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Public Policy Updates

The NAI serves as the leading voice of digital advertising companies and third-party advertisers in public policy discussions before the U.S. government, states, and governments around the world. We are committed to promoting public policies that balance strong consumer privacy protections with consumer demands for a vibrant digital content ecosystem, supported by innovative digital advertising.

To that end, the NAI also works closely with member companies to facilitate cooperation around key legal and compliance issues, and to develop analysis to enhance NAI members’ understanding of various legal requirements as they apply to the digital advertising ecosystem.

The NAI also continues to be a champion of strong industry self-regulation and co-regulation, whereby industry efforts can play a complimentary role to new regulations as a means of supplementing and enhancing new regulations as a method for companies to demonstrate their compliance with legislative and regulatory requirements.

Recent Public Policy Updates

NAI Welcomes Bipartisan, Bicameral Effort to Enact a Uniform National Privacy Framework

April 9, 2024

Efforts should focus on preserving beneficial uses of data, and protecting consumers from harm WASHINGTON, DC (April 9, 2024) – The Network Advertising Initiative (NAI) released the following statement from

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NAI Comments on COPPA NPRM

March 12, 2024

On March 11, the NAI submitted comments on the FTC’s (Federal Trade Commission) Notice of Proposed Rulemaking (“NPRM”) to amend the COPPA Rule (Children’s Online Privacy Protection Rule) pursuant to

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NAI Submits Comments to CFPB on Financial Advertising

January 2, 2024

On December 29, 2023 the NAI submitted comments on the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) Notice of Proposed Rulemaking (“NPRM”) and the Proposed Rule on Personal Financial Data

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NAI Comments on Colorado Universal Opt-Out Shortlist

December 12, 2023

On December 11, 2023 the NAI submitted comments on the Universal Opt-Out (UOOM) shortlist recently announced by the Colorado Department of Law (DoL). In summary, the NAI recommends the following

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NAI Comments on NTIA Kids Online Health and Safety RFC

November 17, 2023

On November 16, the NAI commented on the National Telecommunications and Information Administration’s (NTIA) Request for Comment (RCF) on best practices to protect minors’ mental health, safety, and privacy online.

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NAI Comments on Health Data Privacy RFI

September 29, 2023

On September 28, the NAI commented on Sen. Bill Cassidy’s (R-LA) Request for Information (RFI) on Improving Americans’ Health Data Privacy. The comments highlight three key recommendations: (1) Congress should

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How Ad-Tech companies help bolster small publishers and advertisers.

September 20, 2023

Ad-Tech companies play an important role in helping small publishers and advertisers serve appropriate ads to consumers while maintaining and adhering to industry best practices for data privacy. Find out

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NAI Legal and Regulatory Analysis: Sensitive Health Information

September 5, 2023

Health-related advertising has been around nearly as long as advertising itself. However, new data collection and storage technology has fundamentally changed how many in the industry operate and the ways

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NAI Comments on FTC Notice of Proposed Rulemaking to Update HBNR

August 9, 2023

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

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NAI Comments on CFPB RFI

July 20, 2023

On July 14, 2023 the NAI sent its comment on the CFPB RFI to the agency. These comments discuss the following key issues raised by the RFI, and make recommendations

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State Privacy Patch #6 for Iowa: What Digital Advertising Companies Need to Know

March 30, 2023

By Meaghan Donahue (meaghan@thenai.org) and Ryan Smith (ryan@thenai.org) On March 29, 2023, Iowa Governor Kim Reynolds signed Senate File 262 (SF 262) into law, making Iowa the sixth state to

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NAI Comments on the Comments on the CCPA’s Preliminary Rulemaking on Cybersecurity, Risk Assessments and Automated Decisionmaking

March 28, 2023

The NAI would like to thank the California Privacy Protection Agency for the opportunity to provide comments on the CCPA’s preliminary rulemaking on cybersecurity, risk assessment and automated decisionmaking. Please

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NAI Comments on the Washington My Health My Data Act

March 16, 2023

The NAI would like to thank you for the opportunity to provide feedback on H.B. 1155, the Washington My Health My Data Act. Please see our full testimony below.

