We assist financial institutions (including companies that are surprised to learn that they are financial institutions covered by the Gramm-Leach-Bliley Act [GLBA]) in reaching a determination as to coverage and in drafting of policies, procedures, and notices, as well as in addressing ongoing compliance issues. We have worked with traditional and nontraditional companies (e.g., casinos, electronic commerce firms, universities) in drafting policies, notices, and procedures; coordinating corporate strategies; reviewing and drafting contracts with third parties; and dealing with a variety of novel compliance issues generated by GLBA. States and perhaps Congress are expected to expand upon GLBA by passing stricter provisions, including restrictions on affiliate use of customer information.