InfoBytes, October 14, 2011 - A Weekly In-depth review of news & developments in the financial services industry


Topics In This Issue:

• Federal Issues

• Courts

• Firm News

• Firm Publications

• Banking

• Consumer Finance

• Litigation

• Privacy/Data Security

Excerpt from Privacy/Data Security

SEC Issues Guidance on Disclosure of Cybersecurity Risks. On October 13, the Securities and Exchange Commission's Division of Corporate Finance (Division) released CF Disclosure Guidance: Topic No. 2 - Cybersecurity, which outlines the Division's views regarding the criteria that publicly held companies should consider in determining what disclosures of cybersecurity risks should be made. The Guidance indicates that companies should weigh several risk factors including the history, probability and severity of incidents and the adequacy of measures taken to mitigate risks for actual or threatened attacks to determine the materiality of the risk and the resulting need to disclose. The Guidance further addresses the specific locations in annual reports and financial statements that certain cyber risk issues should be disclosed. While the Division notes that some incidents may call for greater factual disclosures, there is no requirement that a company provide a "roadmap" to those who may attempt to infiltrate its computer systems...

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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