The FBI guidelines say there needs to be pre-disposition before they can investigate a public official. But according to Burns, there is no proposal needed to start investigating someone if the undercover operation has already been approved and according to Burns, he was aware of 3 past investigations of Ford before their first meeting in April 18, 2004.
While they don't need approval to start investigating individuals, the FBI did have strict guidelines. They weren't allowed to let the legislature become a state law or have it hit the Senate floor. They had to get authority for bribe payments and they needed a service agreement with the undercover informant every six months. The informant in this case was Timothy Willis.
January 2004 was the beginning of operation.