Outline of OIG Investigation into FBI Conduct in Crossfire Hurricane Investigation

The DOJ Office of the Inspector General Report :

Review of Four FISA Applications and Other Aspects of the FBI's Crossfire Hurricane Investigation A Short Outline of the Executive Summary

(prepared by Brian T. Lynch, MSW)

1.      “… the FBI opened Crossfire Hurricane on July 31, 2016, just days after its receipt of information from a Friendly Foreign Government

a.     Papadopoulos "suggested the Trump team had received some kind of suggestion from Russia that it could assist ... with the anonymous release of information ... damaging to Mrs. Clinton

b.     The FBI… (EC) open[ed] the Crossfire Hurricane investigation state[ing] that…  "this investigation is being opened to determine whether individual(s) associated with the Trump campaign are witting of and/or coordinating activities with the Government of Russia."

c.     [The OIG] did not find information … indicating that any information other than the FFG information was relied upon to predicate the opening of the Crossfire Hurricane investigation.

d.     FBI officials involved … had reason to believe that Russia may have been connected to the Wikileaks disclosures … in July 2016, and were aware of … Russia's efforts to interfere with the 2016 U.S. elections.

e.     [The FBI] did not become aware of Steele's election reporting until weeks later and we therefore determined that Steele's reports played no role in the Crossfire Hurricane opening.

2.     The FBI assembled a …team of special agents, analysts, and supervisory special agents …[to] conducted an initial analysis of links between Trump campaign members and Russia. Based upon this …analysis, the Crossfire Hurricane team [as they were known] opened individual cases in August 2016 on four U.S. persons - Papadopoulos, Carter Page, Paul Manafort, and Michael Flynn- all of whom were affiliated with the Trump campaign at the time the cases were opened.

3.     Crossfire Hurricane was opened as a Full Investigation and all of the senior FBI officials who participated in discussions about whether to open a case told [The OIG] the information warranted opening it…. [T]he combination of the FFG [foreign friendly government] information and the FBI 's ongoing cyber intrusion investigation of the July 2016 hacks of the Democratic National Committee's (DNC) emails, created a counter-intelligence concern that the FBI was "obligated" to investigate. 

4.     Additionally, …[the OIG] concluded that the FFG information, provided by a government the [U.S.] Intelligence Community (USIC) deems trustworthy, and describing a first-hand account from an FFG employee of a conversation with Papadopoulos, was sufficient to predicate the investigation. This information provided the FBI with an articulable factual basis that, if true, reasonably indicated activity constituting either a federal crime or a threat to national security, or both, may have occurred or may be occurring.

5.      [The OIG] also sought to determine whether there was evidence that political bias or other improper considerations affected decision making in Crossfire Hurricane, including the decision to open the investigation … General Counsel, and a FBI Deputy General Counsel. We concluded that …the investigation was in compliance with Department and FBI policies, and [the OIG] did not find documentary or testimonial evidence that political bias or improper motivation influenced [the] decision.

6.     The Crossfire Hurricane investigation was properly designated as a "sensitive investigative matter," or SIM, by the FBI because it involved the activities of a domestic political organization or individuals prominent in such an organization …We concluded that the FBI satisfied the DIOG's approval and notification requirements for SIMs.

7.      

8.     The AG [and DIOG] Guidelines require that the " least intrusive" means or method be "considered" when selecting investigative techniques … Each of [the initial steps] authorized under the DIOG was a less intrusive investigative technique.

9.     Thereafter, the Crossfire Hurricane team used more intrusive techniques …[The OIG] determined that the CHS operations conducted during Crossfire Hurricane received the necessary FBI approvals.

10.  [The OIG] found it concerning that [DOJ] and FBI policy [do] not require the FBI to consult with any Department official in advance of conducting CHS operations involving advisors to a major party candidate's presidential campaign …and [The OIG]  include[ed] a recommendation to address this issue.

