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The Button is Back – California AG Issues Fourth Set of Proposed Mods to CCPA Regs

CCPAOn Dec. 10, the California Office of the Attorney General issued its Fourth Set of Proposed Modifications to the California Consumer Privacy Act regulations.  The changes affect only two subsections relating to the sale of personal information.

Section 999.306(b)(3) would clarify that a business that operates offline and sells consumers’ personal information must provide a notice of opt-out.  This is a sensible proposal since the current rule applies the requirement to businesses that “collect” rather than “sell” personal information. 

Section 999.306(f) would reinstitute guidance on the use of a uniform opt-out button consumers may use to opt-out of the sale of their personal information.  Similar guidance was contained in the first set of proposed modifications but was omitted in second and third sets and in the final rule. 

The deadline for written comments on the proposed modifications is Dec. 28, 2020.


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

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