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Gramm-Leach-Bliley Act

Posted in Compliances (1300) by Guest on the September 29th, 2011

President Clinton signed the Gramm-Leach-Bliley Act (“Act”) into law November 12, 1999. The Act repeals the 66-year old Glass-Steagall Act, which prohibited banks, securities firms and insurance companies from affiliating. 

The following is a brief summary of the key provisions of interest to the securities industry.

Affiliation: The Act permits banks, securities firms, and insurance companies to affiliate within a new financial holding company (FHC”) structure. The Act prohibits non-financial companies from owning commercial banks.

Financial in Nature: The Act includes a broad definition of financial in nature’ and gives the Federal Reserve Board (“Board”) the authority to define additional activities as “financial in nature, or incidental or complementary to” financial activities.  Merchant banking is included in the definition of a financial activity.

Commercial Basket: The Act includes a grandfather provision for commercial activities which permits a securities firm that becomes a FHC to continue to engage in commercial activities in an amount not to exceed 15 percent of its consolidated annual gross revenues, excluding bank subsidiaries. The grandfather provision will expire ten years after date of enactment, unless extended by the Board for an additional five years. 

Privacy: The Act requires all financial institutions, regardless of whether they form an FHC, to disclose to customers their policies and practices for protecting the privacy of non-public personal information. The disclosure which customers would receive at the time of establishing the relationship and at least annually thereafter would allow customers to “opt-out” of information sharing arrangements to non-affiliated third-parties.  The Act permits financial institutions to share personal customer information with affiliates within the holding company. Effective immediately, it is a criminal offense for any person (including firm employees) to obtain or attempt to attain customer information relating to another person from any financial institution by making a false or fraudulent statement to an employee of that financial institution.  Regulators have six months after the date of enactment to adopt final rules implementing the privacy provisions.

Functional Regulation: All insurance, banking, and securities activities will be functionally regulated. The Act significantly narrows the broad exemptions from broker-dealer registration that banks currently enjoy today. Banks can, however, engage in the following types of securities activities without broker-dealer registration:

  • Third-party brokerage arrangements (arrangements pursuant to which registered broker-dealers offer securities on bank premises).  
  • Certain trust activities.  
  • Transactions in exempted securities (such as government securities). 
  • Transactions for certain stock purchase and employee benefit plans. 
  • Sweeping bank deposits into no-load, open-end money market funds. 
  • Transactions for some bank affiliates. 
  • Private placements of securities for banks that do not have securities affiliates (or have had such affiliates for no more than one year). 
  • Safekeeping and custody activities. 
  • Carrying broker activities. 
  • Municipal securities. 

Transactions in “identified banking products.” Identified banking products include bank accounts, banker’s acceptances, letters of credit, bank loans, certain loan participations, credit card debit accounts, credit and equity swaps sold to a qualified investor (other than equity swaps to retail customers), and other instruments as determined by the Securities and Exchange Commission (“SEC”), subject to challenge by the Board and other interested parties, and to court review and determination     

Other securities transactions not in excess of 500 transactions per year (de minimus exception).


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Sample Visio – Digital Imaging and Communications in Medicine – ISO Mapping

Posted in Compliances (1300),Security (1500),Visio Samples - Stencils (457) by Guest on the September 21st, 2011
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Holding Company Regulation (Fed-Lite Provisions)

Posted in Compliances (1300) by Guest on the September 15th, 2011

The Act limits the authority of the Board to regulate, examine, and require reports from functionally regulated subsidiaries, including registered broker-dealers, of FHCs. The Act establishes a streamlined supervisory system for regulating holding companies, notably:

  • The Board generally is prohibited from imposing capital requirements on functionally regulated holding company subsidiaries (broker-dealer) that are in compliance with applicable federal and state capital requirements. 
  • The Board can impose capital requirements on holding companies. 
  • The Board generally must defer to the functional regulator of a holding company subsidiary (broker-dealer) in connection with regulation and supervision of the subsidiary. 
  • The Board can require additional reports, and conduct additional examinations, only for purposes such as monitoring and controlling financial and operating risks and determining compliance with applicable laws. 
  • The Board cannot regulate functionally regulated subsidiaries of an FHC except in instances in which there is a material risk to an affiliated insured bank or to the payment system.  

Operating Subsidiaries: The Act permits well-capitalized and well-managed national banks, with a satisfactory or better Community Reinvestment Act rating, to conduct most financial activities through an operating subsidiary.  The aggregate consolidated total assets of all financial subsidiaries of the national bank cannot exceed 45 percent of the parent bank’s total consolidated assets, or $50 billion, whichever is greater. An operating subsidiary cannot engage in insurance underwriting, real estate development, merchant banking, or insurance company portfolio investing. 

Unitary Thrift Holding Companies: Commercial companies are prohibited from buying thrifts under the Act.  Existing commercial ownership of thrifts is protected through a “grandfather” provision for entities in existence or those who had applications pending on or before May 4, 1999.

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Sample Visio – Healthcare Conceptual Model

Posted in Compliances (1300),Visio Samples - Stencils (457) by Guest on the September 11th, 2011
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Sample Visio – Healthcare Imaging IT Market

Posted in Compliances (1300),Visio Samples - Stencils (457) by Guest on the September 6th, 2011
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Sample Visio – Digital Imaging & Communication in Medicine (DICOM)

Posted in Compliances (1300),Visio Samples - Stencils (457) by Guest on the September 3rd, 2011
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Sample Visio – Public Healthcare to Healthcare Systems

Posted in Compliances (1300),Visio Samples - Stencils (457) by Guest on the September 2nd, 2011
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Sample – Employee Values

Posted in Business (600) by Guest on the September 1st, 2011

Employees are evaluated annually based on adherence to these values:


  • Bold consistent vision. Deliver a compelling, shared vision that passes the “elevator test” of simplicity – and is consistently communicated to the rest of the world.
  • Focused. Understand our priorities, never get distracted, and systematically refresh our objectives.
  • Customer Satisfaction. Make each customer an E. Piphany evangelist. Only agree to what we can deliver and always deliver what we agree to.
  • Relentless. Always inspire ourselves, our coworkers, and our teams to a higher state of performance, speed, quality, completeness and, ultimately, competitiveness.
  • Respectful. Be professional in every interaction with employees, customers, and vendors. Treat them with the utmost respect, honestly, directness, and always follow through.
  • Extraordinary teamwork. Communicate with and count on every-one to play their part flawlessly, as you would expect them to count on you. Every person has a role on our team.
  • Accountable. Be willing to reap the rewards or accept the consequences of our commitments.
  • Intelligent. Out-think the competition. Constantly drive creative ideas. And work to bring the best ideas and practices to E. piphany.
  • Open, honest communications. Speak your mind for both good and bad. Demand the same from everyone we work with. Insist that bad news travel faster than good news.
  • Listen well, act quickly. Listen well, entertain the ideas of others (both inside and outside the company) and seek counsel. Then act decisively.


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