I earlier posted about agency guidelines in reponse to the Federal Data Quality Act. Lauren Willis (Loyola-LA) wrote a letter in an attempt to use the OMB Guidelines to critique an Office of Comptroller of the Currency proposed regulation change that relied heavily on an OCC Working Paper that used a data sample to come to the conclusion that subprime home loans are priced efficiently. See here. Though it seems there was no response to the Willis critique. Apparently, in publishing the final regs, the OCC included statements about how it was complying with OMB requirements, but failed to mention the OMB Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies.