Chase Manhattan Corp.'s privacy settlement with New York State's Attorney General could provide a blueprint for addressing the issue of the use of customer data, but perhaps equally important was how it illustrated the way state government can work to tie up loose ends in federal law.

Almost immediately after passage of financial reform, experts predicted states would play a key role in developing rules for the financial industry. Chase's agreement not to share personal financial information anymore with non-affiliated marketing companies, a practice not barred under federal law, shows that in such areas, the states may well set the bar higher than Washington has.

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