CPPA CPRA Regulations Comment Letter
On Tuesday, CBA submitted its comment letter to the California Privacy Protection Agency on the proposed rulemaking on regulations implementing the California Privacy Protection Act of 2020. Among other comments, CBA raised concerns in areas where the proposed regulations go beyond, or conflict with, the statute, such as the requirement that businesses honor universal opt-out preference signals. We urged that the Agency avoid new requirements that create an undue burden on businesses subject to the law or that impose new liability, particularly where there is no corresponding consumer benefit. CBA also requested that the regulations become enforceable one year after the date that the regulations are finalized.