ICBA sent comments to the OCC on its proposal to revise its rules governing the disclosure of non-public OCC information, including confidential supervisory information. ICBA commended the OCC for this modernization of its information disclosure rules and said it generally supports the proposal but recommended that OCC mirror FDIC proposed regulations, such as explicit language for service provider consent and adding the FDIC’s service-provider-to-bank pathway, including for prospective partners.