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Considerations for Determining Whether a Cyber Incident Is Material
Troutman Pepper
[Guidance Overview] Sept. 3, 2024 "In late June, the staff of the [SEC's] Division of Corporation Finance released five new compliance and disclosure interpretations regarding the disclosure of material cybersecurity incidents ... The staff makes one underlying theme clear throughout this guidance: No single factor is determinative of whether a cybersecurity incident is material. Once a cybersecurity incident is determined to be material, however, it must be reported within four business days after the company determines that it has experienced a material cybersecurity incident." MORE >> |
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