Solid rock or sinking sand: Redefining banking through electronic activities under proposed Subpart E

Changes in business methods, technology and law are reshaping the financial services industry. The shifts are no longer incremental, but seismic. Congress recognized this by formulating the Gramm Leach Bliley Act, which permits financial holding companies to engage in business that is "financial in nature." Two years after GLB became law, the Office of the Comptroller of the Currency has reinforced the importance of this shift in thinking by proposing rules to define how the agency will determine what electronic activities are permissible activities for national banks.