CFA submitted the following comments on the Federal Trade Commission’s (FTC’s) proposed rule to amend the Children’s Online Privacy Protection Rule. The comments commend FTC for taking action to strengthen the regulations implementing the Children’s Online Privacy Protection Act (“COPPA”) and note the special dangers associated with online food marketing to children. The comments urge FTC to narrow the so-called “school authorization exception” to the COPPA rule so that educational technology (“ed tech”) providers in schools cannot collect and use children’s data to devise ways to maximize engagement with platforms. The comments further argue that the proposed rule should provide parents with the right to review their children’s data collected by ed tech operators pursuant to the school authorization exception.