• The Draft Regulations introduced by the California Attorney General’s Office on October 10, 2019 are subject to a public comment period and public hearings that will close on December 6, 2019. Now is the time to act to try to influence the final regulations.

• The Draft Regulations are a mixed bag—they contain some helpful clarifications, include some additional obligations beyond the CCPA’s current requirements and leave various ambiguous issues either unaddressed or unresolved.

• The Draft Regulations go beyond the CCPA in several important ways and introduce new requirements, including new recordkeeping requirements for businesses that alone or in combination receive or share records of four million or more California residents.