OCC's New Proposal to Share Confidential Supervisory Information Between Banks

The Office of the Comptroller of the Currency (OCC) has proposed to ease the rules governing when banks can disclose confidential supervisory information (CSI), which is information that can't currently leave a bank without the OCC's approval first. This change would allow banks more flexibility to share certain CSI with other institutions, raising questions for compliance teams about which disclosures now require only internal sign-off rather than the OCC's, and how confidentiality agreements with counterparties should account for that shift.

Polsinelli shareholder and former OCC enforcement lawyer Travis Nelson examines what banks should be watching as the proposal moves forward, including which of the new exceptions are likely to matter most and what it could mean for how banks manage their relationships with examiners.