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05 June 2020
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.
For further information on this topic please contact Mark M Brennan, Timothy P Tobin or Bret S Cohen at Hogan Lovells by telephone (+1 202 637 5600) or email (email@example.com, firstname.lastname@example.org or email@example.com). The Hogan Lovells website can be accessed at www.hoganlovells.com.
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