2min chapter

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Srsly Risky Biz: Why two hats are better than two heads

Risky Bulletin

CHAPTER

Navigating Cybersecurity Disclosures in SEC Filings

This chapter explores the complexities of reporting cybersecurity incidents in SEC filings, emphasizing the pitfalls of boilerplate language. The discussion underscores the necessity for ongoing education and adaptive rulemaking in the face of evolving cybersecurity challenges.

00:00
Speaker 1
I
Speaker 2
mean, the joke I made yesterday was like boilerplate language in an SEC filing. That's, I've never heard of that, you know. And
Speaker 1
I mean, you know, the person who first came up with those form of words probably deserves a pay rise. Everyone else is just copying their work. Yeah. So the a copy
Speaker 2
paster mate that's right cyber filings are just a copy paster so
Speaker 1
i when i was writing this piece i was thinking so what's the answer here like there's actually very few material incidents that have been reported should you just give up and say oh yeah don't worry about it um because mostly the material ones are actually ones have significant impacts. And so people in the press pick them up. So they do get reported. In the end, I decided that probably wasn't a realistic or responsible approach, assuming that I was the head of the SEC. And so I think it's just you continue to educate people. Cyber incidents aren't going to go away anytime soon. So this is a long term problem. You've started trying to raise the bar on disclosure. I think it's a good thing in the long term. So you just need to keep pushing and saying, yeah, we don't actually care about these ones. But here's a really good example of, you know, this is what we're looking for in a disclosure. That's
Speaker 2
right. And I think what's going to happen eventually is there's going to be some material disclosure and they roll out the boilerplate language, but it turns out to be a big deal and they're going to get smacked for it, right? So I think that's kind of how this will naturally evolve. And, you know, we're all going to find, you know, everyone's going to come to understand what the line should be for when you do a disclosure and how much detail you should put into it.
Speaker 1
Yeah. And I think there's a tendency to think we've got to solve the problem like in the next rulemaking phase. And I think it's like cybersecurity is an iterative business. People are always learning as they go.
Speaker 2
Yeah.

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