November 21, 2022

Submitted via email: [email protected]

California Privacy Protection Agency
Attn: Brian Soublet
2101 Arena Blvd.
Sacramento, CA 95834

Re: CPPA Public Comment for CPRA Regulations

Dear Mr. Soublet,

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to respond to the California Privacy Protection Agency (“CPPA”) Modified Text of Proposed Regulations dated November 3, 2022 (the “Modified Proposed Regulations”) that modifies the previously proposed regulations published on July 8, 2022 as required under the Consumer Privacy Rights Act of 2020 (“CPRA”).2 SIFMA previously commented on the initial proposed regulations dated August 18, 2022 (“Initial Letter”)3 and the comments below reflect some of those same comments as well as comments on the Modified Proposed Regulations. SIFMA appreciates the continued work the CPPA has done to bring public attention to consumer privacy issues and work with companies to achieve a higher level of consumer protection.

SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets, including a significant presence in California. SIFMA has 24 broker-dealer and asset manager members headquartered in California. Further, there are approximately 384 broker-dealer main offices, nearly 40,000 financial advisers, and 93,522 securities industry jobs in California.4

1 The Securities Industry and Financial Markets Association (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 one 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 https://cppa.ca.gov/regulations/pdf/20220708_npr.pdf

3 SIFMA Letter to California Privacy Protection Agency (August 18, 2022) (available at https://www.sifma.org/wp-content/uploads/2022/08/California-Privacy-Regulation-Letter.pdf).

4 https://states.sifma.org/#state/ca