Credit union regulatory and compliance professionals who have been following the California Privacy Protection Agency’s (CPPA) latest proposed changes to the California Consumer Privacy Act (CCPA), as implemented by the California Privacy Rights Act (CPRA), can click here to view the official comment letter recently submitted.

The California Credit Union League submitted the comment letter on behalf of credit union across the state. On July 8, the CPPA began its formal rulemaking activities in connection with enforcement of the CCPA (as amended by the CPRA).

The League has significant concerns with a number of aspects of the CCPA/CPRA and the proposed regulations, including:

• Several areas in the proposed regulations that appear to exceed the requirements of CCPA/CPRA.
• The potential audits to be performed by the CPPA.
• The effective date.
• The enforcement date.
• A lack of clarity around the exemption for personal information collected pursuant to the federal Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act (CFIPA).
• The lack of model notices to facilitate compliance.
  
  

In the letter, the League offers its analysis and comments.

The League will keep credit unions across California informed as this issue moves forward.

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