Which of the following would qualify as affiliates under the GLBA?

Affiliates under the Gramm-Leach-Bliley Act (GLBA) are defined primarily in the context of companies that are under common control. When we refer to companies controlled by a common owner, we are considering entities that share a relationship through ownership. This means that if one company has the power to direct or control the policies of another, they are considered affiliates.

The GLBA addresses the sharing and protection of non-public personal information (NPI) among financial institutions and their affiliates, which allows for certain data-sharing practices. This is significant because it emphasizes the importance of how ownership impacts the relationships between various businesses in the financial sector.

In contrast, separate corporate entities, independent service providers, and non-profit organizations typically do not qualify as affiliates unless they are linked through common ownership. Separate corporate entities could operate independently, independent service providers are usually contracted out and operate without ownership ties, and non-profit organizations, while they may work with financial institutions, do not automatically meet the affiliate criteria unless they are owned or controlled by the same entity. Thus, the correct identification of affiliates under GLBA focuses on the concept of common ownership.