It may be time for Target Corp. to brush up on their Federal securities law. The data breach that affected at least 70 million customers may necessitate a Form 8-K filing with the U.S. Securities and Exchange Commission, according to a post by Adam Veness and Cynthia Larose on Mintz Levin’s Privacy and Security Matters Blog.

The authors explain that this form has mandatory disclosure requirements when certain events occur, such as the resignation of a director or entering material agreements. However, it also has voluntary elements, for when the company needs to disclose an event they “deem of important to security holders.” And they say this is why Target should be getting their pens out to dot the i’s and cross the t’s.