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New SEC Disclosure Rules for Cybersecurity Incidents and Governance and Key Takeaways

Cleary M&A and Corporate Governance Watch

2] , [3] The rules build on the 2011 guidance issued by the SEC’s Division of Corporation Finance (“2011 Staff Guidance”) and the 2018 Commission Statement and Guidance on Public Company Cybersecurity Disclosures issued by the Commission itself (“2018 Interpretive Release”). [4] The New Rules A. Disclosure by U.S.