11.  At the request of the FBI, the Department filed four applications with the FISC seeking FISA authority. targeting Carter Page. The first application on October I , 2016, and three renewal applications on January, April, and June , 2017.

a.     … the Crossfire Hurricane team's receipt of Steele's election reporting…played a central and essential role in the FBI's and Department's decision to seek the FISA order.

b.     …the same day that the Crossfire Hurricane team first received Steele's election reporting, the team contacted FBI OGC again about seeking a FISA order for Page and specifically focused on Steele's reporting in drafting the FISA request.

c.     Although the team also was interested in seeking FISA surveillance targeting Papadopoulos, the FBI OGC attorneys were not supportive. FBI and NSD officials told [the OIG] that the Crossfire Hurricane team ultimately did not seek FISA surveillance of Papadopoulos, and…no information indicat[ed] that the team requested or seriously considered FISA surveillance of Manafort or Flynn.

d.     [The OIG] did not find documentary or testimonial evidence that political bias or improper motivation influenced the FBI's decision to seek FISA authority on Carter Page.

e.     However, as we explain below, the Department decision makers who supported and approved the application were not given all relevant information.

f.      [The OIG] found that the FBI did not have information corroborating the specific allegations against Carter Page in Steele's reporting when it relied upon his reports in the first FISA application or subsequent renewal applications.

g.     However, absent corroboration for the factual assertions in the election reporting, it was particularly important for the FISA applications to articulate the FBI's knowledge of Steele's background and its assessment of his reliability.

h.     [The OIG] review found that FBI personnel fell far short of the requirement in FBI policy that they ensure that all factual statements in a FISA application are "scrupulously accurate."

i.      [The OIG] identified multiple instances in which factual assertions relied upon in the first FISA application were inaccurate, incomplete, or unsupported by appropriate documentation, based upon information the FBI had in its possession at the time the application was filed. [This included] the following seven significant inaccuracies and omissions:

                                               i.     Omitted information the FBI had obtained from another U.S. government agency detailing its prior relationship with Page…

                                             ii.     Included a source characterization statement asserting that Steele's prior reporting had been "corroborated and used in criminal proceedings,"

                                            iii.     Omitted information relevant to the reliability of Person 1, a key Steele sub-source

                                            iv.     Asserted [incorrectly] that the FBI had assessed that Steele did not directly provide to the press information in the September 23 Yahoo News article based on the premise that Steele had told the FBI that he only shared his election-related research with the FBI and Fusion GPS…

                                              v.     Omitted Papadopoulos's consensually monitored statements…in September 2016 denying that anyone associated with the Trump campaign was collaborating with Russia or with outside groups like Wikileaks in the release of emails

                                            vi.     Omitted Page's consensually monitored statements…that Page had "literally never met" or "said one word to" Paul Manafort and that Manafort had not responded to any of Page's emails…

                                           vii.     Included Page's consensually monitored statements…that the FBI believed supported its theory that Page was an agent of Russia but omitted other statements Page made that were inconsistent with its theory, including denying having met with Sechin and Divyekin, or even knowing who Divyekin was…

j.      Further, as we discuss later, we identified 10 additional significant errors in the renewal applications.

k.     [The OIG] found that the team had speculated that Steele's prior reporting had been corroborated and used in criminal proceedings without clearing the representation with Steele's handling agent, as required

l.      [The OIG] concluded that these failures created the inaccurate impression in the applications that at least some of Steele's past reporting had been deemed sufficiently reliable by prosecutors to use in court, and that more of his information had been corroborated than was actually the case.

m.   [The OIG] found no evidence that the 0I Attorney, NSD supervisors, ODAG officials, or Yates were made aware of these issues…

n.     Although [the OIG] found no evidence that [James] Comey had been made aware of these issues at the time he certified the [FISA] application…multiple factors made it difficult [to] determine the extent of FBI leadership's knowledge as to each fact…in the FISA applications. These factors included…limited recollections, the inability to question Comey or refresh his recollection with relevant, classified documentation because of his lack of a security clearance, and the absence of meeting minutes that would show the specific details shared with Comey and [Andrew] McCabe during briefings.

