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As a result of SEC cyber guidance from 2011 and 2018 , which specifies that cyber risks and cyber incidents could trigger general SEC reporting obligations, Marriott released a statement on its website to coincide with a filing of its 8-K. The breach was discovered in November 2018.
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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.
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