California Attorney General Issues Second Round of Modifications to CCPA Regulations

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At approximately 6:00 p.m. today, March 11, 2020, California Attorney General Xavier Becerra announced a second round of modifications to the draft regulations his office is preparing for the California Consumer Privacy Act (the “Draft CCPA Regulations”). These modifications follow two previous rounds of drafting:

(a) the initial publication of the Draft CCPA Regulations, in regards to which we analyzed 21 potentially material business impacts here, and

(b) a first round of modifications to the Draft CCPA Regulations, for which we provided 30 key business impacts here.

Alston & Bird is currently preparing a detailed analysis of this second round of modifications to the Draft CCPA Regulations, which will be published via this blog. A copy of the Draft CCPA Regulations containing all modifications from both the first and second rounds of modifications can be downloaded here.

Companies who see relevant issues in the most current modifications to the Draft CCPA Regulations should note the Attorney General indicates that the deadline for comments is 5:00 p.m. Pacific time on Friday, March 27.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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