The Institute of International Bankers submitted a comment letter supporting the Office of the Comptroller of the Currency’s proposal to modernize its confidential supervisory information rules, while seeking changes to reflect international banking structures and facilitate cross-border supervision. It also called for greater consistency among federal banking agencies’ information disclosure frameworks. The association recommended broadening the disclosure exemption beyond circumstances tied to the efficacy of supervision to cover legitimate business purposes, including risk management. It also urged the OCC to clarify that information may be shared with authorized affiliates, including internationally headquartered parent banks, and with home-country prudential supervisors that have a legitimate supervisory interest. Other proposals include removing the U.S. incorporation requirement for service providers, preserving existing sharing practices with attorneys and auditors, and applying a more principles-based approach to confidentiality agreements.
Institute of International Bankers supports OCC supervisory information overhaul and calls for broader cross-border sharing
The Institute of International Bankers supported the OCC’s proposed modernization of confidential supervisory information rules but requested broader sharing permissions. Its recommendations would facilitate disclosures to foreign parent banks, home-country supervisors and service providers while preserving access for attorneys and auditors.