• In today’s cloud-first digital environment, financial institutions need to adapt modern compliance tools.
• Confidential Supervisory Rules should be your cornerstone for choosing the best data loss prevention solution for your needs.
• Modern DLP solutions enable compliance by helping institutions safeguard trust, mitigate risk, and stay ahead of evolving regulatory requirements. 

With the Federal Financial Institutions Examination Council (FFIEC) sunsetting its Cybersecurity Assessment Tool (CAT) earlier this year, you could say the industry is going through changes. 

In the face of digital transformation, the retirement of CAT is a picture of how legacy frameworks are giving way to modern architectures. As the way we assess and share data continues to evolve, so do the challenges of protecting it.

Staying up to code

For regulators, this protection centers on Confidential Supervisory Information (CSI) rules designed to safeguard sensitive, non-public information related to the supervision of financial institutions. 

Enforced by regulatory agencies such as the Federal Reserve and the Consumer Financial Protection Bureau (CFPB), these rules ensure critical supervisory data is protected to maintain the integrity of financial systems and prevent misuse. 

While the CSI rules protecting data types haven’t changed much in recent years, applying them in a cloud-first, collaboration-driven environment is more complex than ever before. Protecting modern data requires a modern approach.

Through the lens of the data types protected under CSI rules, as defined by 12 CFR Part 261 (Federal Reserve) and 12 CFR § 1070.42 (CFPB), let’s take a look at how the best Data Loss Prevention (DLP) solutions provide robust tools to help financial institutions achieve and maintain compliance. 

Data types protected under CSI rules

CSI encompasses a range of sensitive data types generated or obtained during supervisory, investigatory, or enforcement activities that are required to be protected under CSI regulations:

• Reports of Examination, Inspection, and Visitation: Detailed evaluations of a financial institution’s operations, compliance, and risk management practices.
• Supervisory Ratings: Confidential assessments, such as CAMELS ratings, assigned by regulators to reflect an institution’s financial health and stability.
• Confidential Operating and Condition Reports: Internal documents detailing an institution’s performance and operational status.
• Supervisory Correspondence: Communications between regulators and financial institutions—including emails, letters, or memos related to supervisory activities.
• Investigative Requests: Documents or information requests tied to regulatory investigations or enforcement actions.

These data types, often sandwiched in internal reports or legal documents, demand strict safeguards to prevent unauthorized disclosure. If leaked, they could undermine regulatory oversight, harm financial institutions, or expose sensitive operational details. 

How modern DLP helps comply with CSI rules

Top-tier DLP solutions enable financial institutions to monitor, detect, and prevent unauthorized disclosure of sensitive information. By leveraging advanced detection technologies and policy enforcement mechanisms, they ensure CSI data is protected in alignment with regulatory requirements.

Specific CSI regulations your DLP solution needs to meet include:

1. Data Identification and Classification

CSI data can exist in numerous narrative document types and is frequently conversational in tone.  This can be a challenge for DLP systems that only use pattern recognition. You need advanced detection capabilities that can cover more than just standard regex and keywords. 

• Indexed Document Matching (IDM): IDM allows organizations to create an index of past or current CSI documents, enabling precise detection of sensitive content. Governance, Risk, and Compliance (GRC) or Legal (GRC/L) teams can gather relevant documents and set detection thresholds based on the likelihood of text matches. This flexibility guarantees that even referenced or partial text is identified, reducing the risk of oversight.
• Form Recognition: For CSI data contained within standardized forms, top-tier systems can index blank forms and create recognition profiles. This enables the detection of "filled-out" forms while avoiding false positives on blank forms—ensuring accurate identification of sensitive content.
• Vector Machine Learning (VML): For institutions with significant historical CSI data, VML is a powerful machine learning tool that adapts to evolving data patterns. Implementation involves defining topics from previous CSI documents, creating keyword lists from document titles, and establishing form-based policies within a content set. Positive and negative data sets are created in secure directories, and ready-response rules move detected files to these directories for training a VML profile. This approach enhances detection accuracy and adaptability.

Additionally, if your institution uses document classification systems like Microsoft Purview Information Information Protection (MPIP), leading solutions can often support the integration of custom tags (e.g., "Highly Sensitive") into DLP rules, further refining the identification of CSI data.

2. Monitoring and Policy Enforcement

DLP solutions need to continuously monitor data flow across multiple channels—spanning email, web, cloud storage, and endpoints to detect potential CSI policy violations. CSI is often restricted even amongst internal corporate teams. “Need to know” basis is something your DLP system can help enforce.  Key enforcement features of compliant solutions include:

• Sender and Recipient Patterns: DLP can define patterns for specific departments handling CSI data, creating automatic exemptions to avoid interrupting legitimate internal exchanges. For example, DLP detects CSI documents and allows their transmission within designated teams while blocking or restricting sharing with external entities unless explicitly authorized.
• Encryption Integration: For allowed external recipients, DLP integrates with encryption solutions to ensure that CSI data is securely transmitted, aligning with the controlled disclosure requirements of 12 CFR Part 261 and 12 CFR § 1070.42.
• Internal Share and Cloud Monitoring: DLP scans internal file shares to identify and quarantine CSI data stored in inappropriate locations. Integration with CASB enables scanning of hosted share sites such as Box, Dropbox, and Office 365 to prevent external sharing of CSI data from cloud storage.

These capabilities ensure that CSI data remains confidential and is only accessed or shared in accordance with regulatory guidelines.

3. Auditing and Reporting

Auditing and reporting are critical components of CSI compliance. Premier DLP solutions support these requirements by:

• Generate detailed compliance reports that track how CSI data is handled within the organization.
• Offering customized audit reports through DLP API integrations, allowing institutions to tailor reporting to specific regulatory needs.
• Restricting access to CSI-related incidents by creating unique policy groups. This ensures that only trusted GRC/L staff can view or manage incidents, protecting the highly sensitive nature of CSI data from unauthorized internal responders.

These features provide auditable evidence of compliance, which is essential for regulatory reviews and avoiding penalties.

4. Risk Mitigation

By proactively detecting and preventing unauthorized disclosures, a well-tuned DLP solution minimizes your risk of CSI breaches. Their ability to block improper transfers, enforce encryption, and quarantine misplaced data helps reduce the likelihood of noncompliance—and the headache of fines, reputational damage, or legal consequences that could follow. Because these solutions are adaptable and built with evolving detection capabilities, they can keep pace with changing data patterns and maintain robust protection over time. 

Best practices in action for financial institutions

Maximize the effectiveness of your DLP for CSI compliance by:

1. Collaborating with GRC/L Teams: Gather historical and current CSI documents to build IDM and form recognition profiles, and leverage VML for advanced detection if sufficient data is available.
2. Define Clear Policies: Create a dedicated CSI Policy Group to restrict incident access to authorized personnel, ensuring sensitive data is handled discreetly.
3. Integrate with Existing Systems: Combine DLP with encryption, document classification, and cloud security tools like CASB for a more comprehensive compliance framework.
4. Regularly Review and Update: Continuously refine detection thresholds, keyword lists, and VML training sets to adapt to new CSI data patterns and regulatory updates.

Now make it stronger and streamline compliance

One of the most acclaimed DLP solutions comes from Symantec—trusted by financial institutions worldwide to protect sensitive data wherever it lives or goes. Legendary in its staying power, Symantec delivers CSI-compliant capabilities that help FinServ institutions stay resilient and regulation-ready, even as rules shift in the era of digital transformation. 

Discover how Symantec DLP builds resilience, extensibility, and speed into every layer in this interview with a DLP expert.