reasoning: The paragraph primarily describes a real cybersecurity incident, including how it occurred through PBI's use of MOVEit, the company's response, the scope of affected data, and the operational impact assessment. Although it begins with disclosure procedures and ends with a materiality statement, the main substance is the incident narrative itself.


content_category: Board Governance

category_confidence: high

specificity_confidence: medium

reasoning: The paragraph is primarily about oversight by the Audit Committee and its reporting to the Board, so Board Governance is the best fit. It includes firm-specific facts such as the presence of a CISO and a specific 2023 interaction detail, but not enough qualifying hard verifiable facts to reach Quantified-Verifiable.

provider: openai

stage: benchmark


content_category: Risk Management Process

specificity_confidence: high

reasoning: The paragraph primarily describes the company's internal cybersecurity risk management activities and response coordination process, with the managed service provider mentioned as one component of that process rather than as the central topic of vendor oversight. It contains no qualifying specific facts such as named roles, named firms, frameworks, dates, or quantified details.


reasoning: The paragraph is primarily about how the Board and its committee receive cybersecurity oversight information and education, making Board Governance the best fit. It includes one firm-specific fact—a CISO role involved in Board presentations—but otherwise relies on largely generic governance language.


content_category: Management Role

category_confidence: medium

reasoning: The paragraph is primarily about management personnel being prepared to assess and manage cybersecurity risk through briefings and experience, rather than describing the company’s broader risk management process. It does not include any qualifying specific facts such as named cybersecurity roles, firms, dates, certifications, or other verifiable details.


reasoning: The paragraph primarily describes how the Board is involved in oversight of cybersecurity matters, with management reporting up to the Board. Although management roles are mentioned, the main thrust is governance and escalation to the Board rather than qualifications of a specific cybersecurity officer.


content_category: Incident Disclosure

reasoning: The paragraph primarily describes a real cybersecurity incident, including the notification, investigation, affected data, and operational impact, so Incident Disclosure is the best fit. It includes multiple verifiable specifics, including a precise filing date, a named incident/system, a named external party, and a quantified number of affected individuals.


content_category: Strategy Integration

reasoning: The paragraph’s only company-specific substantive point is that the bank has not experienced material incidents, which is best treated as a materiality/status disclosure rather than a description of risk management processes or governance. The rest of the paragraph is largely regulatory background.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk assessment and management processes, including integration into enterprise risk management. Although board oversight is mentioned, it is secondary to the discussion of the company's own processes.


reasoning: The paragraph is primarily about FIS’s internal cybersecurity risk identification, remediation, escalation, and ERM integration processes, even though it also references board oversight and management roles. It includes firm-specific details and at least two verifiable facts, notably the CISO’s 15+ years of experience and CISSP certification.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management activities, including monitoring, insider threat efforts, training, assessments, and response preparedness. Although third-party and supplier oversight is mentioned, it appears as one component of the broader internal process rather than the central topic.


reasoning: The paragraph focuses on the Bank's internal cybersecurity risk management activities, including layered controls, assessments, scans, testing, incident response planning, and integration with risk management. It does not center on board oversight, a specific management person, third-party oversight, or an actual incident.


content_category: Third-Party Risk

reasoning: The paragraph is centrally about how the company oversees cybersecurity risks posed by third-party service providers, including onboarding, renewal, and contractual security requirements. It does not include any named vendors, frameworks, dates, tools, or other firm-specific facts.


reasoning: The paragraph describes the company's cybersecurity monitoring and response processes, including prevention, detection, mitigation, and remediation. Although it mentions third-party service providers, vendor risk is only a component of the broader internal risk management process, not the central topic.


reasoning: The paragraph’s main point is a high-level statement about the absence of material cybersecurity incidents and the possibility of future incidents, rather than describing governance, management roles, or risk processes. It does not disclose a specific incident or any concrete firm-specific details.


reasoning: The paragraph describes the company's internal cybersecurity practices—risk assessments and an incident response plan—so it is best categorized as Risk Management Process. It contains no qualifying specific facts such as named frameworks, roles, dates, firms, tools, or other firm-unique details.


reasoning: Although the paragraph opens with Board oversight, most of the substance describes the company's own cybersecurity program, its integration into operations, and how risks are identified, prevented, mitigated, and responded to. The only concrete specific details are references to recognized frameworks, which supports Sector-Adapted rather than Firm-Specific.


reasoning: The paragraph primarily describes the company’s internal cybersecurity function and activities—risk measurement, prevention, detection, mitigation, remediation, and reporting of incidents—so it is best categorized as Risk Management Process. Although a management title is mentioned, the focus is on what the IT/security function does rather than the individual’s qualifications or background.


reasoning: The paragraph describes the company’s internal cybersecurity practices for identifying, testing, and remediating vulnerabilities, so it is primarily about risk management processes. Although it mentions reporting to management and the board, board oversight is not the main subject.


reasoning: The paragraph is primarily about the company’s internal cybersecurity risk identification and assessment activities, not the qualifications or reporting lines of specific executives. Although management roles are mentioned, the substance focuses on monitoring, threat assessment, vulnerability assessment, and tabletop exercises as part of the risk management process.


reasoning: Although the paragraph includes board oversight language, the primary focus is the CISO’s leadership, experience, reporting structure, and responsibilities, making Management Role the best fit. It contains multiple hard verifiable facts, including specific dates and a quantified experience figure.


reasoning: The paragraph describes an actual cybersecurity incident, including unauthorized access, malware deployment, data exfiltration, and the scope of impact. It includes two specific dates, which makes the disclosure quantified and externally verifiable.


reasoning: The paragraph’s most substantive disclosure is the materiality-oriented statement that the company has not experienced any material cybersecurity incidents, along with a risk-factor cross-reference. Mentions of the CFO, board, and Audit Committee are secondary and generic rather than the main focus.


reasoning: The paragraph is primarily about board-level oversight, with the board and its Risk Committee described as overseeing the cybersecurity program and receiving reports on cyber matters. Although it also includes management-role details about the CISO, those details support the governance discussion rather than displacing the board-oversight focus.


reasoning: The paragraph describes the company's internal information security processes for identifying, assessing, and managing cybersecurity risks across its systems and data. References to third-party hosted services are only one component of the internal risk scope, so the central topic remains risk management process.


reasoning: The paragraph focuses on cyber risk insurance coverage and the potential financial limits of that coverage, which falls under strategy and financial risk integration rather than incident details or operational processes. It contains no qualifying specific facts such as amounts, dates, named insurers, or other firm-unique verifiable details.


reasoning: The paragraph primarily describes the company's internal cybersecurity controls and processes, including technical safeguards, incident response planning, training, and third-party risk as one component of the overall program. Although third-party risk is mentioned, the central topic is the company's broader risk management process.


reasoning: The paragraph describes the company's internal cybersecurity processes and controls for identifying, assessing, and mitigating cyber risk, which fits Risk Management Process. It contains only generic practices and vague cadences, with no qualifying named roles, frameworks, dates, firms, tools, or other firm-specific facts.


reasoning: The paragraph is primarily about the Board of Directors overseeing cybersecurity policies and receiving updates from management, making board oversight the central topic. It contains only generic governance language and no qualifying specific facts such as named committees, cyber-specific roles, frameworks, dates, or quantified details.


reasoning: The paragraph is primarily about oversight by the Audit Committee and Board, making board governance the central topic. Although it mentions the CISO, that mention serves to describe the reporting flow into board-level oversight rather than focusing on the management role itself.


reasoning: The paragraph is centrally about how the company evaluates and manages cybersecurity risk from third-party service providers, including vendor diligence and contractual requirements. It contains no named vendors, frameworks, dates, committees, roles, or other qualifying specific facts.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management approach, including integration into risk oversight and use of an incident response plan. It does not center on board oversight, a specific management role, third-party risk, or any actual cyber incident.


reasoning: The paragraph is centrally about oversight of third-party providers, including pre-engagement assessments and ongoing monitoring for compliance with cybersecurity standards. It does not include any named roles, firms, frameworks, dates, or other firm-specific details.


reasoning: The paragraph is framed around actions taken following an incident, including forensic investigation, remediation steps, and the status of affected domain/DNS/email operations, which makes incident response the central topic. Although it ends with a materiality statement, the main substance is the company’s post-incident response and stabilization measures.


reasoning: The paragraph primarily describes the company’s internal cybersecurity activities—monitoring systems, deploying security measures, audits, and incident response planning—so it is best categorized as Risk Management Process. Although the CISO and CIO are mentioned, the focus is on what the program does rather than on the individuals’ qualifications or reporting roles.


reasoning: The paragraph's main point is a materiality assessment stating that cybersecurity risks have not materially affected the company to date, with a forward-looking caveat. It does not describe governance, management roles, or a concrete incident, and the cross-reference to Risk Factors is secondary.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes, specifically integration with enterprise risk management and use of a cybersecurity framework. Its only qualifying specific fact is the named NIST CSF framework, which makes it sector-adapted rather than firm-specific.


