Comment Letter on Proposed Rules to Implement the Freedom of Information Act

May 27, 2011

From: MFA, Richard Baker


The Honorable Timothy F. Geithner,
Financial Stability and Oversight Council

MFA submitted a letter to the Financial Stability Oversight Council in response to the Councils proposed rules to implement the requirements of the Freedom of Information Act. In our letter, we discussed the Councils responsibility to facilitate information sharing among agencies, noting the importance of information sharing to avoid multiple regulators imposing unnecessarily duplicative or inconsistent regulations to get direct access to information that already is being reported to regulators. We also encouraged the Council to defer FOIA decisions regarding information received from other agencies to the originating agency, as the originating agency is likely to be in the best position to determine whether the information should be disclosed. Finally, we encouraged the Council to work with member agencies to promote a consistent approach to the treatment of information shared by the Council with member agencies.