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You friend from college has just started a retirement consulting business. He solicits customers on the internet. To initiate a consulting relationship, prospective clients submit

You friend from college has just started a retirement consulting business. He solicits customers on the internet. To initiate a consulting relationship, prospective clients submit online forms, which your friend then reviews. These forms contain financial information as well as personal identification information. He is considering selling this personal data, without financial information, to internet marketers, and he has asked you whether such a sale would raise GLB Act concerns. If so, he wonders if he could simply sell redacted information to internet marketers. Please provide your friend with the advice he needs.

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