Letter to the OCC on the Rules Regarding the Availability of OCC Information

Dear Sir or Madam,

The American Bankers Association (ABA) appreciates the opportunity to respond to the Office of the Comptroller of the Currency's (OCC) Notice of Proposed Rulemaking (Proposal) to update and clarify the OCC's regulations regarding the disclosure of non-public OCC information (NPOI) and confidential supervisory information (CSI) and the process for submitting Freedom of Information Act (FOIA) requests.

ABA supports the OCC's goal of expanding and clarifying the circumstances in which supervised entities may disclose CSI without prior OCC approval. The Proposal contains several meaningful improvements that would facilitate legitimate business, compliance, governance, transactional, and supervisory activities while maintaining appropriate confidentiality protections.

At the same time, several elements would impose conditions that are more prescriptive and restrictive than the OCC's existing framework. Those new requirements could materially limit the practical utility of the proposed changes and, in some circumstances, make the new disclosure exceptions less workable than the OCC's existing framework. As explained below, ABA makes recommendations to help the OCC achieve the Proposal's objectives while removing unnecessary requirements, preserving workable features of the current framework, and coordinating with the other federal banking agencies to promote a consistent approach to supervisory information.

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