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NAI comments to NTIA RFC on Privacy, Equity and Civil Rights

March 7, 2023

The Network Advertising Initiative (NAI), would like to thank the National Telecommunications and Information Administration (“NTIA”) for the opportunity to provide comments on the intersection of privacy, equity, and civil

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NAI Comments on the FTC Petition for Rulemaking to Regulate Programmatic Advertising.

February 17, 2023

Thank you to the Federal Trade Commission for the opportunity to comment on the “Petition For Rulemaking Under 15 U.S.C. § 57(a) Seeking Regulation Of Advertising Technology Companies And Agencies

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NAI Submits Testimony on Washington H.B. 1155

January 25, 2023

We want to thank the Washington State House Civil Rights and Judiciary Committee for the opportunity to provide feedback on H.B. 1155, the Washington My Health My Data Act.

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NAI Comments on Version 2 of the Colorado Privacy Act

January 19, 2023

The Network Advertising Initiative (“NAI”) appreciates the opportunity to comment in response to Version 2 of the Proposed Draft Rules (“Revised Draft Rules”) for the Colorado Privacy Act(“CPA”).

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NAI Submits Comments To The FTC ANPR

November 22, 2022

We want to thank the Federal Trade Commission for the opportunity to comment on the Advanced Notice of Proposed Rulemaking (“ANPR”) for a Trade Regulation on Commercial Surveillance and Data

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NAI Comments on The Modified Proposed CPRA Regulations

November 21, 2022

The Network Advertising Initiative (“NAI”) appreciates the opportunity to provide comments on the proposed modified regulations under the California Privacy Rights Act(“CPRA”).

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NAI Comments on CPA Proposed Draft Rules

November 9, 2022

On behalf of the Network Advertising Initiative, thank you for the opportunity to providepreliminary comments on proposed rulemaking under the Colorado Privacy Act.

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NAI Comments on Proposed Regulation Under the CPRA

August 24, 2022

The NAI comments call on the California Privacy Protection Agency to amend their proposed regulations regarding the use of Opt-out Preference Signals, which could be used to unfairly disadvantage businesses across

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Prepared Remarks for CPA Pre-Rulemaking Listening Session

June 28, 2022

The NAI’s Vice President of Public Policy, David LeDuc, delivered remarks at a Colorado Privacy Act pre-rulemaking listening session held by the Colorado Attorney General’s Office. We emphasized the importance

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NAI Preliminary Comments on Proposed Rulemaking under the Colorado Privacy Act

June 22, 2022

The NAI submitted comments to the Office of the Attorney General (OAG) in Colorado on proposed rulemaking under the Colorado Privacy Act. The NAI supports the OAG in its principle-guided

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NAI Comments to NTIA on Competition in Mobile App Ecosystem

June 9, 2022

In comments to the NTIA on the Report on Competition in the Mobile App Ecosystem, the NAI recommended a balanced approach to privacy and competition, focused on eliminating harmful or

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Best Practices for User Choice and Transparency

May 10, 2022

This Resource, developed by NAI legal and policy staff in consultation with representatives from member companies, is intended to help member companies better understand the practice of dark patterns and

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Prepared Remarks for CPPA Stakeholder Session

May 6, 2022

The NAI’s VP of Public Policy, David LeDuc, joined the CPPA for a stakeholder session prior to the development of draft implementing regulations for the CPRA. We urged the CPPA

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NAI Regulatory Summary and Analysis: Statement of the Federal Trade Commission on Breaches by Health Apps and Other Connected Devices

February 4, 2022

The NAI has published a Regulatory Summary and Analysis in response to the FTC’s September 2021 Policy Statement on the Health Breach Notification Rule, and its recent guidance updated in

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NAI Comments: Petition for Rulemaking to Prohibit Surveillance Advertising