12.  the FBI closed Steele as a CHS for cause in November 2016. However…despite having been closed for cause, the Crossfire Hurricane team continued to obtain information from Steele through [a Department Attorney, Bruce] Ohr, who met with the FBI on 13 occasions to pass along information he had been provided by Steele.

a.     …the Central Intelligence Agency (CIA) expressed concern about the lack of vetting for the Steele election reporting and asserted it did not merit inclusion in the body of the [Intelligence Community Assessment (ICA) report.

b.     …the FBI, including Comey and McCabe, sought to include the reporting in the ICA. Limited information from the Steele reporting ultimately was presented in an appendix to the ICA.

c.     …the FBI's Validation Management Unit (VMU) completed a human source validation review of Steele in early 2017. The VMU review found that Steele's past criminal reporting was "minimally corroborated," and included this finding in its report that was provided to the Crossfire Hurricane team.

d.     The VMU review also did not identify any corroboration for Steele's election reporting among the information that the Crossfire Hurricane team had collected. However, the VMU did not include this finding in its written validation report …and therefore members of the Crossfire Hurricane team and FBI executives were unaware of it.

e.     [The OIC] further determined that the Crossfire Hurricane team was unable to corroborate any of the specific substantive allegations regarding Carter Page contained in the Steele’s election reporting which the FBI relied on in the FISA applications.

13.  …the FBI filed three renewal applications with the FISC… In addition to repeating the seven significant errors contained in the first FISA application…[the OIG] identified 10 additional significant errors in the three renewal applications…[each outlined in the report]

a.     Among the most serious of the 10 additional errors we found in the renewal applications was the FBI's failure to advise OI or the court of the inconsistences… between Steele and his Primary Sub-source on the reporting relied upon in the FISA applications.

b.     FBI also failed to share other inconsistencies with OI, including the Primary Sub-source's account of the alleged meeting between Page and Sechin in Steele's Report 94 and his/her descriptions of the source network.

14.  [The OIG] concluded that the failures described [in their] report represent serious performance failures by the supervisory and non-supervisory agents with responsibility over the FISA applications. These failures prevented OI from fully performing its gatekeeper function and deprived the decision makers the opportunity to make fully informed decisions… this was a failure of not only the operational team, but also of the managers and supervisors, including senior officials, in the chain of command.

15.  [The OIG] did not identify a specific Department policy prohibiting [Department attorney Bruce] Ohr from [having multiple meetings] with [Christopher] Steele, [Glenn] Simpson [the owner of Fusion GPS], or the State Department and providing the information he learned from those meetings to the FBI…[However the OIG] concluded that Ohr committed consequential errors in judgment by ( 1) failing to advise his direct supervisors or the DAG that he was communicating with Steele and Simpson and then requesting meetings with the FBI's Deputy Director and Crossfire Hurricane team on matters that were outside of his areas of responsibility, and (2) making _himself a witness in the investigation by meeting with Steele and providing Steele's information to the FBI.

16.  The FBI's CHS Policy Guide (CHSPG) provides… [that] a handling agent must not initiate contact with or respond to contacts from a former CHS who has been closed for cause absent exceptional circumstances that are approved by an SSA. [The OIG] concluded that the repeated contacts with Steele should have triggered the CHS policy requiring that such contacts occur only after an SSA determines that exceptional circumstances exist…[and that]… 13 different meetings [between Steele and] Ohr over a period of months…created a relationship by proxy that should have triggered…a supervisory decision about whether to reopen Steele as a CHS or discontinue accepting information indirectly from him through Ohr.

17.  …the Crossfire Hurricane team tasked several CHSs, which resulted in multiple interactions with Carter Page and George Papadopoulos, both before and after they were affiliated with the Trump campaign, and one with a high-level Trump campaign official who was not a subject of the investigation. All of these CHS interactions were consensually monitored and recorded by the FBI…[the OIG] found no evidence that the FBI used CHSs or UCEs to interact with members of the Trump campaign prior to the opening of the Crossfire Hurricane investigation…[and] found no evidence that the FBI placed any CHSs or UCEs within the Trump campaign or tasked any CHSs or UCEs to report on the Trump campaign. [The OIG] also found no documentary or testimonial evidence that political bias or improper motivations influenced the FBI's decision to use CHSs or UCEs to interact with Trump campaign officials in the Crossfire Hurricane investigation.

18.  While [the OIG] concluded that the investigative activities undertaken by the Crossfire Hurricane team involving CHSs and UCEs complied with applicable Department and FBI policies…in certain circumstances Department and FBI policies do not provide sufficient oversight and accountability for investigative activities that have the potential to gather sensitive information involving protected First Amendment activity, and therefore [the OIG] include[d] recommendations to address these issues.

