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California AG Issues Final Text of California Consumer Privacy Act Regulations

CCPA California Consumer Privacy Act webinar
REGISTER: Maurice Wutscher Webinar June 30 “CCPA Enforcement Is Almost Upon Us! Are You Ready?” Learn how to prepare and comply.

On June 1, the Office of the California Attorney General filed its proposed Final Text of Regulations relating to the California Consumer Privacy Act (CCPA) with the California Office of Administrative Law.  

The regulations are identical to the Second Modified Regulations issued by the attorney general on March 11. Any changes would have required an additional notice and comment period.

Pursuant to the California Administrative Procedure Act, the OAL has 30 days to review the attorney general’s documents to ensure compliance with rulemaking standards.  This means the regulations could become effective and enforceable by July 1, 2020, the deadline set forth in the CCPA.  The attorney general notes, however, that the 30-day review period could be extended an additional 60 days pursuant to the COVID-19 Executive Order N-40-20 issued by Gov. Gavin Newsom on March 30.

The attorney general’s website contains an impressive amount of information relating to its CCPA rulemaking process, including:

  • the reasons for each modification made since the original proposed regulation;
  • its responses to comments submitted, with cross references to the specific parties that submitted the comments; and
  • transcripts from the four public hearings.

The CCPA became effective on Jan. 1, 2020, and the filing of the regulations marks the near end to what has been an eight-month rulemaking process.  It is anticipated the OAL will approve the regulations, so businesses subject to the CCPA should follow through with final updates to their CCPA policies and procedures. The attorney general can seek civil penalties up $2,500 for each non-intentional violation and up to $7,500 for each intentional violation.

WEBINAR

Now is the time to fine-tune your CCPA compliance. Join me to learn how to get your business ready to comply with the CCPA during “CCPA Enforcement Is Almost Upon Us! Are You Ready?” Click here to register.

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Eric Rosenkoetter is a principal at Maurice Wutscher LLP, where he provides counsel to businesses and consumer financial services firms nationwide. For many years, he has focused his practice on various aspects of financial services law. As a litigation attorney, he has conducted every aspect of the litigation process, including countless depositions, motion proceedings, bench and jury trials, and appeals in various courts. In addition, he has significant experience as a compliance and transactional attorney, providing strategic, business growth, legislative, compliance and regulatory advice to national corporations and trade associations. For example, he has drafted consumer contracts and disclosures designed to state-specific statutory requirements, and developed “Best Practices” guides and state-by-state compliance grids, for national financial services companies. He also conducted research and crafted a metrics report for a national trade association with analysis designed to counter the claims of advocacy groups. Eric’s experience also includes working for a national corporation as Executive Counsel, Chief Compliance and Ethics Officer, and Director of Legislative Affairs, and as a federal lobbyist and Director of Government and Public Affairs for a national financial services trade association. In the government sector, Eric presided over approximately 6,000 state administrative hearings, served as a staff attorney for the Missouri Senate, and handled litigation in 33 counties as a regional managing attorney. Eric frequently speaks to audiences on topics relevant to the financial services industry including regulatory compliance, data privacy law and related advocacy initiatives. For more information, see https://mauricewutscher.com/attorneys/eric-rosenkoetter/

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