Cybersecurity: SEC Proposals for Public Company Reporting, Disclosures

The SEC cybersecurity disclosure proposed rules reiterate the importance of cyber hygiene and incident reporting. The proposed rules would increase the prominence of required disclosure of cyber security incidents in a number of corporate filings, including annual filings and on Forms 8-K and 6-K. For registered companies, the proposed disclosure requirements would demand (1) a better understanding of risks and potentially new technology and processes to meet the potential reporting requirements and (2) greater engagement on cyber security preparedness. Organizations should look to enhance their current cybersecurity risk management and reporting processes accordingly.