reasoning: The paragraph mainly describes the company’s internal incident identification, assessment, and response process. Although the VP of IT is named, the focus is on what the function does operationally rather than the person’s qualifications or reporting line.


reasoning: The paragraph primarily gives a materiality assessment about known cybersecurity threats and prior incidents, stating they have not materially affected the company and could materially affect operations or financial condition if realized. The rest is a risk-factor cross-reference rather than discussion of governance, management, or a specific incident.


reasoning: The paragraph’s main substance is a materiality assessment stating that cybersecurity risks have not materially affected operations, strategy, or financial results to date, with a forward-looking caveat. It does not describe governance roles, management personnel, or specific risk processes in substantive detail.


reasoning: The paragraph is primarily about the company’s internal cybersecurity risk management approach—its ERM integration, policies, controls, and program objectives—rather than focusing mainly on board oversight or a management individual. It names recognized security frameworks and standards (including NIST and ISO), which makes it more specific than boilerplate but not firm-unique under the stated rules.


reasoning: This paragraph primarily narrates an actual cybersecurity-related event, including when it was discovered, what occurred, the amount involved, and the company's response actions. Because it contains multiple exact dates and a specific dollar amount, it is Quantified-Verifiable.


content_category: None/Other

reasoning: This paragraph is only a cross-reference to Risk Factors and does not provide substantive cybersecurity governance, process, incident, or strategy disclosure. It contains no qualifying specific facts and is therefore generic boilerplate.


reasoning: The paragraph is primarily about who in management is responsible for cybersecurity and their qualifications and reporting structure, which makes Management Role the best fit. It includes multiple concrete, company-linked facts about identified roles and years of experience.


reasoning: The paragraph primarily describes actions and findings related to an actual cybersecurity incident, including forensic analysis, remediation steps, insurance activity, and a payment tied to the event. It contains two hard verifiable facts—a specific date reference and a dollar amount—supporting Quantified-Verifiable specificity.


reasoning: The paragraph is primarily about the company's internal cybersecurity escalation, incident-evaluation, and reporting processes, even though it references management and board recipients of those reports. The CIO is mentioned as part of how the process operates, not for qualifications or background, which makes Risk Management Process the best fit.


reasoning: The paragraph is centered on materiality and business impact of cybersecurity risks, directing readers to risk factor disclosures about potential effects on business strategy, financial condition, and results of operations. It does not describe governance, management roles, operational cyber processes, or a specific incident.


reasoning: The paragraph describes actions taken in response to an actual cybersecurity incident, including identifying affected systems and data, notifying customers and regulators, and providing remediation services. Although it ends with a materiality statement, the primary focus is the incident response and scope.


reasoning: This paragraph is primarily about board-level oversight through an audit committee cybersecurity sub-committee and its review responsibilities. While management roles are mentioned, they appear as members of the oversight body rather than as the main subject.


reasoning: The paragraph is primarily about the company's internal cybersecurity risk management activities and control functions, even though it identifies the VP, ISS. The named cybersecurity-specific role makes the disclosure firm-specific, but there are no two or more hard verifiable facts to support a Quantified-Verifiable rating.


reasoning: The paragraph is primarily about the company's internal incident response and cybersecurity program design, including reporting and escalation procedures, which fits Risk Management Process. The only qualifying specific fact is the named NIST Cybersecurity Framework; the Audit Committee reference is generic and does not change the main topic.


reasoning: The paragraph primarily provides a materiality assessment that cybersecurity threats have not materially affected, and are not reasonably likely to materially affect, the company’s business, results, or financial condition. It does not describe a specific incident or internal cybersecurity process, and the cross-reference to risk factors is ancillary.


reasoning: The paragraph primarily describes the company’s internal cybersecurity governance and risk management activities—monitoring risk trends, evaluating the Information Security Program, incident preparedness, and reporting—rather than focusing on board oversight or an individual executive’s qualifications. It is firm-specific because it names non-generic committees unique to the company’s disclosure.


reasoning: This paragraph is about board-level oversight, with the Risk and Compliance Oversight Committee as the grammatical subject responsible for reviewing the cybersecurity program and risk exposure. The named committee is a firm-specific governance fact, making the disclosure Firm-Specific.


reasoning: The paragraph does not describe an actual cybersecurity incident or a concrete risk management process; instead, it provides a general materiality-oriented discussion of potential cyber impacts and states that no material cybersecurity incident has occurred to date. The cross-reference to risk factors does not change the main focus from a strategic/materiality disclosure.


reasoning: The paragraph focuses primarily on the management personnel responsible for cybersecurity implementation and highlights the IT Lead’s experience and qualifications. Although it mentions cybersecurity processes, the emphasis is on who performs the role and that person’s background rather than on the process itself.


reasoning: The paragraph describes the company's internal cybersecurity practices—using outside assistance for security engineering, operations, assessments, and control improvement—so it is primarily about risk management processes. The third parties are unnamed and described generically, so there are no qualifying specific facts.


reasoning: The paragraph focuses on the company's internal cybersecurity risk assessment and management plan, including operational protections and integration with risk management principles, so it is best categorized as Risk Management Process. It includes firm-relevant specifics such as a named plan and SCADA systems, which push it beyond generic boilerplate.


reasoning: The paragraph is primarily about board-level oversight: the Board and Audit Committee oversee cybersecurity risk through reports and presentations from management. Although management roles are named, they are discussed in service of the Board's oversight function rather than as the main subject.


reasoning: The paragraph is primarily about board-level oversight of cybersecurity, with the board and Audit Committee described as overseeing risks, receiving updates, and handling materiality determinations. While management roles are mentioned, they are supporting details within the broader governance structure.


reasoning: The paragraph describes the company's internal IT and cybersecurity risk identification and tracking process, including use of a risk register. Although third-party service providers are mentioned, they are only one input into the company's broader internal risk management process rather than the central topic.


reasoning: This paragraph describes an actual cybersecurity incident, including the attack method, the unauthorized transfer, and response actions taken after discovery. It also includes two verifiable quantitative facts, which makes the disclosure Quantified-Verifiable.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk assessment, safeguard design, gap remediation, and monitoring activities, so the main topic is the risk management process rather than management biographies. It includes firm-specific management details and two quantified experience facts, which elevates specificity to Quantified-Verifiable.


reasoning: The paragraph is primarily about the company’s internal cybersecurity governance process at the management level—policy approval and reporting flows supporting the cybersecurity program—rather than board oversight or an individual executive’s qualifications. It includes firm-specific facts such as a named management committee and cybersecurity-specific roles.


reasoning: The paragraph is primarily about the company's internal cybersecurity-related governance and operating process through the IT Steering Committee, rather than board oversight or a specific executive's qualifications. It describes how cyber issues are reviewed and escalated within management-level processes.


reasoning: The paragraph describes the company’s internal incident-management and disclosure process, including escalation, materiality determination, and reporting procedures, rather than a specific incident or board/management biography. It includes firm-specific details such as a 36-hour reporting requirement and a named team (CMT), but not two qualifying hard verifiable facts for Quantified-Verifiable.


reasoning: The paragraph’s main topic is oversight of third-party vendors, including due diligence and contractual security requirements imposed on vendors, which fits Third-Party Risk. It contains no qualifying specific facts such as named roles, committees, frameworks, dates, firms, tools, or quantified details.


reasoning: The paragraph focuses on a management-level committee and the management roles and functions represented on it, rather than board oversight or a risk process itself. It identifies firm-specific governance structure through the named Technology and Operations Committee and the inclusion of the CIO and CISO.


reasoning: The paragraph describes the company's internal approach and policies for managing cybersecurity risk, making it a risk management process disclosure. It contains only generic statements with no named frameworks, roles, committees, dates, or other firm-specific facts.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management processes—how its program coordinates across functions to identify threats and update procedures. Although third-party partners are mentioned, vendor oversight is not the central topic.


reasoning: The paragraph primarily describes the company’s internal cybersecurity governance and planning processes, including document updates and a multi-year strategic plan, rather than focusing on board oversight or management qualifications. Although the CISO and Audit & Risk Committee are mentioned, they appear as approvers within the broader risk management process.


reasoning: The paragraph is centrally about identifying and overseeing cybersecurity risks posed by third parties such as vendors and service providers, which fits Third-Party Risk. It contains no qualifying specific facts such as named firms, frameworks, dates, tools, or roles, so it is generic boilerplate.


reasoning: The paragraph focuses on the company’s internal cybersecurity function and activities—day-to-day risk management, protective measures, and control standards—rather than on an individual executive or board oversight. The dedicated Information Security Department is a firm-specific organizational detail, but the paragraph does not provide two or more hard verifiable facts.


