reasoning: The paragraph's central topic is how the company manages third-party service providers — both engaging them and imposing security requirements (certification of security measures, breach reporting obligations) — making TP the best fit over RMP. Despite discussing cybersecurity procedures and safeguards, the language is entirely generic business/risk management vocabulary with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me classify this paragraph.

Content: Describes third-party service providers in two contexts: (1) consultants hired to help the company's own security program (design, implement, monitor, test), and (2) requirements imposed on third-party service providers (certify ability, maintain security measures, report breaches).

Category: This is a mix of RMP (third parties serving the company's program) and TP (requirements imposed on vendors). The first two sentences describe consultants helping the company → RMP. The third sentence describes requirements imposed on service providers → TP. The TP content (requirements imposed on third parties) is substantial - the entire last sentence.

Looking more closely at the structure, the opening sentences about engaging consultants for the company's risk assessment and safeguard processes are clearly RMP, while the requirements sentence that follows—about certifying abilities and maintaining security measures—shifts into TP territory. The paragraph essentially moves from describing how the company uses third parties to support its own program, then transitions into what the company demands from those same providers.

Scanning through for specificity, I'm seeing mostly generic language: "risk assessment processes," "cybersecurity procedures," "monitor and test our safeguards," "certify," "security measures." These are all L1 terms without concrete details about what's actually being done or measured.


content_category: Third-Party Risk

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph describes engaging third-party service providers and imposing security requirements on them (certification of security measures, compliance with laws, breach reporting obligations), making TP the primary focus despite the first two sentences describing consultants serving the company's own program (which would be RMP). The requirements-on-vendors content in the lengthy third sentence tips the balance toward TP. All language is generic business/contractual terminology—no cybersecurity domain terms (fails ERM test), no firm-specific facts, no verifiable claims—yielding Level 1.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: Describes engaging third-party consultants for risk assessment, designing/implementing cybersecurity policies, monitoring/testing safeguards, and imposing security requirements on service providers.

Category: This is a mix of RMP and TP. The first part describes third parties hired to serve the company (assessors helping design and implement the company's own program) → RMP per Rule 3. The second part describes requirements imposed ON those service providers → TP. Let me assess which dominates.

First two sentences: consultants helping the company's own program → RMP

Third sentence: requirements imposed on third-party service providers → TP

Looking at the structure more carefully, the consultants mentioned upfront and the service providers with imposed requirements appear to be the same entities. The paragraph's real focus is on third-party oversight—both engaging them and establishing security requirements for them. That emphasis on vendor requirements tips this toward TP.

But Rule 3 complicates things: consultants helping with the company's own security program should be RMP. The first two sentences clearly fit that. However, the third sentence—which is the longest and most substantive—shifts to requirements imposed on those vendors, which is distinctly TP territory. Given the weight of detail in that final sentence and the overall framing around managing third-party relationships, TP seems like the stronger call.

Now I'm scanning for specificity. The language is all generic: risk assessment processes, cybersecurity policies, monitoring and testing safeguards, breach reporting. No domain terminology, no firm-specific facts, nothing that rises above standard boilerplate. This is clearly Level 1 material.

So the classification is Third-Party Risk, Generic Boilerplate.


category_confidence: high

reasoning: The entire paragraph answers 'how are third-party cyber risks managed?' — describing due diligence of service providers, contractual security requirements imposed on vendors, and incident notification obligations. The language is entirely general business/legal terminology (risk-based due diligence, reasonable security controls, contractual requirements); no cybersecurity domain terms pass the ERM test, no firm-specific cybersecurity facts are present (Cheniere is the parent company name, not a cybersecurity-distinguishing fact), and no verifiable claims exist.

thinking:
Let me analyze this paragraph.

Content: About third-party service provider oversight - due diligence, contractual requirements, incident notification requirements imposed on vendors.

Category: Third-Party Risk - clearly answers "How are third-party cyber risks managed?" The entire paragraph is about requirements imposed ON vendors.

Specificity:
- "information security program" - general
- "risk-based due diligence" - general
- "security controls" - general
- No domain terminology that passes ERM test
- No firm-specific facts (Cheniere is the parent company name, not a cybersecurity-specific fact)
- No QV facts

- "information security program" and "information security incidents" are standard IT/business terms, not domain-specific language

This is generic vendor oversight language throughout - no domain terms, no firm-specific cybersecurity facts, no verifiable claims. Level 1.


content_category: Risk Management Process

fact: penetration testing

fact: ISAT (named internal team)

reasoning: Third parties are hired to serve the company's own security program (assessments, pen testing, monitoring), making this RMP per Rule 3 rather than TP. The named internal team 'ISAT' is a firm-specific fact elevating to Level 3, with 'penetration testing' as supporting domain terminology.

thinking:
Let me analyze this paragraph.

Content: Describes third-party consultants helping with cybersecurity - assessing, testing, enhancing, monitoring. They work with ISAT. Examples include risk assessments and penetration testing.

Category: The third parties here are hired to serve the company's own security program (assessors, pen testers) → RMP per Rule 3. The central topic is how the company's program uses third parties as a component, not vendor oversight.

Specificity:
- "ISAT" - this is a named internal team/committee → firm-specific (Level 3)

- "penetration testing" and "risk assessments" are standard industry terms, but ISAT pushes this to Level 3 overall.


content_category: Management Role

fact: CISO

fact: over 30 years of experience in cybersecurity

type: quantified

fact: United States Navy

fact: Amgen

fact: Warner Bros

fact: KPMG

fact: Forrester

reasoning: The paragraph primarily answers 'how is management organized?' — it describes the CISO's responsibilities, qualifications, and career history. Person-removal test: removing the CISO, experience, and career details leaves only a thin program mention, confirming MR. Specificity is Level 4 due to multiple verifiable facts: 'over 30 years' (lower-bound quantified), and named external entities (US Navy, Amgen, Warner Bros, KPMG, Forrester) where prior employment can be independently verified.

thinking:
Let me analyze this paragraph.

Category: This describes the CISO's role, responsibilities, qualifications, and career history. Person-removal test: remove CISO, titles, qualifications, experience, career history → "our information security program... cybersecurity strategy, policy, architecture, and risk management processes" — some program description remains but the bulk is about the person. The primary question answered is "How is management organized to handle cybersecurity?" → MR.

Specificity: Let me scan for facts:
- CISO (named_role) → firm-specific

- Over 30 years of experience, plus specific roles at the US Navy, Amgen, Warner Bros, KPMG, and Forrester — all verifiable details that anchor this to particular individuals and organizations. Level 4.


content_category: Strategy Integration

reasoning: The paragraph states a backward-looking materiality conclusion ('has not experienced any unauthorized access resulting from cybersecurity incidents with a materially adverse effect on our business, operations, or financial condition'), which is an SI assessment per Rule 5. The cross-reference to Item 1A is subordinate. No domain terminology passes the ERM test — 'cybersecurity posture,' 'cybersecurity measures,' and 'unauthorized access' in a negative assertion context are general business language. No firm-specific or verifiable facts present.

thinking:
Let me analyze this paragraph.

Content: Generic posture statement, negative materiality assertion, and cross-reference to Item 1A.

Category: The key sentence is "Our organization has not experienced any unauthorized access resulting from cybersecurity incidents with a materially adverse effect on our business, operations, or financial condition" — this is a backward-looking materiality assessment → SI per Rule 5.

The cross-reference to Item 1A is subordinate to the materiality assessment.

