Cybersecurity disclosure
5 staff comments in this corpus, to 4 registrants, filed 2023-01-25 to 2023-03-24.
Corpus in progress. This is an early build. It does not yet cover every comment letter the SEC has published, so counts here are counts within this corpus and must not be read as complete SEC-wide totals. Every quotation is verbatim and links to its filing; what is incomplete is coverage, not accuracy. See Methodology.
| Measure | Value |
|---|---|
| Comments raising this issue | 5 |
| Share of all 4,297 comments in the corpus | 0.1% |
| Distinct registrants | 4 |
| With a recorded company response | 5 |
The exchanges
SEC staff comment
7. Please describe the extent and nature of the role of the board of directors in overseeing cybersecurity risks, including in connection with the company’s supply chain/suppliers/service providers.
The company responded
The Company acknowledges the Staff’s comment and has revised the disclosure on pages 52 and 53 of the Amended Registration Statement. Summary of Financial Analysis, page 131
Ares Acquisition Corp · filed 2023-03-24 · 0001104659-23-036682
SEC staff comment
1. We note your response to prior comment 2 and reissue it, in part. Please highlight the risk that you may be liable for any cybersecurity breach resulting in the loss of customer assets.
The company responded
We have updated the registration statement to include that we may be liable for any cybersecurity breach resulting in the loss of customer assets. 2. We note your response to prior comment
APPlife Digital Solutions Inc · filed 2023-03-22 · 0001096906-23-000626
SEC staff comment
2. We note your indication that the PRC subsidiaries are not required to obtain any permission or approval from the CSRC and CAC for the business operations within the territory of PRC. Explain the basis for this conclusion, especially considering your disclosure on page 66 suggests that you have sought approval from the Cybersecurity Review Office as to whether a cybersecurity review is required. In this regard, we note that you do not appear to have relied upon an opinion of counsel with respect to your conclusions that you do not need any additional permissions and approvals to operate your business and to offer securities to investors. If true, state as much and explain why such an opinion was not obtained.
The company responded
In response to the Staff’s comment, the Company has revised relevant disclosure on Page 15 of the F-4 under “CSRC Filing Requirements and Security Review Measures Associated with Listing Outside of PRC” regarding potential regulatory compliance requirement recently posed under the PRC Laws.
Able View Global Inc. · filed 2023-03-17 · 0001213900-23-021082
SEC staff comment
6. Please expand your discussion of the security precautions you will take to keep your customers crypto assets secure and highlight the risk that you may be liable for any cybersecurity breach resulting in the loss of customer assets. Additionally, given that the wallets will be non-custodial, please provide more detail on how the "cold storage" feature will work.
The company responded
It is simply too early to answer some of the questions you are asking about the cold wallet, security, or any segment that will first require our fully funding the build-out with the next stage development team in place and then planning the structuring of the writing of the code. That’s where we will see the newest and latest security technology, the best options for cold wallet storage and the most user friendly UX as it’s becoming more integrated with everyday users. It is our intention to build a highly secure, easy to use, non-custodial wallet. We plan to bring in the most advanced technology for security when we begin writing the code. We will have a cold wallet system that allows the users to transfer between storage and active modes and plan to include2FA, fingerprint and/or facial recognition technology. We plan to have multiple additional security daemons that review account…
APPlife Digital Solutions Inc · filed 2023-03-06 · 0001096906-23-000486
SEC staff comment
Comment: Please consider adding cybersecurity risk to the Fund’s principal investment risks.
The company responded
In response to this comment, the Registrant will add cybersecurity risk to the Fund’s principal investment risks. Portfolio Managers 11.
Datum One Series Trust · filed 2023-01-25 · 0001193125-23-015291