Created: 10/3/1991

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SUBJECT: Comments on House Banking Committee Letter of 30

1 Regarding Its Investigation of SCCI and First American Bank

Z have spokenumber of people regarding subject letter. Froa numerous discussions of the HBC interest in FAB, participation in tho briefing of the hbc staff which gave rise to this letter, and my knowledge of the information contained in FAB banknique perspective on the matter. averaft raaponoa tolottery no* havingin theish to share my views with thoss who will decide on its final-version. OCA, OGC, and the Office of the DDO have offered copies of this latter, invitinghis is thatcommentary.

At the outseti my present point of view is from the operations side of the question (as distinguished from the policy aide.) ake no evaluation of the motivation of ths KBC In


ursulhg the "CIA angle." As is true of many requests for information, we need to look beyond the issue at hand and consider carefully the conssquencs of the position we take. ave'neither the experience nor background to suggest the appropriate tack in this regard. Kaving saidould hope that my comments will offer possibilities foronclusion of this investigationay which protsots ourow and In the future.

a previous MFR (datedndicated,not very satisfied with the meetings ws held with Dennisthe hbc. Dennis struck meeasonable, yetwho seemed totonewall position fromidea and his of being responsive were far apart. Thehis investigations (involving banking irregularities andas he told us, requires extensive review ofapproach to protection ofis todescriptions of our [ eserving details toOversight committees, ana even there to ur position continues to make senee. same time, it Is blear to me that one cannot reachabout I without knowing thothe I only one side wine here.





First, weoint with the HBC staff that we wareto acknowledge that "vv

protsotad. Beyond th. activity

toUS corns.

Second, the subpoena In question calls for action by First

Aaarlcan Dank

mink our response to the Hbc should ba to provlde^them

lt t0 UBfor information

they need.

ead in the hbc letter greatar concession to our security concernsxpected, specifically, the committee staff recognises the problem of allowing uncleared

The_kbc Beans to agrse that the Agency shoulday Inba Involved.

nexi, ue hbc staff

undarstanoaconoTder some-Information is too sensitive to be accumulated, even under secure circumstances. ead this to mean that we will be able to carve out of tho Investigation

(through general briefing of tho HBC staffJJ

the most sensitlvs identities:

S. ave no quarrel with the position taken in the draft response with respect to the DCI's statutory responsibility to protect methods and sources. (It is Ironic that tho Congress which so charged tho DCI is now attempting to compel him to do something less than ho believes he needs to do.) The point that this is, perhaps, the camel's nose coming under the tent is" properly made. Now, what do wa offer? hink we ought to take an aggrassivaly responsive position now. Without conceding the



the IG's report available to the HPSCI andleared HBC staffer and/or Member to read lt.

to-cleared HBC staffers the same briefing on tho

individual I

and tne identities

excluding the n

KsJto avaiiaolo to the KBCIC Inapoetor and/or auditor to

aaarch theecords relatedfor any

namesof spacific interest to the HBC.

Provide to Congressman Bereuterember of both HPSCI and HBC) details of any information discovered by the IO which responds directly to speoific questions asked by HBC.

offer to prasent any unresolved issues to both the hpscipresident's Intelligence Oversight Board for review


Offics or Financial Managanent

Original document.

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