Specificity: Let me scan for facts:
- "unauthorized access" — this is a threat type... but in context it's a negative assertion, not describing a program

- The language here is purely self-referential and unverifiable — no external facts or domain-specific details
- Terms like "cybersecurity posture" and "cybersecurity incidents" are just topic qualifiers without substantive content
- There are no firm-specific facts or quantifiable metrics that would indicate real disclosure

This is clearly Generic Boilerplate (Level 1). The materiality assessment itself is just standard language without any meaningful substance.


reasoning: The opening sentence states a materiality conclusion — both backward-looking ('have not materially affected') and forward-looking ('reasonably likely to materially affect') — making this SI per the materiality assessment rule. The remaining text is generic speculation ('could affect') and a cross-reference to Item 1A, which are subordinate. No domain terminology, firm-specific facts, or verifiable claims are present; the negative materiality assertion is a self-reported claim about absence, not externally verifiable.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. "To date, we have not identified any cybersecurity incidents or threats that have materially affected us or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition." — This is a materiality assessment (backward-looking + forward-looking). → SI

2. "However, like other companies in our industry, we and our third-party vendors may, from time to time, experience threats and security incidents that could affect our information or systems." — Generic speculation.

3. Cross-reference to Risk Factors. — N/O

The opening statement is a clear materiality assessment under Rule 5, while the rest is just boilerplate speculation and a cross-reference. The substantive content here is that materiality statement. Looking at the specificity, it's a negative self-assertion with no externally verifiable facts, domain-specific details, or firm-specific information — that puts it at Level 1.


content_category: Incident Disclosure

fact: January 2021 - date when unauthorized access was discovered

reasoning: The paragraph primarily describes what happened in an actual cybersecurity incident — unauthorized access to IT systems hosted by a third-party cloud provider, compromise of source code and credentials, and an extortion threat — making it Incident Disclosure. While the final sentences include a materiality assessment ('do not believe… material adverse effect'), the incident narrative dominates. 'January 2021' is a specific date tied to a real cybersecurity event, elevating specificity to Level 4.

thinking:
Analyzing this paragraph from Ubiquiti's 10-K filing.

Content: Describes a past cyber incident (January 2021), unauthorized access to IT systems hosted by a third-party cloud provider, source code and credentials compromised, extortion threat, and materiality assessment.

Category: This describes an actual incident (January 2021 unauthorized access) with details about what happened, plus a materiality assessment. The dominant frame is the incident narrative - timeline, what was accessed, the threat, and then a materiality conclusion. The incident description dominates, with the materiality assessment being subordinate. → **Incident Disclosure**

The January 2021 date is a specific temporal marker tied directly to the cybersecurity event, which qualifies as quantifiable value. The paragraph provides concrete details about what occurred, placing it at Level 4 specificity.


content_category: None/Other

reasoning: The paragraph acknowledges past incidents only in the most generic terms ('have occurred in the past') without describing any specific event, and then cross-references Item 1A. There is no substantive cybersecurity disclosure — no program details, no governance structure, no materiality assessment (just speculation with 'may continue to occur'). The cross-reference to Item 1A is the hallmark of N/O. No domain terminology or firm-specific facts are present.


reasoning: The first sentence states a backward-looking and forward-looking materiality conclusion ('have had, or are reasonably likely to have, a material adverse effect') — this is the SEC's Item 106(b)(2) assessment language, making it SI. The subsequent speculation ('could have a material adverse effect') and Item 1A cross-reference are subordinate. The date 'February 27, 2025' is just the filing date anchoring the assertion, not a cybersecurity-specific fact; the negative materiality assertion is not externally verifiable; no domain terminology or firm-specific facts appear, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: The paragraph states a materiality assessment conclusion ("do not believe that any risks from cybersecurity threats...have had, or are reasonably likely to have, a material adverse effect"), then hedges with speculation ("could have a material adverse effect"), then cross-references Item 1A.

Category: The first sentence is a clear materiality assessment → SI per Rule 5. The speculation and cross-reference are subordinate.

Specificity: "As of February 27, 2025" - this is a specific date, but is it a cybersecurity fact or just a reporting context date? It's anchoring the materiality assessment.

The filing date anchors this to reporting period context rather than a specific cybersecurity fact. The negative assertion about material adverse effects isn't externally verifiable and lacks domain-specific or company-specific details, so this falls into Level 1.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing requirements imposed on vendors (contractual obligations, cybersecurity audits), making it TP. Despite discussing third-party oversight, the language is entirely generic business/ERM vocabulary ('processes to address,' 'enterprise risk management,' 'contractual requirements,' 'cybersecurity audits') with no domain terminology, no firm-specific facts, and no verifiable claims, leaving it at Level 1.

thinking: Third-party risk management is the central topic.


fact: CDO (Chief Digital Officer)

fact: joined MPC in 2021

fact: GE and its subsidiary companies

fact: over 20 years at GE

fact: named SVP and CIO of Services for GE in 2017

fact: GE Healthcare

reasoning: The paragraph is entirely about the CDO's qualifications, career history, and relationship to the CISO — person-removal leaves nothing substantive, confirming MR. Multiple QV-eligible facts: specific years of experience (20+), named external firms (GE, GE Healthcare), specific dates (2021, 2017), and a verifiable degree.

thinking:
Let me analyze this paragraph.

Content: Describes the CDO's qualifications, experience, career history, and relationship to the CISO. This is clearly about management's organizational role - specifically qualifications and career background.

Category: Management Role (MR) - person-removal test: remove all person-specific content and nothing remains.

Specificity: Let me scan for facts.
- CISO (named role, firm-specific)
- CDO (named role, firm-specific)
- "more than 20 years of executive IT leadership experience" - quantified, lower bound verifiable

- Joining MPC in 2021 with a specific date, prior tenure at GE spanning over 20 years, including roles as Senior Vice President and Chief Information Officer of Services for the parent company in 2017 and Vice President and Chief Information Officer of GE Healthcare - all named firms with specific dates
- Bachelor's degree in Business Administration, Management and Information Systems - verifiable credential

Level 4 - multiple quantified and verifiable facts throughout the career history.


reasoning: The first sentence states a materiality conclusion ('did not experience a material cybersecurity incident'), making this SI per the negative-assertion rule; the cross-reference to Item 1A is subordinate. The fiscal year date is reporting-period context (not a cybersecurity fact), and the negative assertion about no material incidents is a self-reported claim about absence—not externally verifiable—leaving no facts to elevate above Level 1.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. "We did not experience a material cybersecurity incident during the fiscal year ended December 27, 2024." - This is a negative assertion about materiality → SI per the materiality rule.
2. "For more information on risks from cybersecurity threats... see... Item 1A" - This is a cross-reference → N/O.

The first sentence IS a materiality assessment (negative assertion: "did not experience a material cybersecurity incident"). Per Rule 5, this is SI. The cross-reference is subordinate.

The statement is a generic negative assertion without any specific cybersecurity facts, domain terminology, or firm-specific details—just a boilerplate claim that no material incidents occurred during the reporting period. This qualifies as Level 1 generic boilerplate SI.


reasoning: This paragraph is a cross-reference pointing to a risk factor heading for the materiality discussion rather than stating a materiality conclusion itself. It describes what another section covers ('we describe whether and how risks... have materially affected...') rather than making an assessment, fitting the N/O rule for cross-references. No substantive cybersecurity disclosure is present, so specificity is Level 1.

thinking: Cross-reference pointing to another section for materiality discussion.


reasoning: The first sentence states a materiality conclusion — both backward-looking ('have not materially affected') and forward-looking ('are not reasonably likely to materially affect') — making this SI per the materiality assessment rule. The remainder is speculation ('cannot eliminate all risks') and a cross-reference to Item 1A, both subordinate. No domain terminology, firm-specific facts, or verifiable claims: 'In 2024' is reporting-period context, and the negative self-assertion about no material incidents is not externally verifiable, so specificity stays at Level 1.

thinking:
Let me analyze this paragraph.