reasoning: The paragraph primarily describes the company’s internal processes for identifying, assessing, monitoring, and responding to cybersecurity risks, rather than focusing on the board or on a specific executive’s qualifications. It includes a firm-specific named internal program, which makes it more specific than generic boilerplate.


reasoning: The paragraph is centered on the CISO and CTO as management roles, including their responsibilities and reporting line, rather than on board oversight or a general risk process alone. It includes firm-specific facts such as cybersecurity-specific titles and a named non-generic committee, which makes it Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity risk identification, assessment, monitoring, and response activities as part of its overall risk management processes. Although third parties are mentioned, vendor oversight is not the central topic; the focus is the company's own cybersecurity program.


reasoning: The paragraph is centered on the Director of Compliance providing reports to the board, which makes it primarily about a management reporting role rather than the board's oversight itself. It does not include qualifying firm-specific facts under the rubric, since the Board of Directors is generic and Director of Compliance is not a cybersecurity-specific title from the allowed list.


reasoning: The paragraph is primarily about the company's own cybersecurity program and related risk management activities, such as identifying, assessing, mitigating, and reviewing cyber risks. Although it briefly mentions the Audit Committee, that oversight point is ancillary to the broader description of internal cybersecurity processes.


reasoning: The paragraph is principally about audit committee oversight of cybersecurity, including the information it receives from management and incident reporting to the committee. It does not include any qualifying firm-specific facts because the audit committee, General Counsel, IT team, and quarterly cadence are all generic under the rubric.


reasoning: The paragraph’s main point is a materiality assessment stating that cybersecurity threats or prior incidents have not materially affected, and are not reasonably likely to materially affect, the company. It does not describe a specific incident or focus on operational risk-management details.


reasoning: The paragraph is centrally about how the company evaluates and oversees third-party service providers, including contract review and due diligence, so Third-Party Risk is the best fit. It includes a firm-specific detail about the departments involved in that oversight, but does not provide two or more hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph is centered on the company's reliance on third-party SaaS providers and the assurance measures those providers undergo, making vendor oversight the main topic. It names SSAE audits, which makes the disclosure more specific than pure boilerplate but not uniquely firm-identifying.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including when it was identified, its operational effects, restoration timing, and related costs. Although it also includes a materiality statement and risk-factor cross-reference, the central focus is the incident and its impacts.


reasoning: The paragraph’s main point is a boilerplate materiality assessment stating that no known cybersecurity threats have materially affected the company or are reasonably likely to do so. It does not describe an actual incident or substantive risk management process, and the risk-factor cross-reference does not change that classification.


reasoning: The paragraph centers on a materiality-oriented statement that the company has not experienced a cybersecurity incident with material adverse impact, followed by generalized discussion of potential business and reputational harm. It does not describe an actual incident or provide substantive details about governance, management, or risk processes.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk assessment, monitoring, and mitigation activities, making it a risk management process disclosure rather than one focused on a specific management person or board oversight. Although it mentions a third-party technology partner, vendor oversight is not the central topic and the partner is unnamed, so it does not qualify as third-party risk or firm-specific detail.


reasoning: The paragraph primarily describes management's ongoing cybersecurity activities—monitoring threats, mitigating risk, and implementing policies and training—so it is chiefly about the company's risk management process rather than the individual's biography. It includes a cybersecurity-specific executive role and a quantified experience statement, making it more specific than boilerplate.


reasoning: The paragraph is primarily about the company’s internal cybersecurity risk management structure and how the program is operated, with management roles and third parties described as components of that process. Although it includes role and experience details, the main subject is the cybersecurity risk management program rather than the qualifications of a single executive.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk assessment and monitoring activities, with board oversight mentioned as a supporting element rather than the main focus. It does not include qualifying firm-specific facts after filtering out generic roles, generic cadences, and standard governance language.


reasoning: The paragraph’s main focus is the company’s information security program and how it manages cyber risk through monitoring and controls, which makes it a risk management process disclosure. Although it mentions oversight bodies and the CISO, those references are secondary to the description of the program’s operation.


reasoning: The paragraph's main point is a materiality statement that cybersecurity threats or incidents have not materially affected the company's business, results, or financial condition, which falls under Strategy Integration. The mention of third-party provider incidents is incidental and not a substantive discussion of vendor oversight or a specific incident.


reasoning: The paragraph describes a real past cybersecurity event, stating that the bank was targeted by a ransomware attack and noting resulting litigation, so Incident Disclosure is the best fit. Although it includes incident narrative, it does not contain qualifying specific facts from the allowed list such as a precise date, named firm, named tool, or other extractable firm-specific identifiers.


reasoning: The paragraph primarily describes what the company's technology team does to manage and improve cybersecurity, such as defining work plans, setting control objectives, and upgrading systems, so it is best classified as Risk Management Process. Although it mentions a named role and experience, the focus is on the function and activities rather than the individual’s qualifications alone.


reasoning: The paragraph is a standalone materiality assessment about whether any system weakness or malware would materially affect operations, without describing governance, management roles, or risk processes. It contains no company-specific facts, dates, named roles, frameworks, or other qualifying details.


reasoning: The paragraph centers on a materiality-oriented statement that no cybersecurity incident has had a material impact to date, followed by generic descriptions of potential business and legal consequences. It does not describe an actual incident, governance structure, management role, or internal risk management process.


reasoning: The paragraph’s main point is a materiality conclusion that cybersecurity incidents did not materially affect the company’s business strategy, results of operations, or financial condition, which falls under Strategy Integration. It does not describe any actual incident event, scope, or response actions.


reasoning: The paragraph’s main point is a materiality assessment stating the company is not aware of material cybersecurity incidents or threats likely to materially affect the business. It does not describe a specific incident or substantive risk management process, and the cross-reference to Risk Factors is ancillary.


reasoning: The paragraph focuses on cybersecurity insurance coverage and potential financial protection related to incidents, which falls under strategy integration rather than incident disclosure or risk management processes. It provides no firm-unique names, dates, amounts, or other qualifying specific facts.


reasoning: The paragraph is centrally about how the company evaluates and oversees cybersecurity risks arising from third-party service providers, including questionnaires and review of attestation reports. It does not include any qualifying specific facts such as named firms, standards, tools, dates, or quantified details.


reasoning: The paragraph is primarily about how the Board of Directors and the Audit Committee oversee cybersecurity risk, so Board Governance is the best fit. Although management roles are mentioned, they are described mainly as reporting to the committee rather than as the central subject.


reasoning: The paragraph primarily describes how the company’s cybersecurity risk assessment and management processes are carried out internally, even though management titles are mentioned. The named roles are generic operating executives rather than cybersecurity-specific roles, and no qualifying specific facts remain after filtering.


reasoning: The paragraph’s main substantive point is a materiality-oriented statement that no cybersecurity incidents have materially affected the company, followed by general discussion of potential business impacts. Although it briefly mentions management structures and a cybersecurity organization, those references are generic and secondary to the materiality/risk-impact disclosure.


reasoning: The paragraph mainly describes the company’s internal cybersecurity risk identification, monitoring, mitigation, and incident reporting processes. Although it mentions board and audit committee oversight, the core focus is on how management runs the cybersecurity program rather than board governance itself.


reasoning: The paragraph is primarily about the company's internal cybersecurity program and processes, including safeguards, incident response, testing, training, and third-party risk oversight as components of that program. Although it mentions board oversight, the main focus is the company's risk management activities rather than governance by the board.


reasoning: The paragraph is centered on the board of directors receiving cybersecurity presentations, so board oversight is the primary topic. It contains only generic governance language and no qualifying specific facts such as named committees, roles, frameworks, dates, or quantified details.


reasoning: The paragraph's most substantive disclosure is the materiality conclusion that cybersecurity incidents have not materially affected, and are not reasonably likely to materially affect, the company’s strategy, results of operations, or financial condition. The reference to monitoring processes and an IT consultant is generic and does not make internal risk management the central topic.


reasoning: The paragraph provides a materiality assessment that cybersecurity threats and prior incidents have not materially affected the company and are not currently expected to do so. It does not describe governance, management roles, or any actual incident details, so Strategy Integration is the best fit.


reasoning: The paragraph is centered on who within management is responsible for cybersecurity—especially the CIO's responsibility, experience, and supporting leadership structure—rather than primarily describing board oversight or a discrete incident. It also includes firm-specific roles and a named internal council, which makes it more specific than boilerplate.


reasoning: The paragraph centers on who manages cybersecurity—identifying the Information Security Manager, the Chief Information Officer, their reporting relationship, and their experience—so Management Role is the best fit. Although it also mentions operational activities and tools, those details are presented in support of the management structure rather than as a standalone process description.


reasoning: The paragraph primarily focuses on the CIO as the management leader of cybersecurity, emphasizing his experience, background, and reporting relationship. Although it also describes committee responsibilities and program activities, the person-centered qualifications and role details make Management Role the best fit.


