Legal Seminar

then provide less confidentiality than is provided under Connecticut law and disclosure of the requested information would be prohibited by Section 1512(c). Here again, since section 1512(c) would prohibit the disclosure of the requested information, the requested information would also be exempt from disclosure under Section (7)(1)(a) of the Illinois FOIA. In conclusion, it is the opinion of CSBS that disclosure of the requested information is prohibited under the SAFE Act, and by extension is exempt from disclosure under the Illinois FOIA, because the information is subject to the confidentiality protections of the SAFE Act as information shared with NMLS. Moreover, the SAFE Act may preempt the Illinois FOIA to the extent the requested information includes information provided by another state that provides stronger privilege or more confidentiality protections than the Illinois FOIA.

Sincerely,

John Gorman General Counsel Conference of State Bank Supervisors