Content: States no material cybersecurity threats in 2024, acknowledges residual risk, cross-references Item 1A.

Category: The first sentence states a conclusion about whether cybersecurity has materially affected business outcomes - this is a materiality assessment (backward-looking + forward-looking). That's Strategy Integration per Rule 5. The rest is speculation/cross-reference which would be N/O, but the materiality assessment dominates.

Specificity:
- "In 2024" - reporting period context, not a specific cybersecurity fact
- "have not...

The language here is purely negative assertion without external verification—no technical terminology, no company-specific details, no quantifiable facts. The cross-reference to Item 1A is generic boilerplate, and the speculation about potential material adverse effects is standard risk language. This is clearly Level 1 disclosure.


fact: Chief Technology Officer (CTO) as cybersecurity-responsible role

fact: security architecture

fact: over 15 years of experience in software development and security architecture

reasoning: The paragraph answers 'how is management organized?' by describing the CTO's responsibilities, experience, and reporting line to General Counsel. Person-removal test: removing CTO, experience, and reporting structure leaves only generic process language ('establishment and maintenance of cybersecurity risk management processes'), so it collapses → MR. Specificity reaches Level 4 because 'over 15 years of experience' is a verifiable lower bound (checkable against resume/LinkedIn).

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the CTO's role, responsibilities, experience, and reporting line to General Counsel. Person-removal test: remove CTO, 15 years experience, reporting to General Counsel → "the establishment and maintenance of our cybersecurity risk management processes, including the day-to-day oversight of the assessment and management of cybersecurity risks" and "discuss and review our information security and cybersecurity risk management processes." The remaining text is generic process language, not substantive program description. The paragraph is primarily about WHO is responsible and HOW management is organized → MR.

Specificity:
- "Chief Technology Officer" → CTO is a firm-specific cybersecurity leadership role (VP-level or above)

- "over 15 years of experience" → lower bound, verifiable → QV
- "software development and security architecture" → "security architecture" is domain terminology
- "General Counsel" → NOT firm-specific per codebook

So Level 4 due to "over 15 years of experience" being a verifiable lower bound.


fact: service provider oversight committee

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — it describes vendor selection, due diligence, monitoring, security assessments, and contingency planning for service providers, making TP the clear category. The 'service provider oversight committee' is a named non-generic committee (firm-specific, Level 3), but the remaining language (due diligence, ongoing monitoring, questionnaires, onsite visits) is general oversight vocabulary that any ERM professional would use, so no domain terminology elevates beyond Level 3. No QV-eligible facts are present.

thinking:
Let me analyze this paragraph.

Content: This is about oversight of third-party service providers - vendor oversight committee, policies, due diligence, monitoring, security assessments of vendors.

Category: Third-Party Risk (TP) - the central topic is oversight of external parties/vendors.

Specificity: Let me scan for facts.
- "service provider oversight committee" - this is a named non-generic committee → firm-specific (Level 3)
- "Security assessments" - includes "questionnaires, meetings and onsite visits" - these are general process descriptions, not domain terminology
- The rest is general oversight language (due diligence, contracting, monitoring)

- No domain-specific ERM terminology here, just standard business language like "security assessments," "due diligence," and "ongoing monitoring"
- The only firm-specific element is that named committee, which puts this at Level 3
- No quantifiable facts either - no numbers, dates, external certifications, or named third parties


reasoning: This is introductory framing that acknowledges cybersecurity threats exist and resources are needed, but does not answer any of the six substantive questions. The materiality language ('could materially adversely affect') is speculation per the codebook, not an assessment (Rule 5), and no actual cybersecurity measures, processes, or organizational details are described. While ransomware and denial-of-service are domain terms, N/O paragraphs always receive Specificity 1.

thinking:
Let me analyze this paragraph.

Content: The paragraph discusses cybersecurity as important to the company, mentions threat types (ransomware, denial-of-service), notes third parties face similar threats, and says an incident "could materially adversely affect" the business. It concludes they need to spend resources on cybersecurity.

Category: What question does this primarily answer? It's general framing about why cybersecurity matters. It mentions threats but doesn't describe what the program does. The materiality language is "could materially adversely affect" — that's speculation, not an assessment (Rule 5). It's not describing board oversight, management roles, program activities, third-party management, or an actual incident.

The boilerplate language about potential material adverse effects appears in every 10-K and doesn't constitute substantive disclosure. While the paragraph does reference specific threat vectors like ransomware and denial-of-service attacks, it stops short of describing any actual cybersecurity measures, controls, or processes. This is just generic risk acknowledgment without the operational detail needed for Strategy Integration classification. The paragraph doesn't actually describe any substantive cybersecurity measure, process, or assessment — it's just general framing that threats exist and resources are needed. Looking at what it covers: it states cybersecurity matters, lists threat types like ransomware and DoS, mentions third-party risks, uses speculative language about potential business impact, and notes the need for spending. But none of this answers the core substantive questions about what the board oversees, what management does, how the program operates, or how third-party risk is managed. This feels like introductory language without real disclosure, so N/O seems right.


fact: information security division

fact: third-party risk management unit

specificity_confidence: medium

reasoning: The paragraph's central topic is how the company oversees and assesses cybersecurity risks from third-party service providers — squarely answering 'How are third-party cyber risks managed?' → TP. Two named organizational units ('information security division' and 'third-party risk management unit') are firm-specific team identifiers that distinguish this company's structure, elevating to Level 3. No QV-eligible facts (no numbers, dates, named external firms, or certifications). The remaining language (risk-based approach, onboarding assessments, control evaluations) is general risk management vocabulary that fails the ERM test for domain terminology.

thinking:
Let me analyze this paragraph.

Content Category: This is clearly about third-party risk management. The central question answered is "How are third-party cyber risks managed?" - it describes vendor oversight processes, assessments of service providers, and how the company evaluates third-party security posture. → Third-Party Risk

Specificity: Let me scan for facts.

- "information security division" - this is a named team/department → firm-specific
- "third-party risk management unit" - named organizational unit → firm-specific
- "cybersecurity assessments" - general process language

- "risk-based approach" - generic
- "onboarding, ongoing monitoring, contract renewal" - generic cadences

The organizational units like the information security division and third-party risk management unit are firm-specific identifiers, but most of the language around processes and controls is standard risk management terminology. There are no quantifiable facts, dates, or external certifications mentioned. The audit-related language about operational effectiveness of IT and security controls is fairly generic across the industry.

So this lands at firm-specific level because of those named internal teams, even though the actual practices described are standard.


reasoning: The first sentence states a backward-looking conclusion about materiality ('No unauthorized access...material adverse effect on our business, operations, or consolidated financial condition'), making this SI per Rule 5. The second sentence is generic speculation ('could have') and the third is a cross-reference, both subordinate. No domain terminology, firm-specific facts, or verifiable claims are present—'unauthorized access' and 'cybersecurity incidents' are general business language, and the negative assertion is not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: Mixed paragraph with three parts:
1. "No unauthorized access...material adverse effect" - backward-looking materiality assessment (negative assertion)
2. "If our systems...could have a material adverse effect" - speculation ("could have")
3. "See additional information...Item 1(a)" - cross-reference

The first sentence states a conclusion about materiality (backward-looking negative assertion) → SI per Rule 5.
The second sentence is speculation ("could have") → NOT SI.
The third sentence is a cross-reference → N/O.

The primary content is the materiality assessment in sentence 1.

