What changed in this filing

/stocks — the workspaceLOADING

Item 1B. Unresolved Staff Comments

2026-02-19 compared with 2025-02-27 · 23 added, 38 removed, 57 unchanged (52% of the section changed)

23 unchanged sentences

We assess our cybersecurity risk management program at least annually and regularly review our cyber incident response plan.

Our processes and policies also include the identification of those third-party relationships which have the greatest potential to expose us to cybersecurity threats.

Our processes and policies also include the identification of those third-party relationships that have the greatest

potential to expose us to cybersecurity threats.

We also partner with industry leading third parties for regular security audits to ensure we view cybersecurity with a holistic perspective.

14 unchanged sentences

“Risk Factors — Risks Related to Information Technology, Cybersecurity, and Data Protection.”

Since August 2020, our Vice President, Chief Information Security Officer (“ CISO ”) has led a team of information security professionals who have the first line responsibility for our cybersecurity risk management processes and activities.

Since August 2020, our Senior Vice President, Infrastructure, Support Services, and Chief Information Security Officer (“ CISO ”) has led a team of information security professionals who have the first line responsibility for our cybersecurity risk management processes and activities.

Our CISO has more than 20 years of experience as an information security leader responsible for assessing and managing cybersecurity programs.

He reports directly to our Executive Vice President, Chief Information and Digital Officer, who

reports to our Chief Executive Officer, has over 25 years of experience managing global information technology operations, including strategy, application, infrastructure, information security, support, and execution.

In performing his role, our CISO regularly performs the following:

review of enterprise cybersecurity risks, controls, program policy, processes, and training;

oversight of policy and program development, implementation, and updates;

and information to senior leadership about cybersecurity-related issues and activities affecting the organization.

Our CISO is regularly apprised of enterprise cybersecurity events, threats, and activities, including with respect to incidents, protection vulnerabilities, software update needs, and lifecycle status.

He possesses a deep understanding of evolving cybersecurity threats, technologies, and industry best practices to identify cybersecurity risks and threats and assess and guide mitigation strategies effectively.

Relevant cyber certifications include Certified Information Systems Security Professional and Certified Information Security Manager.

Certifications of our cybersecurity professionals include, but are not limited to:

Certified Information Systems Security Professionals from the International Information System Security Certification Consortium;

Certified Information Security Manager from Information Systems Audit and Control Association;

and focused training/certifications from security vendors on the applications utilized in the management of our cybersecurity program.

The certifications mentioned above are accompanied by multiple years of direct experience in cybersecurity which provide the framework for the team’s continuous learning of new technologies, processes, trends, and concepts, with additional training obtained through relevant cybersecurity focused conferences.

We have implemented a robust cybersecurity risk governance model, including the formation of the Cybersecurity Governance Committee chaired by our CISO and composed of key leaders from stakeholder groups throughout our company including our President and Chief Operating Officer, Chief Legal Officer, Chief Compliance Officer, and the head of internal audit, along with other senior members of management.

Experience of key members of the committee includes:

• Our President and Chief Operating Officer, who joined the Company as Chief Operating Officer in November 2017 and has served in his current role since March 2023, has over 25 years of commercial and strategic leadership experience.

He excels at identifying and mitigating operational risks, including cybersecurity threats that could disrupt critical business processes.

His contributions to the Cybersecurity Governance Committee include aligning cybersecurity initiatives with broader business strategies and ensuring cybersecurity considerations are integrated into information technology infrastructure and operations.

• Our Chief Legal Officer, serving since August 2015, brings extensive experience as the top legal executive across various organizations.

At Invitation Homes, he oversees all legal and regulatory affairs, including direct supervision of the risk management department.

His expertise includes advising on governance frameworks, supporting board oversight of cybersecurity risk management, and addressing litigation trends and risks associated with cybersecurity breaches.

• Our Chief Compliance Officer, who joined the Company in July 2016 and has served in her current role since July 2024, is an experienced public company counsel with over 20 years of combined private practice and in-house experience.

She provides expertise in SEC regulations and disclosure requirements, including cybersecurity-related guidance, and ensures compliance with legal standards for disclosing material cybersecurity risks and incidents.

In collaboration with internal audit, she helps oversee our ERM program to align cybersecurity initiatives with broader business strategies.

She also brings a thorough understanding of breach notification requirements and regulatory responses to cybersecurity incidents.

