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Subject: Inquiry Request: Validating and Applying a Tiered Hardening Compliance Framework (70/85/95%) for a Colombian FPI's IPO

Dear Community,

My name is Viviana from a Insurance Company in Colombia. We are at a crucial point in our preparation for an Initial Public Offering (IPO) on the NYSE and are seeking your expert guidance to refine our hardening strategy for operating systems and databases.

Context and Objective:

We are an established Colombian health and insurance company with an 80+ year history. Our objective is to list on the NYSE as a Foreign Private Issuer (FPI), making us subject to regulations from the SFC (Superintendencia Financiera de Colombia) and Law 1581 (Data Protection) in Colombia, as well as the disclosure requirements of the SEC in the United States. A key challenge is our significant technical debt, with critical legacy systems supporting core business functions.

Proposed Internal Framework:

Our technical team has proposed adopting a common industry framework to measure hardening compliance based on the CIS Benchmarks. We wish to validate the application of this framework:

* Tier 1 (70-80%): Considered an acceptable baseline or for initial phases.
* Tier 2 (85-90%): The recommended target for production systems handling sensitive data.
* Tier 3 (95-100%): The ideal goal for mission-critical environments and high maturity.

Strategic Questions for an Inquiry Session:

1. Regarding Framework Application and Regulatory Compliance:

a. Given our complex environment mixing modern and legacy systems, we face an internal debate: Could an across-the-board compliance level of 80% be considered sufficient for initial regulatory purposes with the SFC and SIC (Superintendencia de Industria y Comercio), or would this be immediately interpreted as a material weakness during the IPO due diligence process?

b. On the opposite end, for our most critical systems handling sensitive data, do you believe the Tier 3 target (95-100%) should be considered a **mandatory requirement** to demonstrate due diligence to investors and regulators?

c. And for the intermediate case of a critical legacy system that cannot meet the Tier 2 target (85-90%), is the strategy of **documenting compensating controls** (e.g., micro-segmentation, PAM) to cover the gaps an accepted and defensible approach in the view of an auditor?

2. Regarding Defensibility and Communication:

a. When making disclosures in the SEC Form 20-F, is it advisable to use these percentages? Or is it wiser to describe the risk management program qualitatively, explaining how configuration weaknesses are identified, prioritized, and mitigated?

b. For the **SFC in Colombia**, which references frameworks like ISO 27001, is demonstrating compliance via this percentage-based model sufficient, or would they expect a more formal integration into an Information Security Management System (ISMS)?

3. Regarding Risks and Best Practices:

a. What is the most common mistake companies make when using these types of compliance percentage models?

b. What alternative or complementary metrics do you suggest to demonstrate the effectiveness of a hardening program beyond a simple percentage score?

We look forward to leveraging your expert perspective to ensure our strategy is not only technically sound but also strategically intelligent and defensible for the demanding IPO process.

Thank you for your time.

Sincerely,
Viviana Acevedo