SEC Cybersecurity Disclosure Enforcement Heats Up: Best Practices

The SEC is intensifying its focus on cybersecurity disclosures and, in this enforcement environment, effective disclosure policies and controls are crucial. This second installment of a two-part guest article series by William Johnson, Matthew Hanson, Joseph Zales and Charles Cain, attorneys at King & Spalding, discusses ongoing investigations and provides practical guidance for regulated entities and their boards of directors on best practices for formulating and implementing policies and procedures that address disclosure, and on determining what to disclose. The first article reviewed the applicable SEC regulations and guidance, along with the growing body of enforcement actions, including the recently announced Pearson, First American and Cetera cases. See “Six Ways to Be Prepared for the SEC’s Focus on Cybersecurity and Resiliency” (Apr. 15, 2020). 

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