The Financial Services Modernization Act 1999, usually called the Gramm-Leach-Bliley Act (‘GLBA’) after its sponsors, covers all US-regulated financial services corporations. It applies to
banks, securities firms and insurance companies,
lending, brokering or servicing any type of consumer loan,
transferring or safeguarding money,
preparing individual tax returns,
providing financial advice or credit counselling,
providing residential real estate settlement services,
collecting consumer debts, and
an array of other activities.
The GLBA charges the boards of these entities with protecting their customers’ personal information against any ‘reasonably foreseeable’ threats to its security, confidentiality or integrity. The GLBA also applies to a wide...