Not to Be Indelicate, but …

When President Clinton signed the Gramm-Leach-Bliley Act in 1999 — requiring financial institutions to protect the security, integrity and confidentiality of consumer information — fundraisers scratched their heads, wondering what, precisely, constitutes a “financial institution.” The Federal Trade Commission noted in its analysis that “nothing in the definition of a ‘financial institution’ excludes nonprofit entities,” opening the floodgates for subjective interpretation as to whether a charity is “substantially engaged in activities ... financial in nature.”