The Office of the Comptroller of the Currency's recent proposal to overhaul its supervisory information sharing regime for the first time in decades would provide important flexibility to banks, but it could create new issues around confidentiality agreements, disclosure controls and diligence processes, say attorneys at Simpson Thacher.
By Lee Meyerson and Amanda Allexon ( October 19, 2026, 3:25 PM EDT) -- On Aug. 3, the Office of the Comptroller of the Currency issued a proposal that would substantially expand the circumstances in which national banks may share confidential supervisory information, or CSI, with affiliates, service providers, executive candidates, merger counterparties, trade associations and certain advisers without seeking case-by-case OCC approval.[1]...
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