Davis Polk partner Robert Cohen was quoted in a Cybersecurity Law Report article discussing how companies can comply with the proposed Form 10-K filing standards for annual reporting. “Companies have put a lot of time into evaluating their disclosures,” Robert noted. “I see companies taking a fresh look and making sure that their disclosures reflect accurately the types of risks that they have been seeing.”

Robert continued, “Certainly, the SEC, and I don’t think anyone else, wants boilerplate disclosures that are uniform across companies and industries and don’t tell investors anything unique. That said, cybersecurity risks are very similar across different companies.”

SEC Cyber Rules: How to Prepare for the New 10-K Disclosure Mandates,” Cybersecurity Law Report (August 17, 2022)