The FTC Finalizes Amendments To The COPPA Rule

The Bottom Line

• While the Final Rule does not become effective until 60 days after publication in the Federal Register and operators have an additional year to comply, and the Trump administration has issued an Executive Order enabling new regulations to be paused, operators should begin assessing their current privacy practices now, as it may take some time to come into full compliance.
• Requirements that were ultimately dropped from the Final Rule, such as limitations on push notifications, may still be the subject of enforcement under the Commission's broad FTC Act Section 5 authority. Companies should be mindful of whether their data practices may still be considered an "unfair trade practice" under the FTC Act despite meeting COPPA's express requirements.