do Banks, Insurance companies, Brokerages, plastic surgeons,
and travel agencies have in common?
the privacy rules imposed as part of the Financial Services
Modernization Act (a/k/a the Gramm-Leach-Bliley Act, or
"GLB") financial institutions are restricted
in their ability to use and disclose personal financial
information of consumers. Financial institutions must
and provide 'opt-out' procedures to each consumer with
whom it has a continuing relationship.
you're not a bank, so you're immune from GLB compliance,
right? Guess again. The privacy provisions of GLB can
apply to any company engaged in financial services --
whether or not you are affiliated with a bank. Finance
companies, insurance agencies, medical offices, securities
dealers, even travel agencies and law firms can find themselves
covered under GLB's broad definitions.
GLB compliance efforts evolve, they are shaped by various
rulings and enforcement actions undertaken by the US Department
of the Treasury, the Federal Reserve, the OCC, the FDIC,
the OTS, the SEC, the NCUA, and the FTC. Some issues remain,
including the meaning of things like what is a "continuing
relationship," what constitutes sufficent notice,
what form and manner must the opt-out take, and more.
And some of those issues have already been answered in
ways that raise more questions.
can help you assess whether, and to what extent, GLB applies
to you. Our consultants can help you design a privacy
policy and opt-out process that complies with GLB. If
needed, our strategic partnerships with several software
and hardware providers and technology implementation firms
can help you implement scalable, reasonably priced opt-out
processing, tracking, and auditing systems -- and get
them in place fast.
offers short- and long-term engagements at hourly or fixed-rates
for every budget. We can help you stay GLB compliant at
a fraction of the cost of responding to a Federal Trade