OCC loosens CSI disclosure rules

The Office of the Comptroller of the Currency, or OCC, published in August 2026 a proposal for a new framework on the disclosure of confidential supervisory information, or CSI, aligned with the FDIC proposal. The change would relax the current preapproval regime for sharing CSI with affiliates, service providers and counterparties in corporate transactions.

What changes in CSI disclosure?

The proposal would replace a stricter preauthorization model with a more flexible one for certain transfers of confidential supervisory information. According to the research material, the aim is to allow banks and other supervised entities to share CSI with affiliates, service providers and counterparties in corporate transactions under a less restrictive framework than the one now in place.

That regulatory shift comes as the OCC already operates under a published enforcement framework that can apply to national banks, federal savings associations and their subsidiaries. Available tools include cease-and-desist orders, civil money penalties and other administrative sanctions.

What other compliance standards remain in place?

Regulation S-P, issued by the SEC under the authority of the Gramm-Leach-Bliley Act, continues to impose confidentiality and security requirements for customer information at broker-dealers, investment advisers and investment companies. That regime complements the information security standards that banking regulators issue under GLBA.

At the same time, the research material also identifies the OCC as a regulator with concrete sanctioning authority over entities within its scope. Its enforcement framework covers national banks, federal savings associations and their subsidiaries, with measures ranging from corrective orders to civil money penalties.

For financial groups with a presence in Latin America, the overlap between these rules matters because the same corporate structure can face different requirements depending on the type of entity and the authority supervising it. The OCC's proposal on CSI, the SEC's Reg. S-P and the agency's enforcement powers are direct reference points for banks and holding companies with operations in Argentina and Mexico.