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SEC's Expanded Cybersecurity Guidance Focuses on Insider Trading, Internal Controls

February 22, 2018, The Recorder

Keir Gumbs is quoted by The Recorder in an article regarding the SEC's recently issued guidance on cybersecurity. Gumbs says that he is disappointed the guidance does not give more clarity about how to determine when a cyber breach is material—or provide any kind of safe harbor for companies that make good-faith determinations about the scope of a breach that later turn out to be incorrect. “In every case that I’ve ever worked on, the initial assessment is wrong. You always think the cyber breach is smaller than it is,” Gumbs says. “From a practical perspective, I don’t think the landscape has changed very much by this guidance.”

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