At its core, the AFC’s position is that the existing CSI framework creates friction at exactly the wrong moment in a bank-fintech relationship: before a formal partnership is established. Under current rules, institutions examining prospective partners, senior hires or acquisition targets face constraints that limit what supervisory context can be shared and with whom. The AFC argues that this effectively forces parties into a roundabout information-exchange process it describes as “playing a game of telephone,” increasing due diligence risk rather than reducing it.

The council is pressing both agencies on three related fronts. First, it wants the business-purpose disclosure authority that already permits some CSI sharing to be extended across the full life cycle of third-party relationships, including during initial pre-contractual due diligence. This would allow FDIC-examined service providers to disclose information about their own supervisory standing to prospective bank partners, enabling informed risk assessments before any contract is signed.

Second, in its OCC submission, the AFC specifically calls for CSI sharing to be permitted during merger and acquisition evaluations and during pre-engagement assessments of senior leadership candidates, covering a range of corporate events where supervisory history is directly material to decision-making.

Third, the AFC advocates for a structured route through which qualifying entities, including trade associations and independent research organisations, could receive institution-specific CSI solely to conduct aggregated analysis. The resulting aggregated findings would be publishable, supporting regulatory research and policy advocacy without exposing individual institution data.

On compliance safeguards, the AFC argues that protecting sensitive supervisory data does not require recreating the prior-approval burdens present in earlier frameworks.

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