Protect your company’s reputation and finances.

As a CFO and CISO of a public company, it is imperative to understand the critical nature of protecting Material Non-Public Information (MNPI). The consequences of a data breach involving MNPI can be severe, both financially and reputationally, and can result in significant regulatory fines.


The regulatory implications for protecting MNPI are significant, with laws such as SEC’s Regulation Fair Disclosure (Reg FD) and SEC Rule 10b5-1 and the Sarbanes-Oxley Act requiring companies to take appropriate measures to protect this sensitive information. Cyber criminals often use MNPI for various forms of cybercrime, such as insider trading or identity theft, and the impact of such activities can be devastating.

2. Risk Management Strategy Disclosure Requirements

  • Description of processes, if any, for the assessment, identification, and management of material risks from cybersecurity threats, including:
  • Whether and how processes have been integrated into the overall risk management system or processes


  • Engagements with assessors, consultants, auditors, or other third parties in connection with any such processes
  • Disclosure of whether any risks from cybersecurity threats have materially affected or are reasonably likely to materially affect their business strategy, results of operations, or financial condition.

3.Governance and Board Expertise Disclosure Requirements

  • Description of the board’s oversight of risks from cybersecurity threat and any devoted committees or subcommittees


  • Description of management’s role in assessing and managing the registrant’s material risks from cybersecurity threats which may include:
  • Management positions or committees are responsible for assessing and managing risks, and the relevant expertise of each person
  • Processes on how management is informed about and monitor the prevention, detection, mitigation, and remediation of cybersecurity incidents
  • How information about such risks to the board of directors or a committee or subcommittee of the board of directors.

Unsecured MNPI Puts You at Risk

 classify inventory of MNPI based on associated risks and impact on the enterprise.

Challenges in Achieving Compliance

Proactively Building Trust

 partnership with the CFO organization to ensure end-to-end holistic MNPI risk management and surveillance processes across business units.

Tangible Outcomes from MNPI Governance

Safeguard Against Market Risk

Prevent disruptions to the company’s market value and safeguard the interests of its stakeholders by securing MNPI at the enterprise level and across business units.

Minimize Regulatory Risk

An integrated MNPI governance program will reduce exposure to regulatory fines, and an improved security posture will lead to better premiums for cyber insurance.

Uphold Company’s Reputation

Misuse of MNPI for corporate espionage is not uncommon. Sustained MNPI governance will retain the trust of stakeholders, board members, and customers and prevent reputational damage.

How BluOcean Addresses This Challenge

BluOcean tackles the MNPI governance challenge with a unique blend of collaboration and expertise. Our approach combines the strategic insights of the CISO and CFO to establish robust policies, controls, and training programs that safeguard sensitive information, minimize risks, and ensure regulatory compliance.


By joining forces, we deliver comprehensive MNPI governance that shields your organization from financial, reputational, and cybersecurity risks—trust BluOcean to provide tailored guidance and unwavering support for sustained MNPI protection.

Our Framework

Uniting CFOs and CISOs for Comprehensive Protection

BluOcean’s MNPI Governance Framework empowers CFOs and CISOs with a collaborative approach to achieve holistic MNPI protection. This framework defines strategic actions for both roles, fostering joint ownership and execution. It focuses on pivotal outcomes, including materiality definition, identification of critical information, adherence to SEC regulations, and fortification against external threats.


The framework prioritizes training and education for the board, employees, and contractors. Implementing consistent policies, standards, blackout periods, and essential processes establishes a sustainable approach to MNPI governance and unwavering protection. Unleash the power of collaboration with the BluOcean MNPI Governance Framework and safeguard your organization’s most sensitive information.


MNPI Governance FAQs

Defining materiality for MNPI can be challenging as it requires aligning on the criteria that determine its significance. CFOs and CISOs often face difficulties in establishing a common understanding and consensus within their organizations. At BluOcean we bring our predefined toolkit of materiality and other industry examples from peers and companies to help CFO and CISO define and establish materiality criterian.

BluOcean helps CFOs and CISOs overcome this challenge by providing guidance and facilitating collaborative discussions to establish a shared understanding of materiality. Our consultants leverage industry best practices and regulatory insights to assist in defining materiality criteria that align with your organization’s unique risk profile and regulatory requirements.

BluOcean helps CFOs and CISOs adapt to evolving regulatory requirements by providing continuous support and guidance. We stay abreast of regulatory changes and industry trends, ensuring your MNPI governance program remains up-to-date and compliant. Our consultants assist in conducting regular assessments, reviewing policies and procedures, and implementing necessary updates to align with changing regulatory landscapes, enabling you to maintain a sustainable and effective MNPI governance program.

Identifying and classifying MNPI across the organization can be a complex task. Challenges may include fragmented data sources, inconsistent classification practices, and a lack of visibility into sensitive information. BluOcean Consulting offers expertise in data discovery and classification techniques, leveraging advanced technologies to streamline the identification and classification process and ensure comprehensive coverage.

BluOcean assists CFOs and CISOs in establishing robust controls and processes for effective MNPI protection. Our approach involves designing tailored control frameworks based on SEC regulatory requirements of Reg-FD and SEC 10B 5-1, implementing access controls and encryption mechanisms, and integrating data loss prevention solutions. We work closely with your organization to develop policies and procedures that align with regulatory requirements and industry best practices, ensuring comprehensive protection of MNPI.

Fostering cross-functional collaboration between CFOs and CISOs can be challenging due to differing priorities, communication gaps, and siloed approaches. BluOcean facilitates collaboration by providing structured frameworks and methodologies that encourage joint ownership and collaboration. We facilitate effective communication channels, promote shared understanding, and establish governance structures that facilitate cross-functional collaboration.

Contact Us

Interested in working together? Fill out some info, and we will be in touch shortly.

First Name(Required)
Last Name
This field is for validation purposes and should be left unchanged.

Join Thousands of weekly readers

Enter your email for instant access to our EXCLUSIVE ebook & discover the Roadmap for Moving to ROI-Led Cyber Risk Management.

This field is for validation purposes and should be left unchanged.