The old captain died not a minute too soon (from the executive summary of an internal FBI audit released today, below):

“… we identified many instances in which the FBI obtained telephone toll billing records and subscriber information from 3 telephone companies pursuant to more than 700 ‘exigent letters’ signed by personnel in the Counterterrorism Division without first issuing national security letters [NSL]. We concluded that the FBI’s acquisition of this information circumvented the requirements of the ECPA [Electronic Communications Privacy Act] NSL statute and violated the Attorney General’s Guidelines for FBI National Security Investigations and Foreign Intelligence Collection … and internal FBI policy” (p. 41).

Until later.