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Application of Gramm-Leach-Bliley to 403(b) Plans


Guest David Kolhoff

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Guest David Kolhoff

Has anyone seen an analysis of the application of Gramm-Leach-Bliley ("GLB") to 403(B) plans. In brief, GLB requires protection of "consumer's" and "customer's" "nonpublic personal information." These are all defined terms found in GLB and in several different sets of regulations from various regulators.

I've seen a single short article that concludes, without analysis, that participants in qualified plans are not consumers under GLB. I've not seen any specific mention of 403(B) plans and would be interested in any articles or comments. Thanks.

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