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Vulnerability Disclosure Policy

May 19, 2020

The U.S. Securities and Exchange Commission (“SEC”) is committed to maintaining the security of our systems and protecting sensitive information from unauthorized disclosure.

This policy describes what systems and types of security research are covered under this policy, how to send us vulnerability reports, and how long we ask security researchers to wait before publicly disclosing vulnerabilities.

We encourage security researchers to contact us to report potential vulnerabilities identified in SEC systems.  For reports submitted in compliance with this policy, the SEC will acknowledge receipt within three business days, endeavor to timely validate submissions, implement corrective actions if appropriate, and inform researchers of the disposition of reported vulnerabilities.

If you make a good faith effort to comply with this policy during your security research, we will consider your research to be authorized, we will work with you to understand and resolve the issue quickly, and we will not recommend or pursue legal action related to your research.

Test Methods

Security researchers must not:

  • Test any system other than the systems set forth in the ‘Scope’ section below,
  • disclose vulnerability information except as set forth in the ‘Reporting a Vulnerability’ and ‘Disclosure’ sections below,
  • engage in physical testing of facilities or resources,
  • engage in social engineering,
  • send unsolicited electronic mail to SEC users, including “phishing” messages,
  • execute or attempt to execute “Denial of Service” or “Resource Exhaustion” attacks,
  • introduce malicious software,
  • test in a manner which could degrade the operation of SEC systems; or intentionally impair, disrupt, or disable SEC systems,
  • test third-party applications, websites, or services that integrate with or link to or from SEC systems,
  • delete, alter, share, retain, or destroy SEC data, or render SEC data inaccessible, or,
  • use an exploit to exfiltrate data, establish command line access, establish a persistent presence on SEC systems, or “pivot” to other SEC systems.

Security researchers may:

  • View or store SEC nonpublic data only to the extent necessary to document the presence of a potential vulnerability.

Security researchers must:

  • cease testing and notify us immediately upon discovery of a vulnerability,
  • cease testing and notify us immediately upon discovery of an exposure of nonpublic data, and,
  • purge any stored SEC nonpublic data upon reporting a vulnerability.

Scope

The following systems / services are in scope:

Any services not explicitly listed above are excluded from scope.  Additionally, vulnerabilities found in non-federal systems from our vendors fall outside of this policy’s scope and should be reported directly to the vendor according to its disclosure policy (if any).

Reporting a Vulnerability

Reports are accepted via electronic mail at security@sec.gov.  Acceptable message formats are plain text, rich text, and HTML.

Reports should provide a detailed technical description of the steps required to reproduce the vulnerability, including a description of any tools needed to identify or exploit the vulnerability.  Images, e.g., screen captures, and other documents may be attached to reports.  It is helpful to give attachments illustrative names.  Reports may include proof-of-concept code that demonstrates exploitation of the vulnerability. We request that any scripts or exploit code be embedded into non-executable file types.  We can process all common file types, and also file archives including zip, 7zip, and gzip.

Researchers may submit reports anonymously. Or, researchers may provide contact information, and any preferred methods or times of day to communicate, as they see fit.  We may contact researchers to clarify reported vulnerability information or other technical interchange.

The SEC prefers that vulnerability report messages be encrypted.  We utilize opportunistic Transport Layer Security (TLS) for both incoming and outgoing electronic mail.  Reporters may opt to use OpenPGP standard cryptography for message encryption.  The SEC PGP public key may be downloaded in ASCII Armor Format at BDC829CF.asc.  PGP Key Properties are as follows:

Key ID: BDC829CF
Key Type: RSA
Created: 2020-04-27
Expires: 2022-04-30
Key Size: 4096

Key Fingerprint: 018A E8C8 CBDB B9D7 2EF7 E822 8AE0 D0A6 BDC8 29CF
UserID: US Securities and Exchange Commission – Security <security@sec.gov> 

By submitting a report to the SEC, researchers warrant that the report and any attachments do not violate the intellectual property rights of any third party and the submitter grants the SEC a non-exclusive, royalty-free, world-wide, perpetual license to use, reproduce, create derivative works, and publish the report and any attachments.

Disclosure

The SEC is committed to timely correction of vulnerabilities.  However, we recognize that public disclosure of a vulnerability in absence of a readily-available corrective action likely increases versus decreases risk.  Accordingly, we require that you refrain from sharing information about discovered vulnerabilities for 90 calendar days after you have received our acknowledgement of receipt of your report.  If you believe others should be informed of the vulnerability prior to our implementation of corrective actions, we require that you coordinate in advance with us.

We may share vulnerability reports with the Cybersecurity and Infrastructure Security Agency (CISA), as well as any affected vendors.  We will not share names or contact data of security researchers unless given explicit permission.

Questions

Questions regarding this policy may be sent to security@sec.gov.  The SEC encourages security researchers to contact us for clarification on any element of this policy.  Please contact us prior to conducting research if you are unsure if a specific test method is inconsistent with or unaddressed by this policy.  We also invite security researchers to contact us with suggestions for improving this policy.

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