The Consumer Federation of America (CFA), Center for Economic Justice (CEJ), United Policyholders (UP), and National Consumer Law Center (NCLC) offered comments on the draft Principles for Effective Cybersecurity Regulatory Guidance by the National Association of Insurance Commissioners. In these comments, the consumer groups urged that the principles "explicitly state the requirement for insurers and producers to comply with existing state data security and breach laws" and proposed edits to the draft principles that would strengthen them and offer specific consumer protections.