reasoning: The paragraph is primarily about the Audit Committee’s oversight of cybersecurity, including its review responsibilities, meeting participation, and governance role. Although management roles are mentioned, they are described in support of the committee’s oversight, making Board Governance the best fit.


reasoning: The paragraph focuses on the company’s internal cybersecurity risk management structure and how cyber risk is embedded into enterprise processes, product teams, and a security council. Although the CISO is mentioned, the emphasis is on the functioning of the program rather than the individual’s qualifications or reporting line.


reasoning: The paragraph is primarily about the company's internal governance and oversight process for cybersecurity through management committees, rather than board oversight or the qualifications of a specific executive. It includes firm-specific committee names and team composition, which makes it more specific than boilerplate but not quantified/verifiable.


reasoning: The paragraph describes the company’s internal approach to handling cybersecurity within its ERM framework, focusing on management’s oversight and reporting process rather than the board’s oversight as the main subject. It contains only generic governance language and no qualifying specific facts.


reasoning: The paragraph describes the company's internal cybersecurity risk management activities and program elements, such as risk assessments, security controls, training, incident response, and third-party risk management. Although third-party oversight is mentioned, it is only one component of the broader internal process, so Risk Management Process is the best fit.


reasoning: The paragraph primarily describes the company's internal cybersecurity safeguards and operational processes, such as training, incident response exercises, audits, and continuity mechanisms. Although it mentions insurance and a third-party program, those references are subordinate to the broader description of the company's risk management process.


reasoning: The paragraph primarily states that cybersecurity risks have not materially affected the company's operations, strategy, or financial results to date and may do so in the future, which is a materiality assessment. The cross-reference to Risk Factors does not change the main focus from strategy/materiality.


reasoning: The paragraph’s main focus is the company’s reliance on service providers and its onboarding and monitoring of third-party vendors, making third-party cyber risk the central topic. It contains no qualifying specific facts such as named vendors, dates, frameworks, tools, or quantified details.


reasoning: The paragraph is primarily about the Board of Directors' oversight of cybersecurity risk and the information it receives, so Board Governance is the best fit. It includes a firm-specific management title, which makes it more specific than generic boilerplate, but it does not contain two hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph is centered on the potential or actual material effects of cybersecurity threats on the company's business, financial condition, and results of operations, plus a risk-factor cross-reference. Although it mentions prior cyber attacks, it does not describe an actual incident's facts or response, so the main focus is materiality rather than incident disclosure.


reasoning: The paragraph is centered on the Board of Directors and its Audit Committee overseeing cybersecurity risk, making board oversight the primary topic. It contains only generic governance language and no qualifying specific facts such as named cyber-specific roles, non-generic committees, dates, frameworks, or verifiable details.


reasoning: The paragraph describes the company’s cybersecurity prevention, detection, and incident-response activities as part of its internal risk management process. It does not focus on board oversight, management roles, third-party risk as the central topic, or any specific incident.


reasoning: The paragraph's main point is a materiality assessment stating that cybersecurity threats and incidents have not materially affected, and are not reasonably likely to materially affect, the company, which fits Strategy Integration. It does not describe any actual incident or provide firm-specific operational details beyond boilerplate risk language and a cross-reference.


reasoning: The paragraph is a standalone materiality assessment stating that no identified cybersecurity threats or incidents have materially affected the company, without describing any actual incident or internal process. It uses standard SEC-style materiality language and contains no firm-specific or verifiable details.


reasoning: The paragraph describes an actual cybersecurity incident by stating that information was exfiltrated and that the company is investigating the extent of compromise. It does not include any qualifying specific facts such as dates, named systems, firms, or quantified details.


reasoning: The paragraph describes the company's internal cybersecurity practices—vulnerability scanning, testing, and use of threat intelligence and outside assistance—as part of its risk management process. The external parties are mentioned only as support for the company's own processes, not as a standalone vendor oversight topic.


reasoning: Although the paragraph mentions board oversight, the most specific substantive disclosure centers on the Director of Information Security's responsibility, reporting line to the Chief Information Officer, and committee memberships. That makes management responsibility the primary focus rather than board governance or general process description.


reasoning: Although the paragraph names the InfoSec Director, the main focus is on the company’s monitoring, auditing, and incident response processes rather than the individual’s qualifications or reporting line. The presence of the cybersecurity-specific role and the named eRISC group makes the disclosure firm-specific.


reasoning: The paragraph primarily describes the company's internal incident escalation and materiality evaluation process, including how a management-led team handles incident communication and resolution updates. Although the Board is mentioned, it is the recipient of communications rather than the main subject of the paragraph.


reasoning: The paragraph is about the company's internal cybersecurity risk management approach, specifically the framework it uses to assess and mitigate cyber risk. It names recognized cybersecurity standards/frameworks but does not provide firm-unique roles, dates, numbers, or other company-specific verifiable details.


reasoning: This paragraph is centered on the identities, qualifications, and backgrounds of management personnel responsible for technology and information security, which makes Management Role the best fit. It includes multiple verifiable facts such as named roles, quantified years of experience, and named certifications, supporting a Quantified-Verifiable rating.


reasoning: The paragraph primarily describes the company’s internal cybersecurity risk assessment, vulnerability testing, and recovery planning processes, with the CISO mentioned mainly as the overseer of those activities. Although it includes a sentence about the CISO’s experience, the main subject is the company’s risk management process rather than the management role itself.


reasoning: The paragraph is mainly about the company’s internal cybersecurity risk assessment, mitigation, and monitoring process, with management responsibility described as part of that process. Although it names a specific role, the focus is on how cybersecurity risk is managed rather than on the individual’s qualifications or background.


reasoning: The paragraph describes the company’s own cybersecurity program and safeguards—how it manages cybersecurity risk internally—rather than board oversight, management qualifications, third-party oversight, or any specific incident. Its only qualifying specific detail is the reference to the NIST Cybersecurity Framework, which makes it sector-adapted rather than firm-specific.


reasoning: The paragraph combines general employee cybersecurity training with a statement that the company purchases cybersecurity insurance; the insurance component makes Strategy Integration the best fit. It does not describe board oversight, management qualifications, a specific incident, or a detailed third-party risk program.


reasoning: The paragraph primarily describes the company's response to an actual cybersecurity incident, including identifying affected systems and data, notifying impacted parties, providing remediation services, coordinating with law enforcement, and related litigation. Although it ends with a materiality statement, the main focus is the incident and response actions.


reasoning: This paragraph primarily describes an actual cybersecurity incident, including when it was detected and the response actions taken to contain and remediate it, so it fits Incident Disclosure. It includes two specific date-based facts tied to the incident timeline, which supports Quantified-Verifiable specificity.


reasoning: The paragraph primarily describes the company's internal incident governance and materiality-evaluation process, including the management team structure used to handle cybersecurity incidents. Although the CIO and CISO are named and the Audit Committee is mentioned, the focus is on how the company manages incidents rather than on board oversight or executive qualifications.


reasoning: The paragraph is primarily about governance oversight, describing how the Risk Committee receives cybersecurity reporting. Although the CISO is mentioned, the main point is the committee’s oversight mechanism rather than the individual’s qualifications or role background.


reasoning: The paragraph is primarily about the company's own cybersecurity risk posture and internal efforts to assess, identify, detect, investigate, and manage cyber risks. Although it includes a materiality-related statement and a risk-factor cross-reference, the core subject is the company's internal risk management approach rather than board oversight, management roles, or a specific incident narrative.


reasoning: The paragraph mainly states that the company has not yet commenced operations and only gives a general, future-looking statement about cybersecurity importance, rather than describing a substantive governance structure or risk management program. Under the SPAC/shell-company rule, the absence of an operating cybersecurity program is classified as None/Other.


reasoning: The paragraph mainly describes how cybersecurity risk management for the Trust is handled—through the Sponsor's reliance on BlackRock's ERM framework—rather than focusing primarily on board oversight. The board-reporting sentence is secondary to the broader description of the Trust's cybersecurity risk management approach.


reasoning: The paragraph is primarily about how the Audit Committee and, potentially, the Board oversee cybersecurity risk within the enterprise risk management program, even though it briefly notes that a Co-President manages the risk. It contains no qualifying specific facts under the stated rules because Co-President and Audit Committee are generic governance roles and there are no named frameworks, dates, firms, tools, or quantified details.


reasoning: The paragraph describes the company's internal cybersecurity risk assessment and safeguard activities, including controls used to manage identified risks, which squarely fits Risk Management Process. It does not include any qualifying specific facts such as named frameworks, roles, dates, firms, tools, or quantified details.


reasoning: The paragraph is centered on the Director of IT as the responsible management role and notes that person's experience, rather than primarily describing board oversight or a detailed company risk process. It does not include any qualifying specific facts such as a cybersecurity-specific title from the allowed list, named frameworks, dates, firms, tools, or quantified details.


