On February 21, 2018, the SEC issued new Guidance regarding cybersecurity disclosure and governance requirements applicable to SEC reporting companies. In our earlier Client Update on this topic, we discussed the disclosure considerations addressed in the Guidance. In this Client Update, we focus on the cyber-related governance issues addressed in the Guidance.
Cybersecurity and Risk Governance
The Guidance addresses three governance topics in the context of cybersecurity: (1) the adoption and regular assessment of cyber-related disclosure controls and procedures; (2) the establishment of policies and procedures to address the risk of insider trading based on material nonpublic cybersecurity … Read more