On August 17, 2022, WLF filed a formal comment with the California Privacy Protection Agency (CPPA) on its recently proposed regulations under the California Privacy Rights Act. As part of the administrative process, CPPA submitted an Economic Impact Statement concluding that a typical business’s cost to comply with the proposed regulations would be only $127.50. To justify that miniscule number, CPPA regulators insisted that the proposed regulations merely re-state the law while imposing no new compliance burdens on businesses. In painstaking detail, WLF’s comment identifies more than 45 proposed economic burdens that go well beyond the existing statutory and regulatory rules. WLF thus calls on CPPA to bring its estimate of the proposed regulations’ economic impact in line with reality. As WLF explains, regulated entities require a full and accurate estimate of each new compliance burden before they can meaningfully comment on the proposed regulations. WLF’s comment was drafted with the pro bono assistance of David Zetoony and Andrea Maciejewski of Greenberg Traurig LLP.

In addition, through a WLF publication (here), we offered readers sample language that they can use to generate their own comment to CPPA. That sample language can be found here.


WLF comment