reasoning: The paragraph is centered on the Vice President, IT Security—his responsibilities, experience, education, and certifications—so it is primarily about a management role rather than the broader cybersecurity process. It includes multiple firm-specific, verifiable facts about that role, including a quantified experience figure and named certifications.


reasoning: The paragraph is centered on a management role—the CFO—being responsible for day-to-day cybersecurity oversight and reporting to the Board. Although it mentions risk management activity and Board updates, the main focus is the management-level responsibility rather than the company’s broader process or board oversight.


reasoning: The paragraph is about the company’s approach to assessing, identifying, and managing cybersecurity risks, which fits Risk Management Process. However, it provides only high-level risk examples and no concrete process details, roles, frameworks, or firm-specific facts.


reasoning: The paragraph's central topic is cybersecurity risk arising from third-party service providers and the company's monitoring of those provider-related risks. It contains no named vendors, contracts, standards, dates, roles, or other firm-specific details.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management activities, including evaluating risks, detecting vulnerabilities, and incident notification procedures. Although it mentions the Head of Information Security, the focus is on what the process does rather than on the individual role itself.


reasoning: The paragraph primarily describes the company's internal escalation and reporting process for cybersecurity risks and incidents rather than focusing on board oversight or the qualifications of a particular manager. The roles mentioned are generic executives, and there are no qualifying specific facts such as named frameworks, dates, firms, tools, or cyber-specific titles from the allowed list.


reasoning: The paragraph is primarily about board-level oversight of cybersecurity risk, with the Board and a named board committee as the grammatical subjects. It includes a firm-specific fact by identifying the non-generic Risk and Information Security Committee.


reasoning: The paragraph is principally about the Board’s oversight role, including its responsibility to approve cybersecurity-related plans and the cyber expertise of a board member. It contains firm-specific governance details and named entities, but not two or more qualifying hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity program, controls, and incident procedures, making it a risk management process disclosure. Its only qualifying specific detail is the named NIST Cybersecurity Framework, with no firm-unique roles, dates, or other verifiable company-specific facts.


reasoning: The paragraph primarily describes the company’s own cybersecurity risk management processes, with only a brief mention that oversight is shared by the board and senior management. It contains no qualifying specific facts, named roles, frameworks, dates, or other firm-unique details.


reasoning: The paragraph describes an actual cybersecurity incident, including when it occurred and what happened (a ransomware attack involving removal of data), so Incident Disclosure is the best fit. Although it also discusses resulting legal proceedings and potential impact, those points are secondary to the incident narrative.


reasoning: The paragraph is centered on the company’s informational technology consultant as the responsible individual and highlights that person’s experience, which makes Management Role the best fit. It does not primarily describe board oversight or broader risk processes apart from the consultant’s role.


reasoning: The paragraph is primarily about the Board of Directors' expected oversight of cybersecurity risks and related updates from management, making board oversight the central topic. It contains only generic governance language and vague cadences, with no qualifying specific facts such as named cyber roles, non-generic committees, dates, frameworks, or quantified details.


reasoning: The paragraph describes an internal incident-handling step—an immediate assessment by the incident response team to evaluate scope and impact—so it is about the company's cybersecurity process rather than a specific disclosed incident. It contains no qualifying specific facts such as named roles, dates, frameworks, products, firms, or numbers.


reasoning: This paragraph describes an actual cybersecurity-related incident, including the attack method, the fraudulent transfer, and the recovery efforts, so Incident Disclosure is the best fit. It includes two concrete quantitative facts—the amount of BTC and its approximate dollar value—supporting a Quantified-Verifiable rating.


reasoning: This paragraph is a cross-reference to a risk factor and does not provide substantive cybersecurity governance, management, process, incident, or strategy disclosure in this paragraph itself. It contains no qualifying specific facts under the provided rules.


reasoning: The paragraph describes the company's own cybersecurity monitoring and vulnerability-identification process, centered on how it uses a tool to detect and remediate risks. It is not about board oversight, management qualifications, vendor governance, or a specific incident.


reasoning: The paragraph primarily describes the company’s internal cybersecurity controls and practices for managing risk, so it is best categorized as Risk Management Process. Although it mentions a CISO, the focus is on the program’s activities rather than the person’s qualifications or reporting role.


reasoning: The paragraph is primarily about the company’s internal cybersecurity governance and control processes—how cyber risk is managed, integrated into ERM, independently assessed, and embedded into IT initiative review and implementation. Although a management title and board reporting are mentioned, the focus is on the functioning of the company’s risk management process rather than on board oversight or the individual executive’s qualifications.


reasoning: The paragraph’s main focus is the materiality assessment—that no cybersecurity incidents or threats, including the previously disclosed incident, materially affected or are reasonably likely to materially affect the company’s business, operations, or financial condition. Although it briefly references an actual incident, the central point is the no-material-impact conclusion rather than the incident narrative itself.


reasoning: The paragraph primarily discusses the company’s information systems environment and mentions its own Information Security Program establishing security policies and procedures, which fits internal cybersecurity risk management processes. References to customers and service providers are contextual rather than a central discussion of third-party oversight.


reasoning: The paragraph focuses on the potential business, financial, legal, and reputational impacts that could result from a cybersecurity compromise, rather than describing governance, management roles, or risk management processes. It is framed as a generic consequences statement with no incident details or company-specific facts.


reasoning: The paragraph’s main point is a materiality-related statement that the company did not experience a material cybersecurity incident during the referenced period, along with a forward-looking impact caution. It does not describe an actual incident, board oversight, or management roles, so Strategy Integration is the best fit.


reasoning: The paragraph’s main point is the company’s materiality assessment that cybersecurity risks, including a prior incident, have not materially affected and are not reasonably likely to materially affect the business. Although it mentions a real past incident, that incident serves as support for the materiality conclusion rather than as the primary narrative focus.


reasoning: The paragraph’s main focus is the company’s oversight of third-party service providers, including pre-engagement assessments and ongoing monitoring, which fits Third-Party Risk. The closing materiality statement is secondary and does not change the paragraph’s central topic.


reasoning: The paragraph primarily describes the potential business, operational, legal, and financial consequences of cybersecurity risks, including insurance coverage and material adverse effects, rather than detailing a concrete incident or a specific governance/process structure. Although it briefly mentions security measures, the main thrust is risk exposure and business impact.


reasoning: The paragraph describes the company's internal cybersecurity operations, including monitoring, detection, incident response, and employee training. It does not focus on board oversight, management personnel, third-party risk, or any actual disclosed cyber incident.


reasoning: The paragraph's main substance is a materiality assessment stating that known cybersecurity threats and prior incidents have not materially affected the company, while acknowledging potential future material effects. Although it briefly mentions enterprise risk management, the central focus is the business/materiality impact of cyber risk rather than the company's operational cybersecurity processes.


reasoning: This paragraph describes an actual cybersecurity incident, including what occurred and the company’s response actions, so Incident Disclosure is the best fit. It also includes two hard verifiable facts—an exact date reference and a specific dollar amount—supporting Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's cybersecurity monitoring and scanning activities as part of its internal risk management process, even though those activities are performed by an unnamed IT service provider. It is not primarily about oversight of vendors or any actual incident.


reasoning: Although the paragraph includes an example of a past cyber incident, its primary disclosure purpose is the materiality assessment that such incidents have not materially affected, and are not reasonably likely to materially affect, the company’s business, results, or financial condition. Under the tiebreakers, incident reference plus a materiality conclusion as the main point is Strategy Integration.


reasoning: This paragraph describes a real cybersecurity incident’s operational impact and the company’s response, including systems taken offline and restoration after containment, so Incident Disclosure is the best fit. It does not include qualifying specific facts such as dates, named systems, named firms, or other firm-unique verifiable details.


reasoning: The paragraph focuses on the company's internal cybersecurity risk assessment and safeguard processes, with only a brief mention of who handles day-to-day responsibility. The referenced 'IT consultant' is not a sufficiently specific cybersecurity role or other qualifying firm-specific fact, so the disclosure remains generic.


reasoning: The paragraph’s main substantive clause is about the Board of Directors discussing applicable cyber risks and questioning management about related controls, which makes board oversight the central topic. Although it also includes a materiality statement, that functions as a qualifier rather than the paragraph’s main focus.


reasoning: The paragraph’s main point is that prior cyber-attack incidents have not been material to the company and that future incidents could create business and financial harm, which fits Strategy Integration. Although it also mentions a cybersecurity committee, the core emphasis is materiality and business impact rather than governance mechanics.


reasoning: The paragraph focuses on the company’s internal cybersecurity capability-building process—training, exercises, and maintaining staff expertise—rather than on a specific executive or board oversight. It includes multiple concrete, externally recognizable facts such as named industry groups and named professional certifications held by cybersecurity personnel.


reasoning: The paragraph is primarily about a board committee's oversight of cybersecurity matters, with management providing reports and reviews to that committee. It names a cybersecurity-relevant management role and a non-generic committee, making the disclosure firm-specific.


