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CA Consumer Privacy Act Gets a Rewrite

MSK Client Alert
March 27, 2019

When the law was signed by then Governor Brown (see our prior Alert here), the expectation was that Attorney General Becerra would issue the enabling regulations by July of this year, which would allow a phase-in period. Then by January 1, 2020, the requirements would be clear and companies would be able to properly formulate and implement their compliance policies. Regretfully, things are not going as expected.

First, in accordance with the law, General Becerra organized a series of public meetings:

In the same press release which announced these meetings, General Becerra advised the regulations would be adopted by July 1, 2020 and went on to remind businesses that they must comply with the key provisions of the CCPA by January 1, 2020:

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