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Ted Dziekanowski, Brian D. McCarthy, Rich Waite, M.Ed. and George Sawyer. This is an important summary from the SECs Erik Gerding, Director, Division of Corporation Finance on cybersecurity disclosure and released ahead of regulatory oversight of the cyber rule. Providing guidance, of disclosure requirements.
1. Reaffirming the standard of materiality as set out on caselaw.
2. Outlining the SECs, DoJs and FBIs recent guidance and interpretations for delayed reporting on the grounds of national security and public safety.
3. Risk Management, Strategy and Governance Disclosure provisions.
The final rule focuses on corporate responsibilities and of managements role in assessing and managing material risks from cyber threats, and whether and which management positions or committees are responsible for cybersecurity threats, and their relevant expertise. The SEC leaves the door open to public companies and their advisers to raise questions and seek clarification over regulatory compliance.
One must remember that organizations have different risk profiles and that it is not possible to economically secure everything. But it is important to demonstrate adequate, economic and justifiable compliance to the rule. As we see with the SEC charges against SolarWinds, the decisions made over the management of material risks will be tested through the compliance and legal process.
Look for our public cybersecurity risk management program in Quarter 1 2024. Designed around the principles of Materiality and Adequate cybersecurity risk management compliance, as defined by Federal Government. That the SEC is expected to comply. The basis of which can be found here – https://lnkd.in/ecEPkpVd
#cybersecurity #cyberriskmanagement #securitiesandexchangecommission
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