I may be interpreting the memo harshly but until today this policy has been private.
This bulletin makes public Chief National Bank Examiner (CNBE) Policy Guidance 2010-2 (REV), “Policy Interpretation: OCC Bulletin 2000-20—Application to Private Student Lending,” which was issued to OCC employees only on August 4, 2010. In making this guidance public today, the OCC made minor formatting and typographical adjustments.