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The enclosed letter is an interesting read. In May 2020 the Cybersecurity Solarium Commission wrote to the SEC asking that they consider the material impact of cyber security and including oversight of control reporting in Sarbanes Oxley, under section 404. Aligning with PCAOB concerns about the material impact of cyber attacks on financial reporting accuracy and misstatement.
If cyber were to be specifically included under section 404 and SoX audits we expanded beyond APD, PDPC and CO under IT General controls. Could it make boards of publicly traded companies liable for the failing to manage material risks in the event of a cyber attack?
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