New SEC cyber proposal: How could it change current reporting?

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On March 9, the SEC published a proposed rule addressing disclosures related to a company’s cybersecurity risk management, strategy, governance, and incidents.

Heather Horn was joined by Kyle Moffatt, a partner in PwC’s National Office, to discuss the potential impacts of the proposal and what could change in companies’ current reporting for cybersecurity.

In this episode, you will hear:

• 1:20 - An overview of the current disclosure guidance and what would change under the proposed rule
•  5:42 - How the proposed rule would address insider trading, and a discussion on the landscape of cyber-related comment letters
• 8:54 - The impetus for the proposed rule, and how the current regulatory environment influenced its creation
• 12:48 - Key changes to incident reporting, and how the new rules try to create comparable disclosures across companies
• 19:22 - Cyber risk management and strategy: how the new rule is intended to impact behaviors
• 24:42 - Governance and oversight disclosures, including a new requirement to include directors’ and management’s cybersecurity expertise
• 28:58 - Potential challenges that companies may face in preparing the proposed new disclosures
• 32:54 - The importance of focusing on disclosure readiness, controls, policies, and procedures to comply with the new rules once enacted

Want to learn more? Read the proposed rule on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure.

Kyle Moffatt is a partner in PwC's National Office where he consults with engagement teams and audit clients on SEC reporting matters. He joined PwC in 2020 after spending almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance.

Heather Horn is PwC’s National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC’s accounting and reporting weekly podcast and quarterly webcast series, as well as periodic webcasts for the power and utilities industry. With over 30 years of experience, Heather’s accounting and auditing expertise includes financial instruments and rate-regulated accounting.

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