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A GLBA Comment Period Deep Dive for Credit Unions

Over the past 26 years, both technology and the financial landscape have evolved dramatically. On July 31, 2025, the U.S. House Financial Services Committee requested public feedback on issues that could shape the first major update to financial privacy laws in more than two decades. The inquiry centers on the Gramm-Leach-Bliley Act (GLBA).

As digital banking, data sharing, and artificial intelligence reshape how financial institutions interact with consumers, lawmakers are reassessing whether the GLBA’s framework for safeguarding personal information remains adequate in today’s environment.

In order to determine the next steps when it comes to possible reform, Congressional leaders had interested members of the public send their comments related to a list of questions.  Below are just a few that were asked for public opinion.

Should we amend the Gramm-Leach-Bliley Act (GLBA) or consider a broader approach?

Revising the GLBA is a step in the right direction, but it may not go far enough. A comprehensive federal privacy law could join protections across industries and states, creating consistency nationwide. Lawmakers have yet to achieve this goal, despite years of proposals and debate.

Should we consider a preemptive federal GLBA standard or maintain the current GLBA federal floor approach?

The main sticking point is whether a federal law should override state privacy laws. A single national standard could make things simpler for businesses and more consistent for consumers. However, it could also weaken the stronger privacy protections that many states already have. Reducing consumer privacy rights seems unwise at a time when new technologies are raising more concerns about how personal data is used.

If GLBA is made a preemptive federal standard, how should it address state laws that only provide for a data-level exemption from their general consumer data privacy laws?

Expanding what counts as “personal financial information” to include digital details — like someone’s IP address, location, or online activity — would better protect consumers and bring the GLBA up to modern times. This would also reduce the need for states to step in with their own privacy laws.

How should GLBA relate to other federal consumer data privacy laws, both a potential general data privacy law and current sector-specific laws?

Revising these terms to match how people use financial services today would make the law apply fairly to both credit unions and newer fintech companies. It would also strengthen privacy by giving the same protection to all kinds of personal data.

How should we define “non-public personal information” within the context of privacy regulations? 

With fintech apps and data aggregators now handling more sensitive financial information, including them under GLBA’s Title V would help cover gaps in the law and ensure all companies protect consumer data consistently.

Comments were due to the U.S. House Financial Services Committee by August 28, 2025.  To see the whole list of questions presented, check out the news article.

Keep an eye out for possible updates in the future.

Have questions or want to know more? Contact ViClarity’s compliance services team at compliancesupport@viclarityus.com.

(Authored by ViClarity)

For More Information

For more information, email Heather Line.

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