April 2, 2012
The 2010 Dodd-Frank Act did not explicitly address the confidential treatment of privileged information provided to the Consumer Financial Protection Bureau (Bureau) but did grant the Bureau the ability to promulgate rules addressing this important issue. The Bureau has now proposed a Rule that would codify protections for privileged information submitted to it by the financial institutions it regulates.
In a comment letter CBAI supported the confidential treatment of privileged information provided to the Bureau. CBAI also encouraged the Bureau eliminate any ambiguity or confusion in the Rule and protect all information provided to the CFPB from institutions the Bureau directly supervises (those with assets in excess of $10 billion) and community banks with assets of $10 billion and under.