The California Consumer Privacy Act (CCPA) imposes sweeping obligations on a diverse array of businesses, but investment advisers subject to Regulation S-P (adopted pursuant to the federal Gramm-Leach-Bliley Act (GLBA)) are treated somewhat differently. The CCPA does not provide a blanket exemption for investment advisers with retail clients, although the CCPA’s exception for personal information covered by the GLBA takes the edge off the CCPA. In addition, two late amendments to the CCPA also reduce the scope of the CCPA for investment advisers during the year 2020.

The CCPA applies to some personal information that investment advisers routinely handle. Therefore, it’s important that investment advisers examine the compliance burdens they may have under the CCPA. This checklist is intended to help investment advisers track their CCPA compliance obligations for 2020 and 2021.

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