NAI Comments on FTC Notice of Proposed Rulemaking to Update HBNR

On August 8, the NAI submitted comments to the Federal Trade Commission in response to their Notice of Proposed Rulemaking to update the agency’s Health Breach Notification Rule (HBNR). NAI’s comments, while agreeing with the Commission on many of the proposed changes to the HBNR, also recommended a series of additional modifications to prevent the Rule’s application more broadly than intended.