California AG submits CCPA regulations for approval – requests expedited review ahead of July 1

On June 1, The California Attorney General (CA AG) submitted the final text of the CCPA regulations to the California Office of Administrative Law (OAL) for approval. Though regulations submitted to the OAL in June ordinarily would not become effective—if approved—until October 1, the CA AG has requested an expedited review. According to the CA AG, the expedited review would allow the regulations to become effective by July 1, which still is the date his office plans to begin enforcing the CCPA according to a public statement.

The final text is unchanged from the most recent draft published on March 11, which we previously summarized. The final text also is accompanied by a revised Statement of Reasons that explains the basis for the regulations and outlines textual changes from the initial draft regulations published on October 11, 2019.

Even though we do not yet know whether the OAL will approve the final CA AG text in time for them to be effective July 1, it would still be prudent for businesses that were waiting for final regulations to proceed with updating their CCPA compliance programs.

To read our summary of the unchanged most recent draft regulations, click here. To access materials released by the CA AG to accompany the final regulations, click here.

 

 

 

Authored by Timothy Tobin, Mark Brennan, Bret Cohen, Scott Loughlin, Melissa Bianchi, Britanie Hall, Roshni Patel, Arielle Brown, Ryan Woo, Aaron Lariviere, Julian Flamant, Filippo Raso, Jonathan Hirsch and Sophie Baum.

Contacts
Melissa Bianchi
Partner
Washington, D.C.
Mark Brennan
Partner
Washington, D.C.
Bret Cohen
Partner
Washington, D.C.
Scott Loughlin
Partner
Washington, D.C.
Tim Tobin
Partner
Washington, D.C.
Arielle Brown
Senior Associate
Denver
Roshni Patel
Senior Associate
Washington, D.C.
Julian Flamant
Associate
Washington, D.C.
Jonathan Hirsch
Associate
Washington, D.C.
Filippo Raso
Associate
Washington, D.C.
Ryan Woo
Associate
Washington, D.C.

 

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