By now, CFOs understand that the SEC’s final rule on cybersecurity disclosure requires public companies to give investors prompt, “decision-useful” information about material cybersecurity incidents, as well as periodic information on their approaches to cyber risk management, strategy and governance. What they may not fully appreciate is the holistic, collaborative approach required to meet the new disclosure requirements. CFOs may encounter challenges in applying “materiality” to cyber risks and cyber incidents. They may also face similar uncertainties in assessing their company’s cyber risk management, strategy and governance.

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