reasoning: The paragraph describes the company's internal cybersecurity safeguards and security procedures, so it is primarily about its risk management process. The mention of external service providers is generic and only a supporting element of the internal program, not a central third-party risk discussion.


reasoning: The paragraph focuses on the company's internal cybersecurity architecture and controls for protecting systems and data, which fits Risk Management Process. It includes firm-specific technical details such as use of AWS RDS and the described network exposure configuration, but not two qualifying hard verifiable facts needed for Quantified-Verifiable.


reasoning: This paragraph primarily describes an actual cybersecurity incident, including when it occurred, what systems were affected, response actions taken, and subsequent disclosure of extracted data. It includes two specific dates, which makes the disclosure quantified/verifiable under the rubric.


reasoning: The paragraph is mainly about the company’s internal security program serving as its benchmark for protecting information, which makes the company’s own cybersecurity process the central topic. Although it mentions the Board and the COO, those references are secondary and do not shift the paragraph to board governance or management role.


reasoning: The board is the grammatical subject and the paragraph focuses on the board’s oversight of cybersecurity risk and cyber-related expertise among trustees, which fits Board Governance. It includes one company-specific verifiable fact—two board members with information security expertise—but not enough hard facts to reach Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity controls and protective measures, such as authentication, encryption, and DDoS defense, so it is best categorized as Risk Management Process. It includes a firm-specific named security tool, AWS Shield, which makes it more specific than generic boilerplate.


reasoning: The paragraph is primarily a materiality assessment stating that prior cybersecurity threats or incidents have not materially affected the company and are not reasonably likely to do so, which fits Strategy Integration under the tiebreaker rules. It contains no qualifying specific facts beyond generic boilerplate materiality language and a cross-reference to risk factors.


reasoning: The paragraph is primarily about the company's governance structure for cybersecurity oversight, culminating in reporting to the board's Innovation and Technology Committee. While management roles are named, the main focus is on committee-based oversight and board-level governance rather than the qualifications or duties of a specific individual.


reasoning: The paragraph describes the company’s use of outside providers as part of its own cybersecurity risk identification, assessment, and management process, rather than focusing on oversight of vendor risk itself. It contains no named firms, tools, dates, frameworks, or other qualifying specific facts.


reasoning: The paragraph refers to the company's internal security controls and mitigation measures for managing cybersecurity risk, which fits Risk Management Process. It contains no named frameworks, roles, dates, tools, firms, or other qualifying specific facts.


reasoning: The paragraph is primarily about board-level oversight, with the Board and Audit Committee described as overseeing and receiving briefings on cybersecurity risk. The mentions of the CEO and CFO are generic management references and do not shift the main focus away from governance.


reasoning: The paragraph is primarily about board-level oversight: the committee reports to the full Board, the Board receives cybersecurity briefings, and directors receive cybersecurity education. Management responsibilities are also described, but as supporting the Board’s oversight structure rather than as the main subject.


reasoning: The paragraph is primarily about how the company monitors and manages cybersecurity risk through internal processes and information inputs, rather than about board oversight or the CISO's qualifications. It includes firm-specific organizational facts through the named CISO role and the ERMC.


reasoning: The paragraph focuses on the company's internal cybersecurity activities—implementation support, employee training, phishing tests, and awareness efforts—so it is primarily about risk management processes rather than the qualifications or background of a specific executive. It is firm-specific because it explicitly identifies a CISO, which is a cybersecurity-specific role.


reasoning: The paragraph primarily discusses the potential business, operational, and financial consequences of cybersecurity threats, emphasizing possible material adverse effects rather than detailing governance, management roles, or specific risk management processes. It contains no company-specific verifiable facts, dates, named roles, frameworks, or other qualifying details.


reasoning: The paragraph describes the company's internal cybersecurity identification and incident assessment activities, such as monitoring systems, detecting anomalies, and documenting incidents. It does not focus on board oversight, management personnel, third-party risk, or a specific disclosed incident.


reasoning: The paragraph’s main focus is oversight by the Audit Committee, making it a board-governance disclosure rather than a description of management roles or operational processes. It contains only generic governance language, and the references to the Audit Committee and quarterly reporting do not qualify as specific facts under the rules.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including when it was discovered, the unauthorized access, and response actions taken. It includes one qualifying firm-specific fact—a specific date—but not two or more hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph mainly gives a materiality-oriented statement that cybersecurity incidents could affect the business, but that no such incident has had a material impact to date, and then cross-references other sections for more information. It does not describe a specific incident or provide substantive detail about governance or processes.


reasoning: The paragraph is primarily about board- and committee-level oversight of cybersecurity and enterprise risk, with the Board of Directors and board committees as the grammatical subjects. It includes a named committee beyond generic board references, making it firm-specific.


reasoning: The paragraph is primarily about the company's internal cybersecurity risk management program, including ERM integration, policies, and ongoing review processes. Although the Board and CISO are mentioned, they are supporting details rather than the main subject of the paragraph.


reasoning: The paragraph discusses an actual cybersecurity incident, focusing on the ongoing investigation and the currently known scope and potential data impact. It contains no qualifying specific facts such as dates, named firms, tools, or other firm-unique verifiable details.


reasoning: The paragraph primarily describes the company's internal risk administration and framework for identifying, analyzing, and responding to risks, which fits Risk Management Process. Although management is mentioned, the focus is on how risk is administered rather than on an individual's qualifications or background.


reasoning: The paragraph describes the company's internal cybersecurity measures for prevention, detection, response, and updates to address evolving threats. It contains only general process language with no named frameworks, roles, dates, tools, or other firm-specific details.


reasoning: The paragraph primarily describes the company’s internal cybersecurity risk assessment, mitigation, and monitoring process. Although it mentions an IT consultant and reporting line, the focus is on how cybersecurity risk is managed rather than on a named management role’s qualifications or background.


reasoning: The paragraph describes an internal process outcome—keeping management informed about cybersecurity posture and risks—rather than identifying a specific board committee, named executive role, or incident. It contains only generalized language with no firm-specific details.


reasoning: The paragraph describes the company's internal access control and user provisioning practices, including review of system access and use of authentication controls. Although third-party hosted environments are mentioned, they are only one component of the broader internal security process rather than the central topic.


reasoning: Although the paragraph begins with board oversight, most of the disclosure focuses on the CIO and CISO, their reporting relationship, responsibilities, and qualifications. That makes management leadership of cybersecurity the dominant subject rather than board governance.


reasoning: The paragraph describes a real cybersecurity event involving attempted phishing attacks against the company's online banking platform, along with the outcome and response context. It does not include qualifying specific facts such as exact dates, named firms, named tools, or other verifiable details.


reasoning: The paragraph’s main point is a materiality assessment about past and potential cybersecurity incidents, not a description of governance, management roles, or risk processes. The inclusion of a specific date makes it firm-specific, but there is only one qualifying verifiable fact, so it does not reach Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity processes—incident response planning, testing, and backups—rather than board oversight, management qualifications, third-party oversight, or a specific incident. It contains only generic process descriptions with no qualifying specific facts.


reasoning: The paragraph is primarily about committee-level oversight: the Audit Committee receives incident information and discusses cybersecurity risk management, making board/committee governance the main subject. It includes one firm-specific fact through the identified CSO role, but otherwise consists mostly of standard oversight language.


reasoning: The paragraph focuses on the potential impact of cybersecurity threats on the company's business strategy, results of operations, and financial condition, rather than describing governance, management roles, or specific risk management processes. It contains only generic, boilerplate language and no qualifying specific facts.


reasoning: The board is the grammatical subject and the paragraph focuses on its oversight of cybersecurity risk and management's implementation of the program. It contains no qualifying specific facts such as named committees, roles, frameworks, dates, or quantified details.


reasoning: The paragraph describes how cybersecurity risk management is integrated into the company's broader enterprise risk management processes, so it is about internal risk management rather than board oversight or management qualifications. It contains no qualifying specific facts such as named frameworks, roles, dates, firms, tools, or quantified details.


reasoning: The paragraph describes the company's internal cybersecurity policy and control framework, so it is primarily about its risk management process. It includes named internal security policy/system references that make it more specific than generic boilerplate, but it does not provide two hard verifiable facts.


reasoning: The paragraph describes the company's internal cybersecurity preparedness processes, specifically incident response and recovery planning and testing. It does not discuss board oversight, management qualifications, third-party risk, or a specific incident.


reasoning: The paragraph primarily describes the company's cybersecurity risk management activities—using third-party assessments, threat intelligence, and regulatory monitoring to inform cybersecurity investments and strategy. Although specific management roles are named, the focus is on the process and function rather than the individuals' qualifications or reporting lines.


