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Getting ready for the SEC’s new cybersecurity disclosure rules


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In this episode, we discuss the SEC’s new cybersecurity disclosure rules finalized in July. 

The new disclosure rules expand registrants’ annual disclosures and require timely reporting for material cybersecurity incidents. With these significant changes and the implementation approaching, companies should not wait to get ready. 


This week, Heather Horn is joined by Kyle Moffatt, PwC National Office Professional Practice Leader, and Matt Gorham, PwC Cyber & Privacy Innovation Institute Leader, to discuss what companies can do to prepare now for the new requirements.


In this episode, you’ll hear discussion of:

  • 4:28 - Why cybersecurity is an area of focus for the SEC 
  • 8:03 - A summary of the SEC’s new cybersecurity rules and disclosure requirements
  • 10:21 - Types of cyber incidents, including what’s required to be disclosed in the Form 8-K and how companies should think about “material” impacts
  • 12:58 - The importance of developing relationships with federal law enforcement and how smaller companies can start to build those relationships
  • 20:19 - An ideal sequence of action steps when a cyber incident occurs
  • 24:32 - Top considerations when preparing to disclose in accordance with the SEC’s cybersecurity rules
  • 33:10 - Key takeaways for companies reviewing their processes and preparing for the new disclosure requirements

Looking for more information on cybersecurity? Check out our publication and register for our Q3 2023 Quarterly accounting webcast for a detailed discussion of the SEC’s cybersecurity rules with Kyle; PwC Vice Chair, Wes Bricker; and Raquel Fox, Partner & Co-Head of SEC Reporting and Compliance; Capital Markets; M&A; Corporate Governance at Skadden, Arps, Slate, Meagher & Flom LLP and Affiliates. 

Kyle Moffatt is PwC’s Professional Practice leader, leading a team responsible for working with standard setters and regulators as well as delivering brand-defining thought leadership and educational materials. He also consults with engagement teams and audit clients on SEC reporting matters. Before PwC, Kyle spent almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance.


Matt Gorham is PwC Cyber & Privacy Innovation Institute Leader, providing thought leadership, perspective, and analysis on trends affecting all aspects of cybersecurity and privacy. He has over three decades of experience mitigating threats through building and leading cross functional teams. Before PwC, Matt spent 25 years with the FBI as the Assistant Director of Cyber.


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. With over 30 years of experience, Heather’s accounting and auditing expertise includes financial instruments and rate-regulated accounting.


Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to [email protected].

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