Chief Counsel’s Office Attention: Comment Processing Office of the Comptroller of the Currency 400 7th Street SW, Suite 1E-216 Washington, DC 20219.
Re: OCC Rules Regarding the Availability of OCC Information
The Conference of State Bank Supervisors (“CSBS”)1 provides the following comments on the Office of the Comptroller of the Currency’s (“OCC”) Notice of Proposed Rulemaking (“proposal”) entitled OCC Rules Regarding the Availability of OCC Information.2
The OCC should permit supervised entities to disclose confidential supervisory information (“CSI”) to state agencies without obtaining prior approval from the OCC, consistent with the proposed requirements in §4.14(b)(2).3 The rationales for permitting entities to share CSI with federal agencies without prior OCC approval equally apply to requests from state agencies.4 Just as the OCC recognizes that it may be necessary for a supervised entity to share CSI with a federal agency, and the need for OCC prior approval can cause unnecessary delays, so too, permitting entities to share CSI with a state agency under certain circumstances would reduce the regulatory burden on supervised entities and facilitate the supervisory process at the state level.5
Several routine corporate activities would benefit from streamlined CSI sharing with state agencies, including charter conversions, M&A transactions, and applications involving banking organizations that include entities chartered by both a state agency and the OCC (e.g., a bank holding company with a state-chartered bank subsidiary and a national trust bank affiliate). In all these instances, allowing an entity to share OCC CSI with the relevant state agency without prior approval would save time and reduce burden on supervised entities.
CSBS is the nationwide organization of state banking and financial regulators from all 50 states, the District of Columbia, and the U.S. territories. The views presented in this letter may not reflect the policy of individual states.
Chief Counsel’s Office
Attention: Comment Processing
Office of the Comptroller of the Currency
400 7th Street SW, Suite 1E-216
Washington, DC 20219.
Re: OCC Rules Regarding the Availability of OCC Information
The Conference of State Bank Supervisors (“CSBS”)1 provides the following comments on the Office of the Comptroller of the Currency’s (“OCC”) Notice of Proposed Rulemaking (“proposal”) entitled OCC Rules Regarding the Availability of OCC Information.2
The OCC should permit supervised entities to disclose confidential supervisory information (“CSI”) to state agencies without obtaining prior approval from the OCC, consistent with the proposed requirements in §4.14(b)(2).3 The rationales for permitting entities to share CSI with federal agencies without prior OCC approval equally apply to requests from state agencies.4 Just as the OCC recognizes that it may be necessary for a supervised entity to share CSI with a federal agency, and the need for OCC prior approval can cause unnecessary delays, so too, permitting entities to share CSI with a state agency under certain circumstances would reduce the regulatory burden on supervised entities and facilitate the supervisory process at the state level.5
Several routine corporate activities would benefit from streamlined CSI sharing with state agencies, including charter conversions, M&A transactions, and applications involving banking organizations that include entities chartered by both a state agency and the OCC (e.g., a bank holding company with a state-chartered bank subsidiary and a national trust bank affiliate). In all these instances, allowing an entity to share OCC CSI with the relevant state agency without prior approval would save time and reduce burden on supervised entities.
Read the full comment letter.
CSBS is the nationwide organization of state banking and financial regulators from all 50 states, the District of Columbia, and the U.S. territories. The views presented in this letter may not reflect the policy of individual states.
OCC, Notice of Proposed Rulemaking, OCC Rules Regarding the Availability of OCC Information, 91 Fed. Reg. 50610 (Aug. 5, 2026).
See Question 15, id. at 50627.
See id. at 50622.
See id. at 50623.