BPI Comments on Proposed Revisions to Proposed California Consumer Privacy Act Regulations

On February 25, BPI filed a comment letter with the California Attorney General’s Office (AG), in response to their proposed revisions to the California Consumer Privacy Act regulations. BPI supports many of the proposed revisions but raised concerns with the AG’s requirement that businesses annually publish several metrics about consumer requests received under the CCPA as well as their responses. This and other regulatory expectations and changes in the proposed revisions could increase fraud and other risks to businesses. BPI also reiterated its previous recommendation to the AG that the effective date of the regulations should be set at least six months after the final rules are published and that the Attorney General should not undertake enforcement actions for conduct that occurs before January 1, 2021.