December 6, 2019

VIA EMAIL TO: [email protected]

The Honorable Xavier Becerra
Attorney General, State of California
1300 I Street
Sacramento, CA 95814

Privacy Regulations Coordinator
California Office of the Attorney General
300 South Spring Street, First Floor
Los Angeles, CA 90013

Re: Proposed California Consumer Privacy Act Regulations

Dear Attorney General Becerra,

The Securities Industry and Financial Markets Association (SIFMA)1 appreciates this opportunity to comment on the proposed California Consumer Privacy Act (CCPA) regulations.

I. Executive Summary
In promulgating regulations under the CCPA, it is important that the Attorney General’s office endeavor to create clear and consistent rules that businesses can meaningfully rely on in their efforts to comply with the CCPA and provide consumers with additional clarity about the collection, use, and sharing of their personal information. To that end, SIFMA requests that the Attorney General’s office delay enforcement of the CCPA until January 1, 2022, to allow for businesses to appropriately implement the complex systems of accepting, verifying, and responding to consumers’ requests in accordance with the regulations’ requirements.

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 for 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).