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CBA Submits Comments on BCFP’s Trial Disclosure Proposal
On Wednesday, October 10, 2018, CBA along with ABA and the U.S. Chamber of Commerce submitted a joint comment letter to the BCFP in response to its trial disclosure proposal. We are supportive of changes to the trial disclosure program as the current framework offers few incentives or protections for participating companies. In our letter, CBA asks the Bureau to provide greater protections for sensitive commercial information, as well as regulatory enforcement and litigation risks. We also ask the Bureau to coordinate with state and federal regulatory authorities, and to clarify certain elements of its proposal. Finally, we urged the Bureau to commit to amending disclosure rules and regulations in light of successful trial disclosure data.