CUNA has several major concerns with a Consumer Financial Protection Bureau (CFPB) proposal regarding disclosure of records and information. Specifically, the proposal would make changes to regulations regarding confidential supervisory information (CSI), confidential investigative information (CII) and the Freedom of Information Act.
CUNA is concerned that, despite the stated intention to clarify, correct and amend certain provisions, the proposal appears to go well beyond this scope, and in some instances, beyond statutory authority.
“Information sharing is a critical component to ensuring the safety and soundness of financial institutions and their provision of financial services to consumers,” CUNA’s letter reads. “However, the vast expansion of information sharing contemplated by the proposal could increase the risk of unintended disclosures and a loss of confidentiality, which could ultimately harm consumers.”
CUNA’s area of greatest concern is changes to the subpart that deals with confidential information.
Highlights of the letter include:
For more information, see CUNA’s Removing Barriers Blog.