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One has to say that Erik Gerding, Securities and Exchange Commission Director of the Division of Corporation Finance, is on a role on disclosure. This is not the first statement made recently on the disclosure requirements of covered entities. Here he highlights the role of the SEC is providing oversight of Corporate reporting against Sarbanes Oxley and emerging areas of focus, that includes cybersecurity risk.
Cybersecurity risk is a disclosure priority for the SEC, director Gerding makes clear that Division staff will review both current cyber reports about material cybersecurity incidents and selected annual disclosures to assess compliance with the rules, provide guidance, and improve disclosures.
When one reviews both 10K and 8K filings one may expect both incident reviews and annual reviews to raise many questions about the determination and reporting of both material cyber risks and material cyber incidents. As many commentators have said that both reports seem to under value both cyber risk and cyber incidents and further more disclose little about cybersecuirty risk management governance and processes. As we may see as the SEC and Federal Trade Commission examine the UnitedHealth cyber attack, possible MGM and Caesars.
@Thaddeus Dziekanowski Brian D. McCarthy
Veritas GRC U.S. Securities and Exchange Commission
#cybersecurity #cyberriskmanagement #cyberregulation
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