The Economy and Society Benefit When Poor Families Have More to Spend

by Brian T. Lynch, MSW

Enhancing the human dignity of employment is an obvious, self-evident social benefit of raising minimum wages. It is both empowering and ennobling when breadwinners are able to provide for the needs of their family on their own, without government or extended family supports. This is reason enough to enact a living wage law. The minimum fair exchange for a full-weeks work ought to be a self-sufficient minimum wage. The burden for this minimum standard of living should rightly be on employers and not on the taxpayers who currently help support full-time low wage earners.

Corporations and business owners enjoy the benefits of government-subsidized labor and don’t want to give it up. Most of their arguments opposing higher wage standards rely on business-friendly economists whose academic theories and scholarly studies plum the detrimental impacts on businesses from higher labor costs. It is current practice to treat workers as a labor commodity separate from workers and their families as consumers and social beings with basic human needs. It is also current practice to take a business view of the economy without consideration of the broader context of the overall social economy within which commerce operates. All this results in flawed and biased arguments against self-sufficient minimum wages.

The overall beneficial impacts of increasing the purchasing power among poor families are rarely studied. Now a major new study has found that the ripple effects when direct, substantial cash assistance is given to poor families have, “… large positive spillovers on non-recipient households and firms, and minimal price inflation. The researchers in this large-scale experiment in Kenya estimated that a direct cash payment of $1,000 US dollars to poor families within randomly selected communities resulted in a local fiscal multiplier of 2.6 times within the local communities.

In addition to measured improvements in the welfare of the children and families who received an infusion of cash, the experiment reinforced the relationship between income and increased consumption to the benefits of both businesses and the families who did not receive cash payments. Here is an excerpt from the study:

“A large-scale cash transfer program in rural Kenya led to sharp increases in the consumption expenditures of treated households, and extensive broader effects on the local economy, including large revenue gains for local firms (that line up in magnitude with household consumption gains), as well as similar increases in consumption expenditures for untreated and treated households approximately a year and a half after the initial transfers. Local firms do not show meaningful increases in investment, and there is minimal local price inflation, with quite precisely estimated effects of far less than 1% on average across a wide range of goods.” [snip]... The consumption expenditures of untreated households and firms rise substantially in areas receiving large cash transfers…”

The infusion of cash payments to poor families in the study did not come from employers, and the economy of Kenya is very different than the economy here in the US. Directly extrapolating the results isn’t possible. Nevertheless, these findings are hopeful. The high fiscal multiplier stimulus effect on local businesses from increased consumption by poor families appear to mirrored results found here within states and municipalities that have raised minimum wage standards. While the burden of cash transfers from higher minimum wages is on businesses, the literature I’ve seen so far suggests there is still a positive fiscal multiplier within the business community coupled with little increase in unemployment and negligible increases in inflation.

A broader look at the spillover effects of increased base wages might show similarly positive results for the business economy and those workers who are already self-sufficient wage earners. Future studies of communities where the wage base is improved should also look at the wellbeing and overall welfare of children living in low wage households as well as the social wellbeing of the wage earners themselves.

_____________________________________

Further Reading

Debunking the Myth That It's Your Fault You're Poorhttps://aseyeseesit.blogspot.com/2015/09/debunking-myth-that-its-your-fault.html

Myth Busting Data RE: Minimum Wage Increaseshttps://aseyeseesit.blogspot.com/2012/09/myth-busting-data-re-minimum-wage.html

Making the Case for a Living Wage  https://aseyeseesit.blogspot.com/2012/07/making-case-for-living-wage.html

NPR -

Researchers Find A Remarkable Ripple Effect When You Give Cash To Poor Families

 https://www.npr.org/sections/goatsandsoda/2019/12/02/781152563/researchers-find-a-remarkable-ripple-effect-when-you-give-cash-to-poor-families

The Rise of a Disloyal Opposition

by Brian T. Lynch, MSW

It isn’t too radical to say that the Republican Party establishment is no longer compatible with the democratic ideals on which our republic was founded. If that shocks you or disturbs you, you are in good company. This isn’t how most of us picture things. For well over a hundred years politicians in both parties have been unquestioningly loyal to democratic principles, to this republic, the Constitution, and the rule of law. This truth is the source of the phrase “the loyal opposition.” Members of the "other side" were always opponents, not enemies.

But politics isn’t static, of course. It evolves, and our understanding of how governments and society have changed must change as well. This is difficult because most changes unfold very slowly. We keep up by taking the occasional mental snap-shots of the surroundings, but the tendency to hold on to these images is strong as we struggle to manage our busy lives. We reconcile our views of events from day to day until one day some event or a crisis comes along that scrambles how we pictured things. We are living in one of those times.

