Asset Managers Should Take Action in Light of the Expiration of Two Important Exemptions to the California Consumer Privacy Act

Summary

This article discusses considerations for asset managers and financial institutions for compliance with the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act (CPRA). The California legislature adjourned its 2022 session without extending several exemptions from the CCPA. As a result, due to the CPRA amendments to the CCPA that went into effect on January 1, 2023, compliance with the CCPA has become more complicated for in-scope asset managers and financial institutions that: have California-resident employees or job applicants, and/or business contacts resident in California.