On January 27, 2015, the CFPB issued Bulletin 2015-01 as a reminder that, with limited exceptions, persons in possession of confidential supervisory information (CSI) are prohibited from disclosing CSI to third parties. To view and/or print the bulletin in full, click this hyperlink. Below is a redaction of the main points of the bulletin: 1. The CFPB has issued regulations that govern the use and disclosure of CSI, which are contained in 12 CFR part 1070, and expects all supervised financial institutions and other persons that may come into possession of CSI to understand what constitutes CSI and to know and comply with these regulations. 2. Supervised financial institutions are those persons that are or that may become subject to CFPB supervisory authority – e.g., (i) depository institutions and credit unions with assets over $10 billion, and their affiliates; (ii) nonbanks, such as mortgage lenders, brokers, and servicers, and (iii) service providers – i.e., anybody that provides a material service to any of the above persons in connection with that person’s offering or providing of a consumer financial product or service.
