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Survey of Information Sharing Protections

Background 

The purpose of the CSBS Information Sharing Protection Task Force (Task Force) is to provide process and guidance to State agencies about information sharing among States that is (a) protected from disclosure in accordance with the Federal SAFE Act, state law generally, and potentially state SAFE Act enabling legislation, and (b) potentially not protected under the SAFE Act.  SAFE Act information disclosure is currently being tested through multiple State Freedom of Information Act (FOIA) requests and potential litigation based on the decisions of multiple States.  This has also raised questions about how information shared among States potentially outside of the protections of the SAFE Act would be protected (for example CSBS, SRR and CSBSEF Board materials).  A task force of a select group of State attorneys, outside counsel and staff was formed to examine the issues and determine the best ways to protect information shared among the States to the greatest extent possible.  

Validating the 50-State Survey of Information Sharing Laws and Exemptions 

Over the past year the Task Force, with the help of outside counsel, drafted a 50-state survey of information sharing laws and exemptions. These laws and exemptions were then broken down by industry: Banking, Consumer Finance, Money Service Business, and Mortgage. Below you will find the maps based on industry. In addition, a ranking of state non-disclosure laws, from weakest to strongest, was added to distinguish the states from each other. 

Validation of this data is a critical piece in this project. Each state should review their information provided on all four maps below and provide feedback in the tab titled, “Provide Feedback Here”.  

Please contact Emily Matson or Buz Gorman with any questions or for more information on how to use the maps. 

Access the Full Survey Data Here.
 

1129 20th Street, N.W., 9th Floor, Washington, DC 20036 | Tel. 202.296.2840 | Fax. 202.296.1928

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