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November 2015 » The Issue of Cyber Risk Disclosures
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Allan B. Afterman, PhD, CPA
As 2015 comes to a close and companies begin to think about preparing Form 10-K annual reports and first-quarter 2016 Form 10-Q reports, disclosures concerning cyber risk that should be included in SEC filings are among the key issues requiring the attention of managers and boards of directors alike. Cyber risk disclosure is not a new issue; it has formally been on the SEC's high-interest list since October 2011, when the staff of the SEC's Division of Corporation Finance issued guidance on the disclosure obligations relating to cyber risk, cybersecurity, and cyber incidents (see, for example, “SEC Cybersecurity Disclosure Guidance Is Quickly Becoming a Requirement,” Gerry H. Grant and C. Terry Grant, The CPA Journal, May 2014).
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