Therefore, GLBA could be seen as a customer retention asset if the institution aggressively works to cross-sell a number of services at the beginning of a new customer relationship.
In the wake of the financial crisis and concerns about the role of new and controversial products contributing to the crisis, GLBA has attracted its share of criticism.
Analysts such as Peter Wallison, who testified before the Senate Banking Committee in May 2009, have noted that GLBA has helped to insulate investors from larger losses.
He then ruled the GLBA gives OCC "implicit interpretive authority" to determine if provisions in the state's law "are disruptive to bank operations, increase bank operating costs, and substantively affect a bank's ability to solicit and sell insurance products.
Although OCC was "entitled to some deference" under the GLBA, he found the GLBA "does not provide guidance as to what level of deference is appropriate" and determined OCC's interpretations were entitled to respect to the extent they met the standard for persuasiveness outlined by the Supreme Court in Skidmore v.
King disagreed with Gregory that OCC has authority to act unilaterally in interpreting or implementing GLBA.
The GLBA reaffirms the McCarranFerguson Act, which recognizes the legal authority of the state to regulate insurance activities.
In addition to the revised regulatory regime, the GLBA amended existing law concerning the Community Reinvestment Act.
Furthermore, the FTC promulgated safeguard rules that require a financial institution, which, again, could be anyone offering financial services, to oversee the third-party provider's use of the information and ensure compliance with GLBA
As such, we needed a vendor with a comprehensive understanding of GLBA
regulatory requirements that reached beyond the standard technology-based approach.
All packages include a GLBA compliance review that incorporates both internal and external vulnerability assessments, prioritized recommendations regarding compliance, and information on how to fix network vulnerabilities.
This combination of products and services provides ICBA member banks with a complete blueprint for achieving and maintaining GLBA compliance.