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Corporate America is concerned about the timing of the SEC cyber ruling. While the timely reporting of material cyber incidents is Important. It is by far the least consuming of the rule. Disclosure and management of material cyber risk is where the money is.
However, it’s fair to say that corporates globally have had many years to consider cyber. It’s now a national security problem so everyone, regulators and corporates alike are between rocks and hard places.
It’s correct to say that the effective date for reporting Material cyber incidents starts 90 days from the 5th September. Its also fair to say that the reporting of material risk to the regulator is not a new requirement.
Ted Dziekanowski Rachel V. Rose, JD, MBA Bob Dix
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