CCMC letter to SEC on Extending Cyber Rule Implementation Date

We appreciate the time that the Division of Corporation Finance spent with members of the American business community—including members and non-members of the U.S. Chamber of Commerce (the “U.S. Chamber”) on November 8, 2023, to discuss the Securities and Exchange Commission’s Cybersecurity Risk Management, Strategy, Government and Incident Disclosure Rule adopted in July 2023 (the “Final Rule”). 1 While the meeting was productive in several respects, we remain concerned that the effective date of the Final Rule—as soon as mid December in some cases—likely will arrive before impacted entities can institute procedures to ensure compliance, among other issues.