This is clearly generic boilerplate—the language about unauthorized access and cybersecurity incidents lacks any firm-specific details, domain expertise, or quantifiable facts. It's a self-assertion without external verification, and the cross-reference to Item 1(a) doesn't add substantive content. This falls squarely into Level 1 boilerplate territory.


fact: Energy Transfer's Chief Information Officer (CIO)

fact: more than 35 years of experience leading business technology functions

fact: over 50 years of combined experience in IT

fact: 20 years dedicated to cybersecurity

fact: GICSP certification

fact: CISSP certification

fact: CEH certification

fact: average of over 25 years of experience in IT operations

fact: over 10 years of experience in IT security

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — detailing the CIO's role, IT team qualifications, credentials, and experience levels. Person-removal test confirms MR: removing roles, qualifications, and experience leaves almost no content. Multiple QV-eligible facts drive Level 4: specific years of experience (35, 50, 20, 25, 10) as verifiable lower bounds, plus named certifications (GICSP, CISSP, CEH) verifiable through issuing bodies.

thinking:
Let me analyze this paragraph.

Content: Describes management roles - Energy Transfer's CIO, IT team experience, certifications, USAC's IT department leadership. This is about how management is organized and qualified.

Category: Management Role (MR) - primarily about who handles cybersecurity, their qualifications, experience, and credentials. Person-removal test: remove all person-specific content and very little remains beyond "shared services cybersecurity program" and "internal cybersecurity program."

Specificity: Let me scan for facts:
- CIO (cybersecurity-specific title at VP+ level) → firm-specific

- Multiple quantified experience metrics across the team: years in IT operations, cybersecurity-specific experience, and professional certifications like GICSP, CISSP, and CEH that are all verifiable.

Level 4 - multiple QV facts.


fact: Chief Security Officer (CSO) role

fact: Chief Information Security Officer (CISO) role referenced

fact: more than 20 years in information security

reasoning: The paragraph primarily describes the qualifications, career history, and team support structure of Deutsche Bank's Chief Security Officer — person-removal test leaves near-nothing substantive, confirming MR. 'More than 20 years' is a verifiable lower bound and 'three different large European financial institutions' is a specific quantity, elevating to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes Deutsche Bank's Chief Security Officer's qualifications and experience, plus team composition.

Category: This is about management's qualifications and experience - MR. Person-removal test: remove the CSO's experience, roles, qualifications → "security requirements are met from a regional, divisional, and technical perspective" - near nothing substantive remains. → MR.

Specificity:
- "Chief Security Officer" - named role (firm-specific)
- "CISO" / "CSO" - firm-specific cybersecurity roles

- "More than 20 years" and "three different large European financial institutions" are both quantified and verifiable, while the reference to a global strategy firm lacks specificity. Level 4.


content_category: Board Governance

fact: CISO

fact: Risk and Compliance Committee

fact: Chief Legal Officer

reasoning: The paragraph describes the oversight chain: CISO reports to the Risk and Compliance Committee, which reports to the Board — this is a governance-chain paragraph answering 'how does the board oversee cybersecurity?' The CISO and Risk and Compliance Committee are firm-specific facts (the latter is a non-generic committee), but there are no QV-eligible facts (quarterly is a generic cadence, no specific dates or verifiable claims).

thinking:
Let me analyze this paragraph.

Category: The paragraph describes how information flows from CISO → Risk and Compliance Committee → Board. This is about oversight structure and information flow to the board. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

The CISO is mentioned but as part of the reporting/oversight chain, not about their qualifications or organizational role.

Specificity:
- "CISO" → firm-specific (named_role)
- "Risk and Compliance Committee" → named non-generic committee → firm-specific (named_committee)

- "Chief Legal Officer" is a general role without cybersecurity specificity, and "quarterly" is just a standard reporting cadence, so neither adds firm-specific detail. No QV facts are present, but the named committee and CISO reference push this to Level 3.


fact: IT Committee

reasoning: The paragraph describes what the committee and engaged experts DO — identify improvements, assess security layers, evaluate technologies — making it about program activities (RMP) rather than committee structure (MR). The IT Committee is a named non-generic committee (firm-specific), but the remaining language is generic with no domain terminology or verifiable facts.

thinking:
Let me analyze this paragraph.

Content: Describes IT Committee meetings for improvements and engaging cybersecurity experts to assess policies/infrastructure.

Category: The paragraph describes what the cybersecurity program does - assessing, improving, evaluating technologies. The IT Committee is mentioned but in the context of activities, not structure/membership. Person-removal test: remove "IT Committee" - still describes improvement processes and engaging experts. This is RMP.

Wait - "IT Committee" could be a management-level committee. But the paragraph focuses on what the committee DOES (identifies improvements, assesses security layers, evaluates technologies) rather than who's on it or how it's structured.

The engagement of cybersecurity experts to evaluate the company's own security posture points to RMP rather than TP. For specificity, "IT Committee" is a named non-generic committee similar to "Technology Committee" or "Cybersecurity Committee," making it firm-specific at Level 3. The other elements—unnamed cybersecurity experts and generic activity descriptions—don't add specificity, and there are no QV facts present.


reasoning: The paragraph states both a backward-looking materiality conclusion ('have not... materially affected') and a forward-looking assessment ('reasonably likely to materially affect'), making it SI per the materiality assessment rule. The cross-reference to Item 1A is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — purely boilerplate materiality language.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. "We have not identified risks from known cybersecurity threats... that have materially affected or are reasonably likely to materially affect us" — backward-looking materiality assessment → SI
2. "We face certain ongoing risks from cybersecurity threats that, if realized, are reasonably likely to materially affect us" — forward-looking materiality assessment → SI
3. Cross-reference to Item 1A risk factors → N/O

The first two sentences are materiality assessments (both backward and forward-looking), making this SI. The cross-reference is subordinate.

This is just generic boilerplate language without any firm-specific details or concrete examples—no domain terminology, no verifiable claims, just standard materiality language. That puts it at the lowest specificity level.


reasoning: This paragraph is a cross-reference pointing to another section for the materiality assessment rather than stating a conclusion itself. Per the N/O vs SI rule, 'risks that may materially affect... see [elsewhere]' is N/O because it points elsewhere rather than making an assessment. The paragraph contains no substantive cybersecurity disclosure, only a reference to where such disclosure can be found.


reasoning: The paragraph states a materiality conclusion — 'we do not believe we have been materially affected' and 'not reasonably likely to materially affect us' — which is both a backward-looking and forward-looking assessment per the SI materiality rule. The remaining content (generic risk-based approach, limitations of controls, cross-reference to Item 1A) is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — all language is generic business/ERM vocabulary.

thinking:
Let me analyze this paragraph.

Content: The paragraph discusses experiencing cybersecurity incidents (generic), classification and tracking of incidents, a materiality assessment ("do not believe we have been materially affected" and "not reasonably likely to materially affect us"), risk-based approach mention, limitations of controls, and a cross-reference to Item 1A.

Category: The key sentence is the materiality assessment - "we do not believe we have been materially affected by cybersecurity incidents or threats in the past, or that past incidents are reasonably likely to materially affect us." This is a backward-looking and forward-looking materiality conclusion → SI per Rule 5.

Scanning through the specific language, I'm not finding any concrete facts or firm-specific details—just standard boilerplate about cybersecurity incidents, risk management approaches, and control limitations. There's no domain expertise, no quantified metrics, and no company-particular information, which puts this squarely at Level 1 generality.


reasoning: This is a cross-reference directing readers to Item 1A for additional cybersecurity risk information, with no substantive cybersecurity disclosure of its own. N/O always receives Specificity 1.


reasoning: The paragraph states the company maintains cyber liability insurance, which answers how cybersecurity affects the business/finances (SI). However, it provides no specifics about the policy — no dollar amounts, named insurers, or coverage details — and the cross-reference is subordinate to the insurance claim. No domain terminology, firm-specific facts, or verifiable claims are present.


fact: penetration tests

fact: confidentiality, integrity and availability (CIA triad)

reasoning: The paragraph describes what the cybersecurity program does — security controls, risk-based architecture, risk register, penetration testing, backup/recovery — squarely answering 'what does the program do?' → RMP. Domain terms like 'penetration tests' and the CIA triad ('confidentiality, integrity and availability') pass the ERM test, but there are no named roles, firms, specific numbers, or other firm-specific or verifiable facts, keeping this at Level 2.

thinking:
Let me classify this paragraph.

