“CPPA’s underlying economic assumptions are grounded in fantasy.”
—Cory L. Andrews, WLF General Counsel & Vice President of Litigation
Click here for WLF’s comment.
(Washington, DC)—Washington Legal Foundation (WLF) yesterday submitted a formal comment to the California Privacy Protection Agency (CPPA) on the its recently proposed regulations under the California Privacy Rights Act. WLF’s comment was drafted with the pro bono assistance of David Zetoony and Andrea Maciejewski of Greenberg Traurig LLP.
As part of the rulemaking process, CPPA submitted an Economic Impact Statement concluding that a typical business’s cost to comply with the newly proposed regulations would be only $127.50. To justify that miniscule number, CPPA regulators insisted that the proposed regulations merely re-state current law while imposing no new compliance burdens on businesses. As WLF’s comment shows, however, that assumption is indefensible.
In painstaking detail, WLF identifies more than 45 proposed new economic burdens that go well beyond the existing statutory and regulatory rules. CPPA takes none of these into account. WLF thus calls on CPPA to bring its estimate of the proposed regulations’ economic impact in line with reality. As WLF’s comment explains, regulated entities require a full and accurate estimate of each new compliance burden before they can meaningfully comment on the proposed regulations.