On July 1, 2020, the California Consumer Privacy Act (“CCPA”) will become enforceable by the California Attorney General (“AG”). The CCPA went into effect on January 1, 2020. Covered companies have been required to comply with its provisions since the effective date, but the AG has not been empowered to bring any enforcement action for non-compliance. For a complete summary of the CCPA, please see Seward & Kissel’s client memorandum.

On June 1, the AG submitted final proposed regulations to the California Office of Administrative Law (“OAL”) for review for compliance with the California Administrative Procedure Act. If approved by the OAL, as expected, the regulations will become legally binding. The final regulations do not make any material changes to the provisions of the CCPA described in our prior client memorandum.

If you have any questions regarding the CCPA, please contact any of the partners and counsel listed below or your primary attorney in Seward & Kissel’s Investment Management Group.