Content: Describes security controls, technologies, risk-based approach, risk register, penetration testing, backup/recovery systems. This is about what the cybersecurity program does → RMP.

Specificity: Let me scan for facts.
- "penetration tests" → domain term
- "risk register" → this is more general risk management, but in cybersecurity context... actually "risk register" is generic ERM terminology
- "confidentiality, integrity and availability" → CIA triad, domain concept
- "annual penetration tests at each of our businesses" → "annual" is generic cadence, "each of our businesses" is somewhat firm-specific but not really

- "independent third parties to perform annual penetration tests" → third parties unnamed, penetration tests is domain
- "backup and recovery systems and disaster recovery" → general IT/business continuity terms, Level 1

The domain terminology here centers on penetration testing and the CIA triad, while the rest relies on generic risk management and IT continuity language. There's nothing that's clearly firm-specific—no named roles, committees, or unique organizational structures. No quantifiable details either. This lands at Level 2 based on the domain concepts present.


fact: Clarium Managed Services, LLC — named external firm that conducted the assessment

fact: 2022 — specific year the cybersecurity assessment was conducted

fact: Score of 4.8 on a scale of 0 to 5 — specific quantified assessment result

reasoning: The paragraph's arc moves from a third-party assessment (supporting evidence) to a materiality conclusion: 'have not materially affected, and are not reasonably likely to materially affect' — the SEC's Item 106(b)(2) language — making SI the primary purpose. Multiple QV-eligible facts drive Level 4: a named external firm (Clarium Managed Services, LLC), a specific year (2022), and a precise numerical score (4.8/5).

thinking:
Let me analyze this paragraph carefully.

**Content Category:**
This paragraph contains multiple elements:
1. Clarium assessment (RMP - third party assessing the company's own security)
2. "has not experienced any material cybersecurity incidents" - negative assertion with materiality
3. "No specific cybersecurity threats or incidents... have materially affected, or are reasonably likely to materially affect" - materiality assessment (SI)
4. Cross-reference to Item 1A

The materiality assessment language is classic SI (Rule 5). The Clarium assessment is RMP (third party hired to assess the company's OWN security → RMP per Rule 3).

The materiality assessment sentences form the paragraph's core conclusion, with the Clarium assessment functioning as supporting evidence. The structure flows from "we were assessed well" through "no material incidents" to "not materially affected and not reasonably likely to be" — fundamentally addressing how cybersecurity impacts the business, which points to SI rather than RMP.

Now I'm identifying the specific verifiable facts: the named firm Clarium Managed Services, the 2022 date, and the quantified score of 4.8 out of 5 are all concrete QV elements, while the soft timeframe and negative assertions don't meet the codebook's verifiability threshold. With multiple QV facts present, this lands at Level 4.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not materially affected us, including our business strategy, results of operations or financial condition'), which is an SI assessment per Rule 5. No domain terminology, firm-specific facts, or verifiable claims are present — the incident reference is entirely vague ('from time to time, experienced threats') and the cross-reference to Item 1A is subordinate to the materiality assessment.

thinking:
Let me analyze this paragraph.

Content: The paragraph makes a materiality assessment ("have not materially affected us, including our business strategy, results of operations or financial condition") and references past incidents vaguely, then cross-references Item 1A.

Category: The materiality assessment is the key statement here. "Have not materially affected us, including our business strategy, results of operations or financial condition" is a backward-looking materiality assessment → SI per Rule 5.

Specificity: Let me scan for facts:
- "have not materially affected us, including our business strategy, results of operations or financial condition" - this is a negative self-assertion, not verifiable

- The disclosure mentions vague security incidents and vendor threats without concrete details, just pointing to Item 1A for more information
- No domain-specific terminology, no company-specific facts, no quantifiable metrics

This is Level 1 disclosure.


reasoning: The paragraph answers 'How does the board oversee cybersecurity?' by describing delegation from the board to the audit committee for cybersecurity risk oversight. No domain terminology, firm-specific facts, or verifiable claims are present — 'board of directors,' 'audit committee,' and 'cybersecurity risk management program' are all generic governance language found at every public company.

thinking:
Classify this paragraph.

Category: Board governance - describes how the board oversees cybersecurity, delegation to audit committee.

Specificity: Let me check facts. "board of directors" - generic. "audit committee" - generic (every company has one). "cybersecurity risk management program" - generic. No domain terms, no firm-specific facts, no QV facts.

Level 1.


fact: vulnerability assessments

fact: Chief Information Security Officer (CISO)

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — the Audit Committee's oversight role, quarterly presentations to the board, prompt incident reporting, and annual discussions with the CISO all describe the board-level oversight structure. Specificity reaches Level 3 due to the CISO reference (firm-specific cybersecurity leadership role); 'vulnerability assessments' is a domain term but the CISO elevates it further.

thinking:
Let me analyze this paragraph.

Content: The Audit Committee oversees cybersecurity risks, management presents quarterly on various topics, Board receives prompt info on incidents, Board discusses cybersecurity with CISO annually.

Category: This is about how the board oversees cybersecurity - BG.

Specificity: Let me scan for facts.
- "Audit Committee" - NOT firm-specific (every public company has one)
- "vulnerability assessments" - domain term
- "Chief Information Security Officer" (CISO) - firm-specific named role

- "quarterly presentations" - generic cadence
- "At least once each year" - generic cadence

So I'm seeing a domain term with vulnerability assessments at Level 2, and the CISO reference pushes this to Level 3.


reasoning: This is a cross-reference directing readers to Item 1A for additional information, with no substantive cybersecurity disclosure. N/O always receives Specificity 1.


fact: IT Committee (named non-generic management committee)

fact: Executive Vice President and Chief Accounting Officer (CAO)

fact: Co-Chief Operating Officer (COO)

reasoning: Despite the heading 'Management's Role,' the bulk of the paragraph answers 'How does the board oversee cybersecurity?' — describing briefings to the Board, ongoing dialogue with the Board, and the Board's active participation in strategic cybersecurity decisions. Per Rule 1, management reporting TO the board (describing oversight flow) → BG. The named IT Committee and SVP of Information Technology are firm-specific facts (VP-level IT role and non-generic committee), but no QV-eligible facts are present (the 'minimum once per year' cadence is a generic frequency, not a specific verifiable date or number).

thinking:
Let me analyze this paragraph.

Content Category: This paragraph is titled "Management's Role Managing Risk" but the content describes how information flows to the Board and the Board's oversight. Let me apply the primary test.

The paragraph covers:
1. IT Committee with senior executives meets regularly to monitor cybersecurity issues (MR - management committee)
2. SVP of IT, EVP/CAO, and Co-COO inform the Board on cybersecurity risks (BG - information flow to board)
3. They provide briefings to the Board regularly, minimum once per year (BG)
4. Briefing topics listed (BG)

5. The Board maintains ongoing dialogue with management about emerging risks and actively participates in strategic cybersecurity decisions (BG)

Despite the heading saying "Management's Role," the bulk of the text answers "How does the board oversee cybersecurity?" — describing briefings to the board, board oversight, board participation in decisions. The IT Committee mention is brief. The management roles (SVP IT, CAO, COO) are mentioned primarily in the context of reporting TO the board.

