perspective reports focus on issues that pose threats to those financial institutions regulated by the OCC and are intended as a resource to the industry, examiners, and the public. For the purposes of this guidance, the OCC will develop function/program appropriate definitions for "influential" as the OCC develops processes for disseminating quality information.

Integrity

Protect information from unauthorized access or revision, to prevent corruption or falsification of information. Comply with government-wide, Treasury-wide, and OCC security requirements and OMB Circulars A-123, A-127, and A-130 when disseminating information. In addition, comply with other regulation, depending on the nature of the information.