Gibson Dunn’s “Cybersecurity Overview: A Survey of Form 10-K Cybersecurity Disclosures by the S&P 100 Companies” details Regulation S-K Item 106 cybersecurity disclosure trends across the areas of cybersecurity risk management and strategy; cybersecurity governance; and material cybersecurity risks, threats, and incidents, based on the firm’s analysis of S&P 100 Form 10-K filings as of November 30, 2024. Coverage includes disclosure presentation and length, as well as a summary of Item 1C SEC comment letter exchanges (which we include in the weekly Society Alerts).
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