January 27, 2022

The NAI filed comments with the Federal Trade Commission (FTC) in response to a petition proposing an FTC rulemaking on unfair competition that would result in a ban on “surveillance

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Prepared Remarks from NAI President & CEO Leigh Freund for NTIA Virtual Listening Session on Personal Data: Privacy, Equity, and Civil Rights

January 11, 2022

On behalf of the Network Advertising Initiative (“NAI”), President & CEO Leigh Freund joined a virtual listening session hosted by the National Telecommunications and Information Administration (“NTIA”) to discuss solutions

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NAI Comments: The Washington State Public Disclosure Commission (“PDC”): How to Improve Digital Political Advertising Disclosure in the State

November 11, 2021

The Network Advertising Initiative (“NAI”) appreciates the opportunity to provide comments on the Washington State Public Disclosure Commission deliberations on how to improve digital political advertising.

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Preliminary Comments on Proposed Rulemaking Under the California Privacy Rights Act

November 9, 2021

On behalf of the Network Advertising Initiative (“NAI”), thank you for the opportunity to providepreliminary comments on proposed rulemaking under the California Privacy Rights Act (“CPRA”).

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NAI Comments: Bringing Dark Patterns to Light: An FTC Workshop

March 16, 2021

At a time when Americans are spending more time than ever on connected devices, this discussionabout “dark patterns” is important and timely. While there are different definitions of this term,

Public Policy Leadership for Ad-Tech Companies

February 16, 2021

The Network Advertising Initiative (NAI) is the leading ad-tech industry association, helping member companies navigate the increasingly challenging legal and regulatory environment. The NAI’s advocacy program also promotes and protects

Testimony on WA SB 5062 (Washington Privacy Act of 2021)

January 21, 2021

On behalf of the ANA, the 4A’s, the AAF, the IAB, and the NAI, thank you for the opportunity to provide comments on SB 5062 (“WPA”). In addition to this

NAI Letter to Rep. Schiff Regarding Ad Blocking on News Sites

June 2, 2020

On behalf of the Network Advertising Initiative (NAI) and our members, thank you for your recent inquiry about digital advertising practices during the COVID-19 pandemic and the potential negative effects

NAI Summary of CPRA

May 13, 2020

This summary represents the NAI’s preliminary analysis of the changes to the CCPA proposed by the CPRA ballot initiative. This summary is intended only to highlight proposed changes of particular

Political File Requirements- Presentation by Perkins Coie

April 13, 2020

NAI Comment Letter – CCPA Second Set of Modified Regulations

March 27, 2020

The Network Advertising Initiative (“NAI”) is pleased to submit these comments regarding the second set of modifications to the regulations proposed for adoption under the California Consumer Privacy Act of

NAI Comment Letter: COPPA Rule Review

February 25, 2020

NAI Comment Letter: COPPA Rule Review

December 19, 2019

On behalf of the Network Advertising Initiative (NAI), thank you for providing the opportunity to revisit the crucial priority of protecting children on the internet. NAI submits these comments in

NAI Analysis – CCPA Sales

November 1, 2019

Considerations for NAI Members Regarding the Classification of Ad-tech Data Flows as “Sales” Under the CCPA: An NAI Analysis

CCPA Amendment Summary

October 1, 2019

NAI Analysis of Verifiable Consumer Requests under the CCPA

September 1, 2019

This analysis will explain the rights California consumers have gained under the CCPA to request access to and deletion of their personal information, and how businesses are required to verify

NAI Comments to California AG Xavier Becerra re: CCPA Regulations

March 1, 2019

The Network Advertising Initiative (“NAI”) is pleased to submit this letter in response to the Department of Justice’s request for comments regarding implementing regulations it may promulgate under the California

NAI Comments to FTC re: Consumer Privacy Hearings

December 21, 2018

Thank you for to opportunity to submit comments in advance of the upcoming hearing on Consumer Privacy, scheduled for February 12-13. Please find below detailed responses to the questions for