Latest Developments on New NAIC Consumer Privacy Model Law

Client Alert June 23, 2023

Following the Spring National Meeting, the National Association of Insurance Commissioners (“NAIC”) Privacy Protections (H) Working Group (“PPWG”) held a series of private and public meetings in which interested parties and consumer advocates provided feedback on the initial exposure draft of the new Consumer Privacy Protections Model Law (Model 674).1 Two series of meetings were held in both May and in early June. At the conclusion of the meetings, the PPWG announced that it will fully rewrite Model 674 with the goal of publishing a new draft by the end of June. Rather than the normal 60-day comment period, the PPWG will incorporate comments on a rolling basis and release periodic redlines as revisions are made. It will host regular open meetings every two weeks starting in early July and discuss additional comments and revisions at the Summer National Meeting. The PPWG is targeting adoption no earlier than the Fall National Meeting.

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