It is getting interesting : Swiss Category 2 Banks Push Back on DOJ's Draft NPA Agreement

From  Kristen A. Parillo, Swiss Banks Slam DOJ's Proposed Non-Prosecution Agreement, 2014 TNT 206-1 (10/24/14) or http://online.wsj.com/articles/swiss-banks-want-changes-in-justice-dept-hidden-account-program-1414085166 . The requested changes included limiting what the DOJ could do with the information it collected and dropping a requirement that banks also agree to disclose similar information to other foreign authorities. The pushback occurred in a letter from a number of attorneys representing the banks to the DOJ tax.  According to the reports,  28 lawyers representing 73 Swiss banks signed the letter.
According to the Parillo article, the draft NPA requires the Category 2 banks to :

• cooperate fully with the DOJ, the IRS, and any other domestic or foreign law enforcement agency designated by the DOJ regarding all matters related to the conduct described in the NPA;
• assist the DOJ or any designated domestic or foreign law enforcement agency in any investigation, prosecution, or civil proceeding arising out of or related to the conduct covered by the NPA;
• provide testimony as needed to enable the U.S. to use the information and evidence provided by the bank under the NPA; and
• provide the DOJ, upon its request, all information, documents, records, or other tangible evidence not protected by legal privilege or work product regarding matters arising out of or related to the covered conduct.
  The draft NPA also requires the banks to assist the U.S. with the drafting of treaty requests seeking U.S. account information (whether the account is open or closed), and to retain all records relating to its U.S. cross-border business for a period of 10 years from the NPA's termination date. The agreement also describes the circumstances under which the DOJ may determine that a bank has violated the terms of the NPA and may be prosecuted.

http://taxcontroversywatch.com/2014/10/24/swiss-banks-pushing-back-on-scope-of-agreement-with-u-s-under-amnesty-program/