Another route to engaging in nonbanking or nonfinancial activity--and the focus of this Note--is under Section 4(o) of the GLBA
, the Grandfather Provision.
While the EFTA and TILA are good resources to start creating more protections for consumers using mobile payments, the GLBA
should also be used to establish privacy and data security provisions from mobile payment companies.
(60) See McTaggart & Freese, supra note 9, at 495 (noting that Congress, the Federal Reserve Board, nor the courts have made explicit the GLBA
application to mobile payment systems).
Further, a section of the GLBA
erected new barriers to the ability of a nonfinancial firm to own a depository institution.
and soundness of the depository." (25) The GLBA
was not the first legislation to repeal portions of the Glass-Steagall Act.
The volatility Equations (2), (4), and (6) include ARCH and GARCH factors, risk spillover factors across different insurer categories, and a binary variable for the passage of the GLBA
, also known as the Financial Services Modernization Act.
Title V of GLBA
focuses on requirements of financial institutions with regard to protecting consumer privacy.
"Certainly the Sarbanes-Oxley Act, GLBA
, and changes in the FRCP alerted companies to develop better internal controls to guard privacy and prevent and detect fraud," said Gary Corcoran, systems manager at Central Insurance.
Prior to October 13, 2006, GLBA
required accountants to provide annual notices to clients regarding their privacy policies.
The regulators encourage institutions to provide the notice in conjunction with other disclosures including the annual GLBA
privacy notice (where most institutions already include the FCRA information sharing notice).
The means and opportunities to do harm to consumers via identity theft have also increased in number and effectiveness, so many that analysts and congressmen alike believe it's time to update the granddaddy of data security laws, the Gramm-Leach-Bliley Act (GLBA