The CCPA Is Here: What Financial Institutions Need to Know about the California Consumer Privacy Act
As of January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) is now the law of the land, having gone into effect at the beginning of this year. One of the more complex issues concerning the CCPA pertains to the extent to which financial institutions governed by the Gramm-Leach-Bliley Act (GLBA) must adhere to the mandates of the CCPA. While California’s new privacy law does afford a carve-out for financial institutions, it does not provide a comprehensive, across-the-board “get out of jail free” card for the financial services industry. Consequently, at this juncture it is imperative that all covered financial institutions ensure that they are in compliance with the CCPA to minimize the potential liability risk that now exists for noncompliance with the law. Fortunately, through the implementation of several best practices, financial institutions can continue to effectively leverage data in the course of their business operations, while at the same time steering clear of the potential pitfalls that could result in substantial liability exposure resulting from a failure to adhere to the CCPA’s broad mandates.
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“The CCPA Is Here: What Financial Institutions Need to Know about the California Consumer Privacy Act,” by David J. Oberly and Tanweer Ansari* was published in the Summer 2020 edition of the NY Business Law Journal (Vol. 24, No. 1), a publication of the Business Law Section of the New York State Bar Association. Reprinted with permission.
* Tanweer Ansari is Senior Vice President and Chief Compliance Officer of First National Bank of Long Island.