Per Rule 1: "Management reports TO the board (describing oversight flow) → BG"

Category: Board Governance

Specificity:
- "IT Committee" — named non-generic committee → firm-specific (Level 3)
- "Senior Vice President of Information Technology" — VP-level cybersecurity/IT role → firm-specific (Level 3)
- "Executive Vice President and Chief Accounting Officer" — CAO is not a cybersecurity-specific title, but EVP... hmm, not cybersecurity-specific
- "Co-Chief Operating Officer" — not cybersecurity-specific
- "minimum frequency of once per year" — this is a specific cadence but is it QV? It's a soft claim, not really externally verifiable.

No QV-eligible facts. The SVP of Information Technology is VP-level IT title → firm-specific. IT Committee is a named non-generic committee → firm-specific.

Level 3.


fact: regular scanning of both internal and externally facing systems

fact: annual third-party penetration testing

fact: security technologies intended to identify and assist in containing and remediating malware risks

fact: active monitoring of logs and events for network perimeter and internal systems

reasoning: The paragraph lists specific cybersecurity program activities (scanning, penetration testing, malware containment, log monitoring, vendor due diligence), directly answering 'what does the program do?' → RMP. Third-party vendor due diligence is one component among several internal activities, not the central topic. Domain terminology (penetration testing, malware, scanning, log/event monitoring) elevates to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me classify this paragraph.

Content: Lists cybersecurity program activities - scanning, penetration testing, malware technologies, log monitoring, vendor due diligence.

Category: "What does the cybersecurity program do?" → RMP. Third-party vendor due diligence is mentioned but as one item among several internal program activities → RMP per Rule 3.

Specificity: Domain terms present: "penetration testing," "malware," "scanning" (vulnerability scanning). These pass the ERM test. The "third-party penetration testing" is a practice done FOR the company → RMP context. No named roles, no QV facts.

This is a Level 2 classification.


fact: June of 2023 — specific date of cybersecurity event

fact: two employees' email accounts accessed

fact: early September 2023 — notification date

fact: approximately $25,000 in expenses related to the incident

reasoning: Though the paragraph opens with program elements (third-party oversight, incident response), the dominant content describes an actual cybersecurity event — unauthorized access, timeline, remediation, and cost — making Incident Disclosure the primary category. Multiple QV-eligible facts (specific dates, headcount of affected employees, and a dollar amount) drive specificity to Level 4.

thinking:
Let me analyze this paragraph carefully.

This paragraph covers multiple topics: third-party relationship management, incident response program, and then an actual incident disclosure with specific details.

The primary question: This paragraph transitions from program description into describing an actual cybersecurity incident with specific details (June 2023, unauthorized access to email accounts, two employees, September 2023 notification, $25,000 in expenses). The incident disclosure with its specifics dominates the latter and larger portion of the text.

Category: The paragraph starts with program elements (third-party oversight, incident response) but the bulk and most substantive content is about what actually happened — an incident.

The incident frame clearly dominates here, so this falls under incident disclosure. I'm seeing multiple quantifiable facts scattered throughout: specific dates in June and September of 2023, the exact number of employees affected, and a precise dollar amount for expenses, which all point to a Level 4 specificity rating.


fact: Information Security Steering Committee ("ISSC") — named non-generic management-level committee

fact: Executives from Legal, Accounting, Internal Audit and Risk Management, Cybersecurity and Facilities departments — specific team composition by department

reasoning: The paragraph answers 'how is management organized?' by describing a management-level committee (ISSC), its departmental membership, and its oversight responsibilities — this is committee structure/membership, making it MR over RMP. The named committee (ISSC) and specific departmental composition (Legal, Accounting, Internal Audit and Risk Management, Cybersecurity, Facilities) are firm-specific facts that elevate to Level 3, but no externally verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: Describes a management-level committee (ISSC) with its composition and responsibilities.

Category: This is about how management is organized - the ISSC is a management-level committee. It describes membership (executives from specific departments) and responsibilities. This is MR.

Person-removal test: Remove committee membership/composition → what remains is generic risk oversight language. The paragraph is primarily about the committee's structure and membership → MR.

Specificity:
- "Information Security Steering Committee ("ISSC")" → named non-generic committee → firm-specific (Level 3)
- "Legal, Accounting, Internal Audit and Risk Management, Cybersecurity and Facilities departments" → specific team composition by department → firm-specific (Level 3)

- The remaining topics like data protection, privacy, and business continuity are standard business concepts, and there are no quantifiable facts, dates, or external certifications mentioned → Level 3.


reasoning: This is a cross-reference pointing to Item 1A Risk Factors with no substantive cybersecurity disclosure of its own. The 'material adverse effect' language is generic speculation embedded in a cross-reference, not a materiality assessment. N/O always receives Specificity 1.


reasoning: The paragraph describes cybersecurity insurance coverage, which answers how cybersecurity affects the business/finances — a Strategy Integration topic. While it lists various coverage areas (liability, privacy, incident response, business interruption, etc.), these are standard insurance policy components described in general business language. None of the coverage terms pass the ERM test as cybersecurity domain terminology — they are standard insurance categories. No firm-specific details (no named insurer, no dollar amounts, no specific policy details) elevate specificity beyond Level 1.

thinking: Cybersecurity insurance coverage paragraph.


reasoning: The paragraph is organized around the CEO's responsibilities for cybersecurity oversight, reporting structure to the Board, and the CEO's incident response role — management's organizational role is the primary content, though it touches BG (board reporting) and SI (final materiality sentence). The person-removal test leaves only generic risk language ('assessment and management of risks,' 'incident response plan,' 'prevention, mitigation, detection, and remediation'), not substantive program content — supporting MR. No domain terminology passes the ERM test (incident response plan, prevention/mitigation/detection/remediation are all generic), CEO is not a cybersecurity-specific title, and 'Board' and 'Audit Committee' equivalents are not firm-specific, yielding Level 1.

thinking:
Let me analyze this paragraph.

Content category: This touches multiple areas - CEO's role, board reporting, incident response, and a materiality statement. The primary question: it starts with CEO oversight, then board updates, then incident response plan, then materiality statement.

Let me think about what dominates. The paragraph describes:
1. CEO's responsibility for overseeing cybersecurity (MR)
2. Executive management updating the Board (BG)
3. Board receiving periodic reports (BG)
4. CEO's incident response plan (RMP)
5. Materiality statement (SI)

The governance chain here - CEO oversees, management updates board, board receives reports.

The CEO is the central figure throughout - his oversight responsibilities, his role in communicating with the board, his incident response plan. But when I apply the person-removal test, stripping away the CEO and executive management team, there's still meaningful content left: the underlying processes for risk assessment, prevention, mitigation, detection, and remediation, plus the board's periodic reporting structure and incident response protocols. So while the CEO is the focal point, the paragraph is really describing the organizational framework and processes for managing cybersecurity, not just individual roles.

Looking at how the content breaks down, the CEO's oversight role takes up about two sentences, board reporting another two, the incident response plan another two, and materiality gets one. The governance chain from CEO to Board is clearly the organizing principle here. Rule 1 suggests governance-chain paragraphs should default to BG when they're describing oversight structure, but the CEO is so prominently the subject and his responsibilities are what's being emphasized. The board reporting is almost secondary - it happens "as necessary" or through "periodic reports." The CEO's role is what dominates the paragraph, which pushes this toward MR.

Testing whether the paragraph would still make sense without the CEO and executive management team - it would still have content about risk management and incident response, but that remaining material is pretty generic and loses its anchor. The paragraph is fundamentally organized around who does what, with the CEO as the central organizing principle. I'm going to classify this as MR since the CEO's organizational role and responsibilities are what structure the entire discussion.