Tracing the details of how our politics changed is too broad a topic. Seeing one essential feature, the decline of majority rule in government, is the point here. To help do that, the rise of the Christian-right in politics provides a helpful starting point. To be clear, these trends and changes impact every aspect of our politics, including the growing tensions now on display in the Democratic primary. But the impact is most obvious in the GOP as the majority of us struggle to understand the Republican response to the current impeachment inquiry.

The political rise of the Christian-right at the end of the Twentieth-century is not in dispute. Of the primary reasons for this shift, their views on legal abortion predominate. The standard means of resolving religious differences involves evangelizing until the majority viewpoint of citizens are swayed. In the 1980s the religious right came to realize that anti-abortion sentiment may never predominate in a modern, pluralistic democracy. That inability to convince the majority to willingly outlaw abortion is what brought the Christian-right into politics. They sought, and still seek to legislate what they cannot attain through indoctrination or persuasion.

But politics and power have a corrupting influence on religion. After gaining political influence and even after gaining positions as elected officials, the Christian-right was still unable to pass their unpopular legislation within a system based on majority rule. They would eventually compromise certain Christian and democratic values to join a coalition of other minority interests and fringe political groups under the umbrella of the GOP. Secular pluralism would come to be seen by fundamentalist Christians as American society’s moral decay, and government by majority rule would come to symbolize evil in the eyes of some fundamentalist Christians.

These same hard lessons about majority rule also frustrated the economic caste of America’s wealthiest elites. In the corporate world where decision making is proportional to one's ownership share (or wealth). One person-one vote was a significant barrier to enacting laws and policies that the industrial elite favored because they are so few in number.

But money is power. The Barrons of industry resorted to buying government influence in order to reshape state and federal rules so they could buy even more influence over time. They corrupted politicians with campaign cash and perks. This is particularly true in the Republican Party where the industrial elite focused most of their attention. Now the Republicans in Congress routinely pass and implement policies favorable to the rich regardless of how unpopular or harmful to the general population.

As stated above, this transition is a feature in both political parties, but it is especially evident in the GOP where frustration with majority rule has passed the tipping point.

Frustration with majority rule has become a unifying feature that transformed the GOP into an odd coalition of minority and fringe interest groups united by their desire to overcome the majority in order to achieve their unpopular agendas. The rise of Donald Trump and his corrupt, authoritarian style of leadership has accelerated this transition.

Just as the Christian-right has had to make some unchristian compromises, so have the industrial elites and every other minority or fringe interest group within the Republican coalition. In the process, the GOP has morphed into an anti-democratic movement that will do whatever it takes towards a totalitarian rule. This coalition of disgruntled minority interest groups will even propagate Russian disinformation talking points if it excites their base and wins over their support. 

The GOP is no longer faithful to democratic principles or even the rule of law. We have lost the consent of the minority to majority rule. Political opponents are cast as political enemies in an all-out battle for Unitarian control. The opposition is no longer loyal.

Understanding the truth is the first step in identifying ways to save our republican form of government.

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Further Reading:

Coup d'état – The Revolution Has Been Televised for Years

On September 19th Donald Trump Declared Himself our Dictator

ALSO: Listen to this interview by Bill Moyer of psychiatrist and author Robert Jay Lifton. His new book is Losing Reality  https://billmoyers.com/story/losing-reality-can-we-get-the-truth-back/

Shadow Banking a Growing Threat to Global Financial Stability

by Brian T. Lynch, MSW

A Caribean Island Resort

A new global financial regulatory agency, the Financial Stability Board (FSB), quietly emerged from the dust of the Great Recession of 2007. "The FSB’s creation came after the G20 Summit in London in April 2009.

Headquartered in Basel, Switzerland, the board includes all G20 major economies. The FSB consists of 68-member institutions. It comprises several central banks, ministries of finance, and supervisory and regulatory authorities from 25 jurisdictions, as well as 10 international organizations and six Regional Consultative Groups (RCGs). It’s stated purpose seems to be, “… policy work to enhance the resilience of non-bank financial intermediation… [focusing] on those parts of non-bank financial intermediation that perform economic functions which may give rise to bank-like financial stability risks.”