• Our Vice President of Internal Audit, serving since November 2017, brings specialized expertise in identifying internal threats and potential fraud related to cybersecurity through advanced audit techniques.

She is skilled in aligning cybersecurity risk assessments with our ERM framework and monitoring the implementation of cybersecurity audit recommendations to ensure their effectiveness over time.

Our CISO reports directly to our Senior Vice President, Head of Technology, who reports to our Chief Executive Officer, and has over 25 years of experience managing global information technology operations, including strategy, application, infrastructure, information security, support, and execution.

In performing his role, our CISO oversees cybersecurity risk assessments, policy development, training, and incident reporting, while applying industry best practices to identify cybersecurity risks and threats and assess and guide mitigation strategies effectively.

Relevant cyber certifications of our CISO include Certified Information Systems Security Professional (“CISSP”) and Certified Information Security Manager (“CISM”).

Our cybersecurity team holds certifications such as CISSP and CISM, supplemented by vendor-specific training and ongoing education.

We have implemented a robust cybersecurity risk governance model, including the Cybersecurity Governance Committee chaired by our CISO and composed of senior leaders including these key members:

• Chief Operating Officer — Over 25 years of commercial and strategic leadership experience;

skilled in identifying operational and cybersecurity risks and ensuring alignment of security initiatives with business objectives and technology infrastructure.

• Chief Legal Officer — Extensive experience as top legal executive;

oversees legal and regulatory affairs, including risk management;

advises on governance frameworks and board oversight of cybersecurity risk.

• Chief Compliance Officer — Over 20 years of legal experience;

expertise in SEC regulations and disclosure requirements for cybersecurity risks and incidents;

oversees ERM program alignment of cybersecurity initiatives with business strategy.

• Vice President of Internal Audit — Specialized in detecting internal threats and fraud through advanced audit techniques;

integrates cybersecurity risk assessments into ERM and monitors audit recommendations for effectiveness.

The Cybersecurity Governance Committee meets quarterly to review the processes and performance indicators related to prevention, detection, mitigation, and remediation of cybersecurity incidents that could adversely impact business operations.

We maintain a cross-functional cyber incident response plan with defined roles, responsibilities, and reporting protocols, which focuses on responding to and recovering from any significant breach as well as mitigating any impact to our business.

Generally, when a breach or suspected breach is identified, the information security team would escalate the issue to the Cybersecurity Governance Committee for initial analysis and guidance.

The Cybersecurity Governance Committee, in

consultation with appropriate subject matter experts, would be responsible for determining whether a particular incident alone or in combination with other factors, triggers any reporting and/or further notification responsibilities.

The Cybersecurity Governance Committee would designate the primary manager of a cybersecurity incident, identify the parties who should be informed about the incident, and oversee the processes for containment, eradication, recovery, and resolution of the incident.

Significant breaches are escalated to the Cybersecurity Governance Committee for analysis and guidance.

The Cybersecurity Governance Committee then determines reporting obligations, designates an incident manager, and oversees containment, eradication, and recovery.

Depending on the severity and impact of a cybersecurity threat, the audit committee and the board of directors would be notified of an incident and kept informed of the mitigation and remediation efforts.

Our CISO and other senior members of information technology personnel regularly report to the audit committee and the board of directors on recent trends in cyber risks and review our strategy to defend our business systems and information against cyber-attacks.

In addition to providing periodic reports, at least semi-annually, our CISO and other senior members of information technology personnel report to the audit committee and the board of directors on recent trends in cyber risks and review our strategy to defend our business systems and information against cyber attacks.

From time to time, outside advisors may be invited to brief the audit committee on the current cybersecurity threat landscape and other related topics.

Our board of directors has an advanced understanding of its role and that of management in cyber-risk oversight and is well positioned to guide management in the development and implementation of an effective cybersecurity risk program.

Two members of our audit committee hold cybersecurity certifications:

Sears holds a Cyber Risk and Strategy Certification from Diligent Institute;

Barbe holds a CERT Certificate in Cybersecurity Oversight from the National Association of Corporate Directors.

Barbe, the chairperson of the nominating and corporate governance committee of the board, holds a CERT Certificate in Cybersecurity Oversight from the National Association of Corporate Directors.

Howard, a member of the audit committee, brings extensive practical experience in, and domain expertise related to, cybersecurity, shaped by his prior service with the SEAL teams and Joint Special Operations of the United States Navy.

As part of its overall risk oversight activities, with respect to cybersecurity risk management, the audit committee:

10 unchanged sentences

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments