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The SEC’s Guidance on Cyber Risks and Incidents: A Deeper Dive

Posted in Data Security, SEC

In October 2011, the U.S. Securities and Exchange Commission’s Division of Corporation Finance issued “CF Disclosure Guidance: Topic No. 2”, which was a guidance intended to provide some clarity as to the material cyber risks that a publicly traded company should disclose.  I previously wrote about the guidance.  This blog post is the first of… Continue Reading

The SEC Is Cracking Down on Companies That Do Not Disclose Cyber Incidents

Posted in Data Security, SEC

As I wrote in a previous post, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance issued a Disclosure Guidance on October 13, 2011, that states publicly traded companies may be obligated to disclose cyber incidents and the risk of cyber incidents, depending on the application of various factors. Now, according to a recent… Continue Reading