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In late June, the #SEC’s Division of Corporation Finance released new compliance and disclosure interpretations regarding the disclosure of material #cybersecurity incidents under Item 1.05 of Form 8-K, focusing on ransomware payments. Key points include: - Returning to normal operations or recovering data does not negate the need for materiality assessments - Insurance coverage for ransom payments is a consideration but not determinative - The size of a ransom payment alone is not determinative—long-term impacts must be considered - Multiple related cyber incidents over time could collectively be deemed material Companies should reassess their materiality determination processes and ensure robust policies are in place. Preparing now can mitigate risks and ensure compliance during an actual incident. #privacy 🖊️ Sadia Mirza, CIPP/US, CIPM, David Meyers, Jay Dubow, Ronald Raether, and Casselle Smith McKoy 🔗 https://lnkd.in/dvegfeDc

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