Invitation for Preliminary Comments on Proposed Rulemaking Cybersecurity Audits, Risk Assessments, and Automated Decisioning
Summary
SIFMA provided comments to the California Privacy Protection Agency (CPPA) on the Invitation for Preliminary Comments on Proposed Rulemaking Cybersecurity Audits, Risk Assessments, and Automated Decision making dated February 10, 2023.
Excerpt
March 27, 2023
VIA E-Mail to [email protected]
California Privacy Protection Agency
Attn: Kevin Sabo
2101 Arena Blvd.
Sacramento, CA 95834
Re: PR 02-2023 – INVITATION FOR PRELIMINARY COMMENTS ON PROPOSED RULEMAKING CYBERSECURITY AUDITS, RISK ASSESSMENTS, AND AUTOMATED DECISIONMAKING
Dear California Privacy Protection Agency,
The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to provide feedback on the California Privacy Protection Agency (“CPPA”) Invitation for Preliminary Comments on Proposed Rulemaking Cybersecurity Audits, Risk Assessments, and Automated Decisionmaking dated February 10, 2023.2 SIFMA members take cybersecurity and data protection seriously as it is a key component of client trust and confidence. In addition, SIFMA members are subject to a wide array of federal, state, and international laws and regulations governing cybersecurity and data protection. There are also significant requirements in place that would govern SIFMA members’ use of artificial intelligence (“AI”) that should also be considered in any CPPA rulemaking or guidance.
1 SIFMA is the leading trade association for broker-dealers, investment banks, and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate on legislation, regulation, and business policy affecting retail and institutional investors, equity and fixed income markets, and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (“GFMA”). For more information, visit http://www.sifma.org.
2 California Privacy Protection Agency, Invitation for Preliminary Comments on Proposed Rulemaking Cybersecurity Audits, Risk Assessments, and Automated Decisionmaking (February 10, 2023) (available at https://cppa.ca.gov/regulations/pdf/invitation_for_comments_pr_02-2023.pdf).