News & Analysis as of

Final Rules Reporting Requirements Cybersecurity

Wiley Rein LLP

Update: DOJ and CISA Issue New National Security Program to Regulate Foreign Access to Sensitive Data

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On January 8, 2025, the U.S. Department of Justice (Department or DOJ) issued new rules required by then-President Biden’s February 2024 Executive Order (EO) 14117 to establish a new regulatory framework aimed at “Preventing...more

King & Spalding

DOJ Issues Final Rule Restricting Foreign Access to U.S. Data

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The rule imposes substantial new diligence, reporting, cybersecurity, and auditing obligations on companies. On December 27, 2024, the U.S. Department of Justice (“DOJ”) issued a final rule implementing Executive Order...more

Seward & Kissel LLP

Annual Report and Shareholder Meeting Season and Other Recent SEC Developments

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This memorandum summarizes key U.S. Securities and Exchange Commission (“SEC”) and stock exchange regulatory filing deadlines, new disclosure requirements and general tips and guidance for both U.S. domestic issuers and for...more

Burr & Forman

Cyber Incident Reporting Obligations for Public Companies under the SEC’s New Cybersecurity Rules

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The U.S. Securities Exchange Commission (SEC) recently adopted a final rule regarding cybersecurity risk management, governance, and incident reporting. The final rule went into effect on September 5, 2023, and disclosure...more

Polsinelli

The SEC Raises the Stakes: New Cybersecurity Rules for Publicly Traded Companies Hit the Books in 2023

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In 2023, the U.S. Securities and Exchange Commission (“SEC”) issued its now-fully implemented Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure Rule. The Rule reflects the reality that cybersecurity...more

Snell & Wilmer

Corporate Communicator - 2024 Annual Meeting Season

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Clawback Rules. As previously discussed in last Winter’s Corporate Communicator, the Securities and Exchange Commission (“SEC") adopted final rules in October 2022 directing the NYSE and Nasdaq to adopt listing standards that...more

Mayer Brown Free Writings + Perspectives

Cybersecurity Disclosure and Compliance & Disclosure Interpretations

Recently, in advance of the effective date (December 18, 2023), the Director of the SEC’s Division of Corporation Finance provided additional guidance regarding the final rules relating to cybersecurity incident disclosure...more

Woods Rogers

Examining Materiality and Cybersecurity Incidents: Practical Tips for Implementing the New SEC Rules

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Publicly traded companies have tangled with the question of when a cybersecurity incident should be disclosed to the public and investors. In a bid to add clarity to the topic, the U.S. Securities and Exchange Commission...more

Kelley Drye & Warren LLP

SEC Issues Final Rules on Cybersecurity Disclosures

On July 26, 2023, in a 3-2 vote, the Securities and Exchange Commission (the “SEC”) adopted new rules (the “Final Rules”) for public companies that will require disclosures regarding cybersecurity incidents, as well as...more

Stikeman Elliott LLP

SEC Adopts New Cybersecurity Disclosure Rules for U.S. Public Companies and Foreign Private Issuers

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The Securities and Exchange Commission (“SEC”) adopted new rules requiring the disclosure of cybersecurity risk management, strategy, governance and material incidents (the “Rules”), effective September 5, 2023. The Rules...more

Bracewell LLP

SEC Cybersecurity Reporting Requirements for Public Companies: Applying Old Standards to New Risks

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On July 26, 2023, the Securities and Exchange Commission (“SEC”) issued a final rule that requires registrants to provide enhanced and standardized disclosures regarding “cybersecurity risk management, strategy, governance...more

Holland & Knight LLP

SEC Cybersecurity Rules: Considerations for Incident Response Planning

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The new Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure rules (Final Rules) adopted by the U.S. Securities and Exchange Commission (SEC) were published in the Federal Register on Aug. 4, 2023, and...more

Dechert LLP

SEC Final Rule Exempts ABS Issuers from New Cybersecurity Disclosure and Reporting Requirements

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ABS issuers have been exempted from the U.S. Securities and Exchange Commission's (“SEC”) final rule requiring certain cybersecurity risk and incident disclosure (the “Final Rule”). The SEC left open the possibility of...more

Epiq

Breaking Down the New SEC Cybersecurity Rules

Epiq on

On July 26, the Securities and Exchange Commission (SEC) adopted new cybersecurity rules. Organizations will need to disclose material cyber incidents pursuant to a prescribed timeline and information regarding risk...more

Husch Blackwell LLP

SEC Heightens Issuers' Cybersecurity Disclosure Requirements

Husch Blackwell LLP on

On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) adopted final rules regarding cybersecurity risk management, strategy, governance, and incident reporting by public companies. The final rules require...more

Woodruff Sawyer

Roadmap for Plaintiffs or Boon for Investors: The SEC’s New Cyber Rules

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They’re here. No, not poltergeists. Just the Securities and Exchange Commission’s new cyber disclosure rules. While implementing them will be challenging, and new, serious risks will emerge, the rules are now final and public...more

Wyrick Robbins Yates & Ponton LLP

SEC Adopts Final Cybersecurity Rules

Following up on our previous report from almost a year ago, the U.S. Securities and Exchange Commission (the “SEC” or “Commission”) has adopted final rules intended to enhance and standardize disclosures regarding...more

WilmerHale

Preparing for New Cybersecurity Disclosures

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Public companies will soon be required to provide increased transparency about cybersecurity incidents, risk management, strategy and governance as a result of new rules adopted by the Securities and Exchange Commission (the...more

Hogan Lovells

SEC adopts significant new cybersecurity disclosure requirements

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On July 26, the SEC adopted amendments to Regulation S-K and Exchange Act forms requiring public companies to disclose on a current basis material cybersecurity incidents and to disclose annually information regarding their...more

Shook, Hardy & Bacon L.L.P.

SEC Issues Rules on Cybersecurity Reporting Obligations

On July 26, the Securities and Exchange Commission (SEC) issued new rules adding cybersecurity disclosures for public companies in three areas: cybersecurity incidents, governance, and risk management and strategy. The new...more

Miller Nash LLP

SEC Adopts Final Cybersecurity Disclosure Rules for Public Companies

Miller Nash LLP on

The Securities and Exchange Commission (SEC) adopted new rules in late July 2023 that will require publicly traded companies to disclose information to assist investors in understanding the processes companies use to manage...more

Kilpatrick

SEC Issues Final Rule on Cybersecurity Incident Reporting and Cybersecurity Risk Management Disclosure

Kilpatrick on

The Securities and Exchange Commission (the “SEC”) issued a final rule on July 26, 2023 that will require public companies to disclose material cybersecurity incidents on Form 8-K within four business days of discovery. In...more

Perkins Coie

It’s Official: Cybersecurity Disclosure Is Coming This Year

Perkins Coie on

The U.S. Securities and Exchange Commission (SEC) adopted final rules on July 26, 2023, requiring public companies to provide current disclosure, within what may be a short time window, about material cybersecurity incidents...more

Ballard Spahr LLP

SEC Adopts New Cybersecurity Reporting Rules, Setting Up Various Compliance Challenges

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After an extensive comment period, the SEC announced on July 26 that it was formally adopting new rules for public companies governing cybersecurity disclosures. The rules had generated significant backlash from public...more

Jenner & Block

SEC Adopts Rules on Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure by Public Companies

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On July 25, 2023, the US Securities and Exchange Commission (the SEC), by a 3-2 vote, adopted final rules regarding cybersecurity risk management, strategy, governance and incident reporting by public companies (the Final...more

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