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B-202303 1 (1983-06-14)

handle is hein.gao/gaobacsqu0001 and id is 1 raw text is: 









              COMPTROL.ER GENERAL OF THE UNITED STATES
  144 WASHINGTON D.C. 2o3s


B-202303                          June 14  1983



The HonorableWilliam V. Roth, Jr.
Chairman, Committee on Governmental Affairs
United States Senate

Dear Mr. Chairman:    Do not -akct :vbiablu -or rtding

     This is in response to your request for our comments on
S. 827, 98th Cong., 1st Sess., which if enacted would be cited
as the Federal Recordkeeping and Civil Action Limitation Act
of 1983.

        eyg bs      remarksm. 0po           r      on.of
this-lb'1and         1 &     l    ,{ he.9ENongressfit  seems
a        t   ei    tof    hbil   is      to  t1  dividuals
    adgbusinesses gainst on me  overnmen  regUator yenforce-
men   ih  respe   to the    he  tseiprj\rbsiness or
                                    e~youlatdie see
persona 1endeavors  A        t   bilthusG woul'd    'tseem to
be   tend d t    l   t  hos  di      diiitlywith' ,the
Governrnent.by contract, ,grant, loan, o7 ther mechanism for
transferring ,funds    .benef;its, aspresently drafted, it would
have this ,e'ffect. Amnong'JEh'er things'utur comments address a
number of undue burdnsw8fi1i-the  tresintbill language would
place/on .Government operations. 4Many of:these burdens would
be eliminated by defining person for the purpose of proposed
section 560 of Title 5 of the United States Code to exclude
those dealing directly with the Government.

                  RECORDKEEPING PROVISIONS
 ,   The, billwould provide a uniform 3-yearjrlIimit'on the time
 thitany agency could require a -per         retin records.
While wsebelieve that reducing records retentionfequirements
is a desirable goal wie do not believe that imposing a single
maximum retention peri'od is`a d 'sirable way to achieve the
goal.  Instead, we prefer-the approach recently adopted by the
Congress in section 2(b)(2)'of 'the Paperwork'Reduction Act of
1980, Pub. L. No..;96-511, December 11, 1980, 94 Stat. 2825,
which amended 44 U.S.C. 5 2905 to provide that:

      The Adftfnistrat of General.2Services shall
      assistthe AdminisratoF, for the Office of
      Information ad Regulitory Affairs in conduct-
      ing stdaies and developing standards relating
      the record retention requirements imposed on
      the public and on State and local governments
      by Federal agencies.

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