AFSA Submits RFI on Texas Consumer Protection Law
On August 21st AFSA’s State Government Affairs (SGA) team sent a letter to the Texas Privacy Protection Advisory Council in response to the council’s request for information from industry stakeholders. The five-member council was created by HB 4390 in September 2019 and must submit recommendations on statutory changes regarding consumer privacy by September 1, 2020. In the letter, AFSA stressed that the financial services industry is already subject to federal data privacy standards like the Gramm-Leach-Bliley Act and Fair Credit Reporting Act, and additional state laws imposing additional requirements on covered entities unnecessarily create a significant compliance burden with little consumer benefit.
The letter also highlighted some of the problems with existing state privacy and data protection standards, such as the California Consumer Privacy Act and the New York Department of Financial Services’ cybersecurity regulations. AFSA urged the council to institute a delayed effective date for any statutory changes to allow for a robust rulemaking process with significant input from stakeholders and ample time for covered entities to implement any required changes.
August 27th, 2020
