NAFCU’s Comments to CFPB on Privileged Information

April 13, 2012

Consumer Financial Protection Bureau
Monica Jackson
Office of the Executive Secretary
1700 G Street NW
Washington, DC 20552

RE: Docket No. CFPB-2012-0010; Treatment of Privileged Information

Dear Ms. Jackson:

On behalf of the National Association of Federal Credit Unions (NAFCU), the only trade association that exclusively represents federal credit unions, I am writing to you regarding the Consumer Financial Protection Bureau’s (CFPB) request for comment on its proposed rule on the treatment of privileged information.  NAFCU supports the proposed rule.
It is critical that the agency finalize the proposal as soon as possible in order to ensure the confidential treatment of information disclosed during the examination process.  As the CFPB is aware, the other federal banking agencies provide protection to information disclosed during the examination and supervision process.  Failure on the part of the CFPB to provide similar protection could lead to the disclosure of sensitive information that could cause litigation and safety and soundness concerns for credit unions.  Further, as the law currently stands, covered entities may be understandably leery of providing some information to the CFPB; this situation benefits no one.  Providing clarity on this important issue will ensure the rights of financial institutions while also allowing the CFPB to better do its job.
While NAFCU supports the proposed rule, we are hopeful the CFPB will continue to work with Congress to pass legislation that codifies these protections.  While this proposed rule is certainly helpful, NAFCU still supports these protections being written into law.
NAFCU appreciates the opportunity to comment on this important issue.  Should you have any questions or concerns, please feel free to contact me at 703-842-2212.


Dillon Shea
Regulatory Affairs Counsel

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