David Kris, the expert appointed by the Foreign Intelligence Surveillance Court (FISC), made the conclusion in a filing (pdf) with the court on Jan. 15. In addition to recommending measures in areas the FBI already explored, he proposed a set of broader changes necessary to restore the bureau’s “organizational culture of individual responsibility for rigorous accuracy” with the FISC, he said.

“The FBI is subject to an obligation of scrupulous accuracy in representations made to this Court,” Kris wrote. “It breached that obligation through a series of significant and serious errors and omissions.”

“These corrective actions point in the right direction, but they do not go far enough to provide the court with the necessary assurance of accuracy, and therefore must be expanded and improved.”

https://www.theepochtimes.com/court-appointed-expert-finds-fbis-proposed-surveillance-reforms-insufficient_3206425.html

Kris' 1/15/20 filing to Judge Boasberg, who presides over FISC since Collyer departed, can be found here: https://www.fisc.uscourts.gov/sites/default/files/FISC%20Misc%2019%2002%20Amicus%20Curiae%20letter%20brief%20January%2015%202020%20200115.pdf

>>8002535

In a12/23/19 Lawfare article, "Further Thoughts on the Crossfire Hurricane Report"

In Section 1, he examines all the reasons that [he hope]s indicate

the McCabe/Strozk teams did not act out of political bial.

In Section 2, Kris was decidedly critical of what the FBI did.

"b. Crossfire Hurricane. The errors in the FISA applications on Carter Page were significant and serious. They were not, in my experience, the kind of errors you would expect to find in every case. I will not belabor the point, as it seems unnecessary in light of the weight of informed opinion on the issue (I have seen no serious arguments that the errors found by the inspector general are trivial or not worthy of concern), but I feel confident saying the following. It’s not acceptable to rely on a Confidential Human Source and then not check with his FBI handler in describing his bona fides to the FISA Court (Report at viii-ix, x, 132, 160, 162, 261-262, 361, 367). It’s not acceptable to omit some potentially exculpatory recorded statements made by the FISA target to a source (id. at ix, 79-80, 127, 169 n.311). It’s not acceptable to leave unresolved credibility and perhaps factual disputes between a key source and his primary subsource (id. at ix, xii, 164, 186-193). It’s not acceptable, after closing the key source, to continue to get information from him through an Office of the Deputy Attorney General (ODAG) staffer, thereby effectively treating him as a subsource of the ODAG staffer (id. at 203, 290). And it’s certainly not acceptable for an FBI attorney to alter an email from another intelligence community agency as to whether the other agency had contact with the FISA target or treated him as a source (id. at 255). Like the inspector general (id. at 413), I “do not speculate whether the correction of any particular misstatement or omission, or some combination thereof, would have resulted in a different outcome” in the initiation and/or any of the renewals of the FISA applications on Page. The errors remain important either way."

Kris also admits he was partially wrong about the Nunes memo " Even if the Nunes memo had some of the details wrong, its basic point that this behavior was highly irregular was correct." Section 4 of the Lawfare article cited below

In Section 5 Kris comments on FISA Reform: "Broadly speaking, it may be helpful to divide the range of possible reforms into two categories: those pertaining to the initiation and conduct of FISA surveillance, and those concerning possible suppression of FISA information in judicial or other proceedings.

The American Civil Liberties Union has already called for changes in the latter area: “The system requires fundamental reforms, and Congress can start by providing defendants subjected to FISA surveillance the opportunity to review the government’s secret submissions.” Under current law, the judge reviewing a suppression motion may disclose the FISA application and related materials to defense counsel only when it is “necessary” to do so;[citations omitted]. In practice, disclosure does not occur.

[It is noteworthy, to me at least, that the ACLU believes even Trump and his team should not be subjected to unwarranted surveillance.]

https://www.lawfareblog.com/further-thoughts-crossfire-hurricane-report

Kris may have been because 2 weeks after the Horowitz report was issued, Kris obviously had done a lot of researching and pondering about its implications.