As the Federal Reserve works to update its procedures for responding to Freedom of Information Act requests and its treatment of confidential supervisory information, the American Bankers Association raised concerns that the proposed changes could “expand significantly the scope of information that would be treated as CSI and subject to restrictions on disclosure.” In doing so, it could significantly limit banks’ ability to use a wide variety of information “developed in, and essential to, the routine business activities of the institution.”
In addition, ABA noted in a comment letter that while the proposal would offer some improvements for the sharing of CSI with outside counsel or auditors, the procedures would be unnecessarily burdensome. ABA urged the Fed to further streamline and clarify various aspects of the proposal, and revise it to incorporate more confidential treatment for sensitive proprietary information submitted by banks.
