Dear Sir or Madam,

The American Bankers Association(ABA)^[1] and Bank Policy Institute (BPI)^[2] respectfully request that the Federal Deposit Insurance Corporation (FDIC) extend the comment deadline for its Notice of Proposed Rulemaking regarding Disclosure of Information to October 5, 2026, which is the current comment deadline for the Office of the Comptroller of the Currency's (OCC) substantially similar proposal concerning confidential supervisory information.

The federal banking agencies have long sought to maintain broadly consistent approaches to the treatment and disclosure of confidential supervisory information. Such consistency is critically important because many banking organizations interact with multiple federal banking agencies, maintain affiliates subject to different supervisory frameworks, and routinely manage information that may be subject to the confidentiality requirements of more than one regulator. Divergent requirements can increase operational complexity, create uncertainty regarding permissible disclosures, and impede efficient information sharing.

Because the OCC recently issued a proposal addressing many of the same issues, the industry would benefit from additional time to evaluate the two proposals together. Allowing stakeholders to compare the FDIC and OCC approaches side by side would facilitate more comprehensive feedback regarding areas of alignment, divergence, and opportunities for harmonization. A common comment deadline would help ensure that commenters can provide more informed recommendations regarding how the agencies can achieve their shared objectives while maintaining a consistent and workable regulatory framework.

ABA and BPI appreciate the FDIC's consideration of this request and respectfully urge the agency to extend the comment period to October 5, 2026. If you have any questions, please contact the undersigned at [email protected] and [email protected].

[1] The American Bankers Association is the voice of the nation's $26.1 trillion banking industry, which is composed of small, regional and large banks that together employ over 2 million people, safeguard $20.5 trillion in deposits and extend $13.7 trillion in loans.

[2] The Bank Policy Institute is a nonpartisan public policy, research, and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.