Now looking at specificity: the CEO, IT personnel, incident response plan, and Board are all generic references without firm-specific details. The risk language around prevention, mitigation, detection, and remediation is standard boilerplate. There's no domain terminology that would satisfy the ERM test, no firm-specific facts, and no quantitative or valuation information. This is clearly Level 1 - Generic Boilerplate.

Though I notice the final sentence does contain a backward-looking materiality assessment about not encountering cybersecurity challenges that materially impaired operations - that would normally push toward SI. But it's just one sentence at the end, while the bulk of the paragraph focuses on management roles and responsibilities. The MR content dominates, so that's my classification.


fact: 25 years of prior experience

fact: Certified Internal Controls Auditor (CICA)

fact: Payment Card Industry Professional (PCIP)

fact: Certified Information Systems Security Professional (CISSP)

fact: Certified Information Systems Auditor (CISA)

fact: Certified in Risk and Information Systems Control (CRISC)

fact: master's and bachelor's degrees in Computer Information Systems and Business Administration

reasoning: The paragraph is entirely about the CISO's responsibilities, qualifications, and credentials — person-removal leaves only generic program area names, confirming MR. Multiple independently verifiable facts drive Level 4: '25 years of experience' is a specific number, and five named certifications (CISSP, CISA, CRISC, CICA, PCIP) are each verifiable via their respective issuing bodies.

thinking:
This paragraph describes the CISO's responsibilities, experience, and qualifications.

Category: Management Role - primarily about who holds the role, their qualifications, credentials, career history. Person-removal test: remove CISO, 25 years, degrees, certifications → very little remains beyond generic program areas.

Specificity: Multiple QV-eligible facts - "25 years of prior experience", CISSP, CISA, CRISC, CICA, PCIP certifications (all verifiable). Level 4.


fact: threat modeling

fact: vulnerability testing

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing assessment activities, testing, and third-party engagements to evaluate the company's own security — third parties serving the company's program → RMP per Rule 3. The final sentence about Board reporting is subordinate. Domain terms like threat modeling, vulnerability testing, and information security maturity assessments pass the ERM test, but no firm-specific or verifiable facts are present, yielding Level 2.

thinking:
Let me classify this paragraph.

Content Category: This describes what the cybersecurity program does - assessments, testing, exercises, third-party assessments. The last sentence mentions reporting to the Board, but the bulk is about program activities. Person-removal test: no persons to remove, it's all about activities. The third-party mentions are about firms hired to assess the company's OWN security → RMP per Rule 3. Primary question answered: "What does the cybersecurity program do?" → RMP.

Specificity: Let me scan for facts.
- "threat modeling" — cybersecurity domain term ✓
- "vulnerability testing" — cybersecurity domain term ✓

- "information security maturity assessments" — domain-specific concept
- "information security control environment" — somewhat domain-specific
- "tabletop exercises" — generic term, not domain terminology per codebook

Domain terms present: threat modeling, vulnerability testing. These pass the ERM test. No firm-specific facts or QV facts present.

→ Level 2


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing controls, assessments, and engaging third-party specialists to review the company's own security (Rule 3: third parties serving the company → RMP, not TP). All language is generic ERM-level vocabulary ('assess, identify, and manage material cybersecurity risks,' 'formal reviews and assessments,' 'independent third-party specialists') with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me classify this paragraph.

Content: Describes cybersecurity risk management processes - controls, technologies, assessments, and engaging third-party specialists to review their environment.

Category: "What does the cybersecurity program do?" → RMP. The third-party mention is about firms hired to assess the company's own security (Rule 3: third parties hired to serve the company → RMP).

Specificity: Let me scan for facts.
- "independent third-party specialists" - unnamed, not firm-specific
- "controls, technologies, and other processes to assess, identify, and manage material cybersecurity risks" - generic ERM language

- "formal reviews and assessments" - generic
- "actionable recommendations for improvement" - generic

No domain terminology that passes the ERM test. No firm-specific facts. No QV facts. This is Level 1 - Generic Boilerplate. The language is all general business and risk management terminology without any specificity.


fact: Mr. Dennis named as individual in cybersecurity role

fact: founder of a data privacy consulting company

fact: attack vectors and vulnerabilities

fact: over 20 years of experience in data management

fact: Director of Information Technology since June 2019

reasoning: The paragraph is organized around Mr. Dennis — his tenure, qualifications, what processes inform him, and how he reports upward — answering 'how is management organized to handle cybersecurity?' The person-removal test leaves substantive process content, making this a close MR/RMP call, but the framing centers on Mr. Dennis's role, credentials, and reporting chain. Specificity reaches Level 4 via 'over 20 years of experience' (verifiable lower bound) and 'since June 2019' (specific date tied to a cybersecurity-relevant role).

thinking:
Let me analyze this paragraph.

Content: Describes Mr. Dennis as Director of IT, his background (founder of data privacy consulting company, 20+ years experience), then describes processes for monitoring cybersecurity incidents, and reporting to management/Audit Committee.

Category: This is a mix. It starts with MR (Mr. Dennis's role, qualifications), then describes processes (RMP-like), then reporting structure (BG-like). Let me apply the person-removal test: Remove Mr. Dennis, his title, qualifications, team. What remains? "We have implemented a number of processes which allow [removed] to be informed about and monitor the prevention, detection, mitigation, and remediation of cybersecurity incidents.

These processes include, among other things, system alerts of potential malicious cyber activity, access to real-time dashboards that monitor and assess our systems, status reports provided on a daily, weekly and monthly basis, and regular ongoing communications with service providers regarding potential new attack vectors and vulnerabilities." — That's still a substantive description of processes. But wait, there's also significant MR content (qualifications, experience, role).

Actually, the paragraph is roughly split. The first two sentences are about Mr. Dennis (MR). The middle describes processes. The last sentence describes reporting. The primary question... it's a blend of MR and RMP. The person-removal test: substantial process content remains → RMP. But actually the paragraph seems to primarily answer "who oversees cybersecurity" with both his qualifications and the mechanisms in place, so it's genuinely hybrid.

Re-reading more carefully, the processes are framed around how Mr. Dennis and his team stay informed — the system alerts, dashboards, and reports all feed into his oversight role. This is fundamentally about how management is structured to handle cybersecurity threats. The specific process details are substantive, but they're presented as tools that support his function. I think the codebook would classify this as MR because the paragraph's organizing principle is Mr. Dennis's role and responsibilities, with processes described as the means by which he executes that role. I'm applying the person-removal test to check what remains when I strip out all the biographical details about Mr. Dennis. The core description of their monitoring processes—system alerts, real-time dashboards, daily/weekly/monthly reports, and vendor communications—is clearly substantive and stands on its own. That's solid RMP content. But the paragraph genuinely splits between his background and qualifications on one side and the program description on the other, roughly equal in length. Since the process description takes up more text overall, this should be categorized as RMP.

Though I'm second-guessing myself a bit—the paragraph's real purpose seems to be establishing how management is organized and how Mr. Dennis fits into the reporting structure, which leans more toward MR. The processes are really just the mechanisms through which he operates. I'll go with MR, though I'm not entirely confident.

Looking at the specificity markers: "Director of Information Technology" without a security qualifier isn't firm-specific enough, but "Mr. Dennis" as a named individual in this context is, along with founding a data privacy consulting company. The "over 20 years" is a quantifiable lower bound, and "June 2019" gives me a specific tenure date to work with.