reasoning: The paragraph is centrally about how the company evaluates and imposes cybersecurity requirements on third-party service providers and business partners, which fits Third-Party Risk. Its only qualifying specific detail is the named SOC 2 standard, with no firm-unique roles, dates, tools, or quantified facts.


reasoning: The paragraph describes the company's cybersecurity practices, including patching, employee training, and review of third-party security procedures, which makes internal risk management the central topic. Although third parties are mentioned, they appear as one component of the company's overall process rather than as the main focus.


reasoning: The paragraph describes an actual cybersecurity incident, including what occurred and the company’s response to it, so Incident Disclosure is the best fit. It also includes two hard verifiable facts—a specific date and a dollar amount—supporting Quantified-Verifiable specificity.


reasoning: The paragraph describes an actual cybersecurity incident’s scope and response, including what data was and was not accessed and actions taken after the investigation. It does not include qualifying specific facts such as dates, named firms, named systems/products, or quantified details.


reasoning: The paragraph focuses on the company's internal cybersecurity risk management program and its purpose of identifying, assessing, and mitigating cyber risks. It does not name any specific framework, role, committee, date, tool, or other firm-specific fact, so it remains generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes and policies, especially incident response preparation, detection, response, recovery, and plan updates. It does not identify any qualifying specific facts such as named frameworks, specific roles, dates, firms, tools, or quantified details.


reasoning: The paragraph is primarily about the backgrounds and qualifications of management personnel, especially the CISO and other executives, rather than cybersecurity processes or board oversight. It includes a firm-specific cybersecurity management role, which makes it more specific than generic boilerplate.


reasoning: This paragraph is a generic definition of a type of cyberattack and does not describe the company's governance, management roles, risk processes, third-party oversight, strategy, or any actual incident. It contains no substantive company-specific disclosure.


reasoning: The paragraph primarily explains how cybersecurity- and privacy-related data exposure connects to the company’s operations, services, and broader business strategy rather than describing governance, management roles, or specific risk management processes. It names HIPAA, which makes the disclosure more tailored than pure boilerplate but not firm-unique.


reasoning: The paragraph describes the company's internal cybersecurity risk identification, assessment, and management processes for its systems and data, making Risk Management Process the best fit. It contains no named frameworks, roles, committees, dates, firms, tools, or other qualifying specific facts, so it is generic boilerplate.


reasoning: The paragraph primarily describes an actual cybersecurity incident, including when it occurred, what systems/accounts were affected, notification timing, mitigation steps, and related costs. Because it includes multiple verifiable facts such as dates, counts, and a dollar amount, it is Quantified-Verifiable.


reasoning: The paragraph is primarily about the Board's oversight of cybersecurity and enterprise risk, with the Board and its committees as the grammatical subject. It does not include any qualifying specific facts such as named non-generic committees, cybersecurity-specific roles, dates, named firms, tools, or quantified details.


reasoning: The paragraph primarily provides a materiality/status conclusion that the company has not experienced any material cybersecurity incidents or known unauthorized access, rather than describing governance roles or a concrete risk management process. The remaining statement about continued monitoring is generic and does not shift the main focus away from this status/materiality disclosure.


reasoning: The paragraph is primarily about which members of management participate in cybersecurity-related communications and escalation, rather than the board's oversight or a risk process itself. However, it identifies only generic executive roles and a standard audit committee, without any qualifying firm-specific cyber details.


reasoning: The paragraph is primarily about how significant cybersecurity matters are escalated to and updated for the Board, making board oversight the main substance. It contains no qualifying specific facts under the rubric because COO, CFO, Board, and generic reporting language are not considered firm-specific.


reasoning: The paragraph focuses on the company's internal cybersecurity functions—risk assessment, security controls, and incident response—rather than on a specific person's qualifications or board oversight. It does not include any qualifying firm-specific facts such as named roles, frameworks, dates, tools, or quantified details.


reasoning: The paragraph is primarily about the company’s internal process for escalating, assessing, determining materiality, and reporting cybersecurity threats and incidents. Although it references the Risk Committee, the main subject is the MAT-led management process rather than board oversight.


reasoning: The paragraph is primarily about oversight by the Audit Committee of the Board, which is the main grammatical subject and focus, even though it also includes details about the CIO. It is Firm-Specific because it includes a cybersecurity-specific management role and quantified experience details, but not enough clearly hard verifiable facts to warrant Quantified-Verifiable.


reasoning: The paragraph is primarily about the company’s internal incident-response structure and how a designated management team coordinates and executes response activities. Although it mentions reporting to senior leadership and the board, the main subject is the operational response process rather than board oversight or an individual executive’s qualifications.


reasoning: The paragraph describes the company's internal cybersecurity controls and operating practices, focusing on how it manages and mitigates cyber risk rather than board oversight, management qualifications, vendors, or a specific incident. Although it lists many control domains, they are generic security practices and do not include qualifying firm-specific facts under the rubric.


reasoning: The paragraph is chiefly about how the company manages cybersecurity risk internally—risk assessment, incident preparation, response, remediation, and materiality determination—rather than about board oversight or an individual executive’s qualifications. Although management roles are listed, the focus is on the process those roles carry out.


reasoning: The paragraph describes the company's internal cybersecurity risk management process and notes that service providers are one input to that process, rather than focusing on oversight requirements imposed on vendors. It contains only generic, unnamed third-party categories and no qualifying specific facts.


reasoning: The paragraph describes the company’s own cybersecurity activities—threat hunting, monitoring, control evaluations, and review of service providers—as part of its internal cyber risk management program. Although third-party service providers are mentioned, vendor oversight is only one component of the broader internal process, so Risk Management Process is the best fit.


reasoning: The paragraph describes the company's internal cybersecurity monitoring and response processes—how management supervises prevention, detection, mitigation, and remediation efforts—rather than focusing on a specific person or board oversight. It contains only generic descriptions of sources of threat information and security monitoring, with no qualifying firm-specific facts.


reasoning: The paragraph is primarily about the IT Director’s role and qualifications, making Management Role the best fit, with the ITSC mentioned as supporting context. It contains multiple company-specific facts, including quantified experience details and a named committee.


reasoning: The paragraph is a standalone materiality conclusion stating that known cybersecurity threats and prior incidents have not materially affected, and are not reasonably likely to materially affect, the company. The cross-reference to Risk Factors does not change the main focus from materiality assessment.


reasoning: The paragraph describes the company's internal cybersecurity practices and controls, such as risk assessments, penetration testing, incident response, monitoring, training, and third-party risk as one component of the overall program. It is not centered on a specific person, board oversight, or an actual incident.


reasoning: The paragraph focuses on the company’s internal cybersecurity risk management program, policies, and control framework, which fits Risk Management Process. It is Firm-Specific because it includes a named internal program and company-specific implementation details, not just generic boilerplate.


reasoning: This paragraph is executive biographical background about Duncan Fulton and does not contain substantive cybersecurity disclosure. Because it is non-cybersecurity content, the appropriate category is None/Other.


reasoning: The paragraph primarily describes the company’s internal cybersecurity risk assessment and risk management processes, including how identified risks are evaluated and integrated into enterprise risk management. Although the Audit Committee is mentioned, it is not the main subject and the focus remains on internal process.


reasoning: The paragraph is primarily about the company's cybersecurity monitoring, safeguards, and incident response activities, which makes it a description of internal risk management processes rather than a person-focused management biography. Although the CISO is mentioned, the focus is on what the function does.


reasoning: The paragraph focuses on management-side responsibility and reporting for cybersecurity, especially the CTO's participation and updates within management committees. Although it mentions oversight structures, these are management committees rather than board committees, making Management Role the best fit.


reasoning: The paragraph is centrally about oversight of third-party service providers, including vendor assessments and contractual cybersecurity obligations, which fits Third-Party Risk. It does not include any qualifying specific facts such as named frameworks, roles, dates, firms, tools, or quantified details.


reasoning: The paragraph primarily describes the company’s cybersecurity programs, controls, testing, and risk oversight processes, so it is best categorized as Risk Management Process. Although the CISO is mentioned, the focus is on what the programs do rather than the individual’s qualifications or reporting line.


reasoning: The paragraph is primarily about the company's general cybersecurity risk posture and protective measures, along with possible consequences of a cyber event. It does not describe an actual incident, board oversight, management roles, or vendor oversight as the central topic.


reasoning: The paragraph discusses the potential business and financial impact of a hypothetical future cybersecurity incident and includes a cross-reference to Risk Factors, rather than describing governance, management roles, or a real incident. It contains only generic materiality language with no qualifying specific facts.


reasoning: The paragraph describes an actual cybersecurity incident, including the alleged unauthorized access, exfiltration of information, public release of data, and response actions taken. It does not include qualifying specific facts such as dates, named firms, named systems/tools, or quantified details.


reasoning: The paragraph is a standalone materiality statement about how cybersecurity threats could affect operations, strategy, results, or financial condition, without describing governance, management roles, or specific risk processes. It contains only generic boilerplate language and no qualifying specific facts.


