John Crozier, left, and Katayun I. Jaffari, right, of Cozen O'Connor. Courtesy photos John Crozier, left, and Katayun I. Jaffari, right, of Cozen O'Connor. Courtesy photos

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Introduction

On June 24, the Securities and Exchange Commission (SEC) issued new compliance and disclosure interpretations (C&DIs) providing additional guidance on cybersecurity incident reporting pursuant to Item 1.05 of Form 8-K. These C&DIs follow four C&DIs published by the SEC in December 2023 relating to disclosure obligation considerations after holding discussions with the U.S. Attorney General about the occurrence of a cybersecurity incident.