Exploring the Disclosure of Cybersecurity

The SEC has been concerned with cybersecurity disclosures for many years. In 2011, guidance was issued to clarify public companies’ responsibility to disclose cybersecurity issues. The guidance requires public companies to disclose cybersecurity as a Risk Factor for companies that … Continue reading

SEC Questions Internal Controls at Citigroup

On August 1, 2014 Citigroup Inc [C] received a comment letter from the SEC. One of the comments referred to a $235 million after-tax charge resulting from a fraud discovered at its Banco Nacional de Mexico (Banamex) subsidiary, which was recorded during the … Continue reading