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ARTICLE · 27 JUNE 2019

Market Trends 2018/19: Cybersecurity Related Disclosures

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This market trends article identifies comprehensive disclosures related to cybersecurity risks, including discussions about the potential reputational

United StatesTechnology

This market trends article identifies comprehensive disclosures related to cybersecurity risks, including discussions about the potential reputational, financial, or operational harm resulting from cybersecurity breaches; the potential associated litigation or regulatory costs; and their policies and procedures addressing cybersecurity incidents, and concludes with practical advice on preparing the required disclosures regarding cybersecurity risks and incidents. The company name, its industry, and the type of filing are also provided in each sample disclosure for reference.

On October 16, 2018, the Securities and Exchange Commission (SEC) released a report of investigation pursuant to Section 21(a) of the Securities Exchange Act of 1934 (the Exchange Act) detailing its investigation of several public companies that were victims of cybersecurity related frauds. While the SEC decided not to pursue enforcement actions against these companies, it emphasized the duty of

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