reasoning: The paragraph is framed around the CEO's role in briefing the Audit Committee, making management the grammatical subject. However, it does not discuss qualifications or a cybersecurity-specific officer, and the substance is still fairly generic governance disclosure.


reasoning: The paragraph’s central topic is the company’s oversight of cybersecurity risks arising from third-party service providers, including diligence, monitoring, and contractual requirements. It contains no qualifying firm-specific facts, named frameworks, dates, tools, firms, or other verifiable details.


reasoning: The paragraph mainly describes the company's internal approach to cybersecurity risk as minimal and references use of basic security features in standard software, which fits risk management processes more than governance or management-role disclosure. The CEO mention is incidental and generic rather than a substantive management-role discussion.


reasoning: The paragraph is primarily about which members of management lead cybersecurity processes and their qualifications/experience, so Management Role is the best fit. Although it mentions reporting to the Audit Committee, the core focus is the backgrounds of management personnel rather than board oversight.


reasoning: The paragraph primarily provides a materiality assessment stating that the company is not aware of cybersecurity threats that have materially affected or are reasonably likely to materially affect the business, with supporting cautionary language and risk factor cross-references. It does not describe governance roles, management qualifications, or concrete risk management processes.


reasoning: The paragraph is primarily framed around committee and full Board oversight, reporting, and cybersecurity briefings, so Board Governance is the best fit. Although it also describes management responsibilities, those details are secondary to the Board-focused oversight narrative.


reasoning: The paragraph's main point is a materiality assessment stating that no known cybersecurity incidents have materially affected or are reasonably likely to affect the company. It does not describe a specific incident or substantive cyber process, and the Risk Factors reference is only ancillary.


reasoning: The paragraph's main subject is the Company's oversight of cybersecurity threats arising from third-party vendors, service providers, and other external users, making third-party risk the central topic. It contains no qualifying specific facts such as named firms, dates, tools, committees, or quantified details.


reasoning: The paragraph is primarily about the company's overall cybersecurity risk environment and its general approach to addressing those threats through risk management, strategy, and governance. It does not describe board oversight, management qualifications, a specific incident, or vendor oversight as the central topic.


reasoning: The paragraph is primarily about the CISO and supporting personnel—their role, experience, and qualifications—so Management Role is the best fit. It also includes multiple concrete, verifiable facts such as ISO/IEC 27001:2022 certification and the CISO's 28+ years of experience.


reasoning: The paragraph primarily describes the bank’s internal cybersecurity activities and controls, such as monitoring, training, testing, audits, and incident planning. References to third parties and cyber insurance are ancillary components of the overall program rather than the central topic.


reasoning: The paragraph focuses on the company's internal cybersecurity coordination and risk-management forum, including who participates and its purpose, rather than board oversight or the qualifications of a specific executive. It contains firm-specific facts such as a named cybersecurity committee, the CISO's role, and a detailed cross-functional team composition.


reasoning: The paragraph primarily describes the company’s internal cybersecurity and incident response processes, including how incidents are managed, tested, classified, and escalated. Although a board committee is mentioned, the main focus is the operational risk management process rather than board oversight.


reasoning: The paragraph primarily describes the company's internal incident response and escalation process, with board notification mentioned only as one step within that process. It contains no qualifying specific facts such as named roles, committees, frameworks, dates, tools, firms, or quantified details.


reasoning: The paragraph describes an actual cybersecurity incident, including when it was detected and that an unauthorized third party gained access to company information systems. Although it mentions expenses and external experts, the only qualifying specific fact is the exact detection date.


reasoning: The paragraph is primarily about the company’s ongoing updating of cybersecurity processes to address evolving regulations and best practices, which fits Risk Management Process. The statement that no cybersecurity incident occurred in 2024 is not an incident narrative, so it does not fit Incident Disclosure.


reasoning: The paragraph is centrally about assessing and managing cybersecurity risks posed by third-party service providers, including due diligence and contractual security requirements imposed on vendors. It does not include any qualifying firm-specific facts, named frameworks, dates, or other verifiable details.


reasoning: The paragraph mainly provides a materiality-related statement that cyber incidents have not materially disrupted the business and cross-references risk factor disclosures about potential effects on business strategy, results of operations, and financial condition. It does not describe governance, management roles, or a concrete incident narrative.


reasoning: The paragraph is primarily about how the Audit Committee and full Board receive cybersecurity-related updates and reports, making board oversight the central topic. It contains only generic governance references and cadence language, with no qualifying specific facts under the rubric.


reasoning: The paragraph is primarily about the company’s internal cybersecurity program and how cyber risk is identified, assessed, and managed through its ERM structure. Although it mentions board oversight and named executives, those references support the description of the overall risk management function rather than making governance or management qualifications the main topic.


reasoning: The paragraph is primarily about how the company organizes and operates its internal cybersecurity risk management program, including the committee structure and multidisciplinary response process. Although it names a leadership role, the focus is on the functioning of the process rather than the qualifications or background of a specific executive.


reasoning: The paragraph primarily describes how cybersecurity risks are assessed, identified, and managed through the company's reliance on IHM's cybersecurity program and related controls, making it a risk management process disclosure. It is firm-specific because it names IHM as the entity implementing the strategy, and also references the NIST Cybersecurity Framework.


reasoning: The paragraph describes the company's internal cybersecurity detection and incident response processes, including escalation, containment, mitigation, and restoration activities. It does not focus on board oversight, management qualifications, third-party oversight, or any actual incident.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management approach, including ERM integration and use of recognized frameworks, rather than focusing on board oversight or a specific management role. The only qualifying specific fact is the reference to NIST, which makes the disclosure sector-adapted rather than generic.


reasoning: The paragraph is primarily about the Board's oversight role and the information it receives regarding cybersecurity, making Board Governance the best fit. It includes firm-specific cybersecurity roles (CTO and CISO), which makes it more specific than generic boilerplate.


reasoning: The paragraph focuses on the company’s internal cybersecurity controls, monitoring tools, assessments, and resilience processes, so it is best categorized as Risk Management Process. Although it mentions third parties and a Qualified Security Assessor, those references are part of the broader internal program and do not add qualifying firm-specific facts under the rubric.


reasoning: This paragraph primarily describes an actual event, including what occurred, the company’s response, and the resulting loss, which makes Incident Disclosure the best fit. It includes two verifiable facts—a specific time reference (early in Fiscal 2024) and a quantified loss of $2.7 million—supporting Quantified-Verifiable specificity.


reasoning: The paragraph describes the company's internal cybersecurity activity—monitoring threat intelligence to identify and mitigate risks—so it fits Risk Management Process. It contains no named frameworks, roles, dates, tools, firms, or other firm-specific facts, making it Generic Boilerplate.


reasoning: This paragraph primarily describes a real cybersecurity incident, including the malware event, containment, server rebuild, resulting outage, and operational consequences. Although it also includes materiality and financial impact statements, the dominant content is the incident narrative and its effects.


reasoning: The paragraph is primarily about the CISO as a person—his title, reporting line, education, certifications, and experience—so Management Role is the best fit. It includes multiple concrete, externally checkable facts about the executive and credentials, supporting a Quantified-Verifiable rating.


reasoning: The paragraph primarily describes the company’s internal cybersecurity review, audit, and assessment processes, with board approval mentioned as part of that process rather than as the main subject. The named FFIEC Cybersecurity Assessment Tool makes the disclosure more specific than boilerplate, but it does not include firm-unique verifiable details.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management activities, controls, assessments, training, and monitoring processes. Although it mentions a management title and vendor due diligence, the central focus is the company's overall risk management process rather than the person or third-party oversight alone.


reasoning: The paragraph focuses on financial impact and insurance reimbursement related to a prior incident, along with a materiality conclusion, rather than describing the incident itself. It contains no qualifying specific facts such as dates, amounts, named firms, tools, or cybersecurity-specific roles.


reasoning: The paragraph focuses on the business significance and potential operational, reputational, legal, and financial effects of cybersecurity threats rather than describing board oversight, management roles, or concrete risk-management processes. Its references to evaluating effects on business strategy, operations, and financial condition make Strategy Integration the best fit.


reasoning: The paragraph is centered on the CISO's role, responsibilities, and reporting line, which makes Management Role the best fit. It also names firm-specific cybersecurity roles/teams, but does not include two or more hard verifiable facts needed for Quantified-Verifiable.


reasoning: The paragraph is primarily about how senior governing bodies receive cybersecurity reporting and updates, making board-level oversight the central topic. Although management functions are mentioned, they are described mainly in service of informing the Management Board and Supervisory Board committee.


reasoning: This paragraph primarily describes an actual cybersecurity incident, including when it occurred, what systems were affected, response actions taken, and subsequent disclosure of data extraction. It includes two specific dates, which makes the disclosure Quantified-Verifiable.