In other words, global shadow banking and finance networks have grown so large and powerful that they pose a threat to the whole nation-based international banking and finance system.

The Financial Stability Board says they are responsible for:

· Preparing annual reports on the implementation of reforms and their effects

· Coordinating financial sector policies

· Conducting outreach activities [To WHOM?]

· Building resilient financial institutions

· Addressing SIFIs [Systemically Important Financial Institutions]

· Making the derivates market safer [Which was the epicenter of the financial collapse in 2007]

· Enhancing the resilience of non-bank financial intermediation [NBFI]

· Formulating additional policies on specific areas of the global financial market

· Preparing progress reports to the G20 

.  Conducting peer reviews

· Analyzing the effects of reforms

So, this is an autonomous international agency reporting to the G20, yet it is independent of the G20 or any other democratically elected government authority. It analyzes and proposes and monitors non-government enforced regulations of cross-border financial interactions between traditional international banking institutions and the global shadow banking institutions. It exists to keep the global economy on an even keel, and it prepares reports. Here is their 2018 report on the health and extent of global, non-standard financial institutions.  Global Monitoring Report on Non-Bank Financial Intermediation 2018 

Have you ever heard of NBFI, "Non-Bank Financial Intermediation?"

I first came across this term looking for information about a high-end tourist destination, a small, self-governing island in the Caribean, one of many such places. In addition to high-end tourism, its economy is also dependent on offshore financial services. Among the financial services listed on the internet about the Island's economy is the 'financial intermediation sector. (The what, I ask? )

Section #4 of the FSB report explains that financial intermediation: "… focuses on those parts of non-bank financial intermediation where bank-like financial stability risks may arise. The narrow measure of non-bank financial intermediation, which reflects an activity-based “economic function” assessment of risks, grew by 8.5% to $51.6 trillion in 2017, at a slightly slower pace than 2011-16. The narrow measure of non-bank financial intermediation, which reflects an activity-based “economic function” assessment of risks, grew by 8.5% to $51.6 trillion in 2017, at a slightly slower pace than 2011-16.

Since 2011, the Cayman Islands, China, Ireland, and Luxembourg together have accounted for over two-thirds of the dollar value increase. The narrow measure represents 14% of total global financial assets. Key components include:

· Collective investment vehicles (CIVs)

· Non-bank financial entities engaging in loan provision that is dependent on short-term funding

· Market intermediaries that depend on short-term funding or secured funding

· Securitisation-based credit intermediation

Section 2 provides an overview of, “Other Financial Intermediaries” (OFIs) aggregate, which includes all financial institutions that are not central banks, banks, insurance corporations, pension funds, public financial institutions or financial auxiliaries. These alt-financial entities grew by 7.6% in 2017. OFIs’ growth exceeded that of banks, insurance corporations, and pension funds. With $116.6 trillion, OFI assets represent 30.5% of total global financial assets, the largest share on record."

These invisible, unaccountable entities are apparently a go-to source for loans by the global banks and nation-based financial institutions. In November 2010, the FSB defined shadow banking as “credit intermediation involving entities and activities (fully or partly) outside of the regular banking system” 

Then, On 22 October 2018, the FSB announced its decision to replace the term “shadow banking” with the term “non-bank financial intermediation,” a less sinister sounding accommodation.

So, what is really going on here? 

It seems that billionaires, oligarchs, and their self-dealing minions are growing an alternate financial network that is fully or partially outside of national boundaries. It is certainly outside the direct control of the traditional international banking and finance systems. Traditional international bank institutions appear to be both fearful of, and increasingly dependent on this dark money network the reach of nations. The FSB says, “Non-bank financing provides a valuable alternative to bank financing for many firms and households, fostering competition in the supply of financing and supporting economic activity.”

Competition indeed. The OFTs alone account for close to a third of all the world’s financial wealth. This appears to be a socially malignant private treasury of wealth with no direct productive value. It is accessible only to wealthy corporations and the very rich. The capital gains of this private wealth cannot be taxed for the benefit of any global society.

This whole development may be more than a financial risk to the global economy. It may be a burgeoning threat to the sovereignty of nations and the sanctity of self-governing democracies everywhere. It is a development worthy of our attention and vigilance.

Read the full FSB report here:https://www.fsb.org/wp-content/uploads/P040219.pdf