So I'm landing on Level 4 based on those quantifiable facts. The domain terminology around attack vectors and vulnerabilities checks out under the ERM test, though "real-time dashboards" and "malicious cyber activity" are more borderline. "Audit Committee" isn't firm-specific on its own.


reasoning: The paragraph states a materiality conclusion ('have not materially affected or are reasonably likely to materially affect') making it SI under the materiality assessment rule. The remainder is a cross-reference to Item 1A and generic speculation ('could be negatively impacted', 'no assurance'). No domain terminology, firm-specific facts, or verifiable claims are present.


fact: Executives from Legal, Accounting, Internal Audit and Risk Management, Cybersecurity and Facilities departments

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by describing the ISSC's composition and oversight responsibilities — a management-level committee with named departmental membership. The ISSC is a named non-generic committee and the specific departmental composition (Legal, Accounting, Internal Audit and Risk Management, Cybersecurity, Facilities) distinguishes this company's structure, elevating to Level 3.

thinking:
Let me analyze this paragraph.

Content: Describes a management-level committee (ISSC) with its composition and responsibilities.

Category: This is about how management is organized - the ISSC is a management-level committee. It describes membership (executives from specific departments) and responsibilities. This is MR.

Person-removal test: Remove committee membership/composition → what remains is generic oversight responsibility language. The substance is about the committee structure and who's on it → MR.

Specificity:
- "Information Security Steering Committee ("ISSC")" → named non-generic committee → firm-specific (Level 3)

- The specific departments represented—Legal, Accounting, Internal Audit and Risk Management, Cybersecurity and Facilities—are concrete organizational details that make this firm-specific (Level 3). The terminology around information security and business continuity is standard industry language rather than company-adapted jargon, so that doesn't push it higher.


fact: March 31, 2023 — specific date by which all significant systems had been restored

fact: DISH TV — named service that remained operational during incident

fact: SLING TV — named service that remained operational during incident

fact: Retail Wireless — named service that remained operational during incident

reasoning: The paragraph describes the aftermath and remediation of an actual cybersecurity incident — which services remained operational, when systems were restored, and that the incident is considered concluded — directly answering 'what happened?' The specific date 'March 31, 2023' for system restoration is a verifiable fact, pushing specificity to Level 4.

thinking:
Analyzing this paragraph from EchoStar's 10-K filing about a cybersecurity incident.

This describes what happened during and after an actual cybersecurity incident - services remained operational, systems restored by a specific date, incident concluded.

Category: Incident Disclosure - describes actual events (restoration, operational status during incident)

Specific facts:
- "DISH TV" - named service/brand
- "SLING TV" - named service/brand
- "Retail Wireless" - named service

- "March 31, 2023" - specific restoration date
- "all significant systems had been restored" - remediation status

The specificity level is 4 due to the precise date provided for when systems came back online.


fact: CSO (Chief Security Officer)

reasoning: Person-removal test: removing the CSO and executive leadership team references leaves a description of a cybersecurity program designed to protect systems, respond to incidents, and deploy multidisciplinary teams — a substantive program description remains, so RMP. The language is entirely generic ERM ('protect information systems,' 'incident response and recovery plans,' 'multidisciplinary teams') with no domain terminology passing the ERM test, but the CSO title is a firm-specific cybersecurity leadership role elevating to Level 3.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes what the cybersecurity program does - protecting systems, responding to incidents, deploying teams. The CSO is mentioned as attribution. Person-removal test: remove "The CSO, in coordination with other members of TTEC executive leadership team" → "works collaboratively across the Company to implement a cybersecurity program designed to protect the Company's information systems from cybersecurity threats and to promptly respond to any cybersecurity incidents in accordance with the Company's incident response and recovery plans. To facilitate the success of the Company's cybersecurity risk management program, multidisciplinary teams throughout the Company are deployed to address cybersecurity threats and respond to cybersecurity incidents." - Still describes a program. → RMP.

The CSO role itself is firm-specific as a VP-level cybersecurity leadership position, but the rest of the language is generic—multidisciplinary teams, incident response plans, and the cybersecurity program framework all fall into standard ERM terminology without domain-specific details or quantifiable facts. This lands it at Level 3 based solely on the CSO attribution.


reasoning: The paragraph acknowledges regulatory oversight and cross-references another section but does not describe any actual cybersecurity measures, processes, or assessments. It is a cross-reference paragraph pointing elsewhere ('see... included in Part I'), making it N/O. No domain terminology, firm-specific facts, or verifiable claims are present.


fact: vulnerability scans

fact: penetration tests

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing a risk-based approach, tools/methodologies, and monitoring activities — fitting RMP. The opening sentence about risks is framing, not a materiality assessment. Vulnerability scans and penetration tests are cybersecurity domain terms that pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity risks in biotech sector, mentions risk-based approach, tools/methodologies, vulnerability scans and penetration tests.

Category: "What does the cybersecurity program do?" → RMP. It describes their approach to managing cybersecurity risk, tools, vulnerability scans, pen tests.

Specificity:
- "vulnerability scans" → domain term
- "penetration tests" → domain term
- No firm-specific facts, no QV facts.

- This falls under RMP because it's about their risk management processes and methodologies, not specific incidents or outcomes.


fact: NSA Cybersecurity Collaboration Center

fact: CISA Critical Partnership

fact: FBI InfraGard

fact: U.S. Coast Guard Area Maritime Security Committees and Cybersecurity Subcommittees

fact: Cyber-Hawaii

fact: Maritime Transportation System Information Sharing and Analysis Center (MTS-ISAC)

reasoning: This is a list of external cybersecurity partnerships and information-sharing memberships, describing components of the company's cybersecurity program (what it does to manage risk through collaboration) → RMP. Multiple named external government agencies and industry organizations (NSA, CISA, FBI InfraGard, MTS-ISAC) are independently verifiable entities whose partnership programs can be confirmed, driving Level 4.

thinking:
This is a list of external partnerships/memberships related to cybersecurity. Let me classify it.

Content: It's a list of government and industry cybersecurity partnerships/memberships. This describes components of the company's cybersecurity program - specifically external collaborations and information sharing. This answers "What does the cybersecurity program do?" → RMP.

Specificity: Contains named external entities - NSA's Cybersecurity Collaboration Center, CISA, FBI InfraGard, U.S. Coast Guard committees, Cyber-Hawaii, MTS-ISAC. These are named external entities that are verifiable.

MTS-ISAC qualifies as a named external entity, making these memberships eligible for QV classification.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' describing Board and Audit Committee oversight and briefing cadence, clearly BG. All elements — Board of Directors, Audit Committee, 'at least once each year,' enterprise risk — are generic governance structures present at every public company with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: "How does the board oversee cybersecurity?" → Board Governance. Board and Audit Committee oversight, briefing frequency.

Specificity: Let me scan for facts.
- "Board of Directors" - not firm-specific (every company has one)
- "Audit Committee" - not firm-specific (every company has one)
- "at least once each year" - generic cadence
- "enterprise risk" - general business language
- No domain terminology, no firm-specific facts, no QV facts.

Level 1.


reasoning: The paragraph describes how a committee presents cybersecurity oversight results to the Board of Directors at regular meetings and between meetings for significant threats — answering 'how does the board oversee cybersecurity?' No domain terminology, firm-specific facts, or verifiable claims are present; 'Committee,' 'Board of Directors,' and 'regularly scheduled meetings' are all generic governance language found at any public company.

thinking:
Let me analyze this paragraph.

The paragraph describes how a Committee presents results to the Board of Directors, how the Board oversees risk management, and how cybersecurity topics are presented at meetings. It also describes notification procedures between meetings.

Category: This answers "How does the board oversee cybersecurity?" - information flows to the board, briefing frequency, oversight structure. → Board Governance

Specificity: Let me scan for facts.
- "Committee" - generic, not named specifically here
- "Board of Directors" - not firm-specific

- "regularly scheduled meetings" - generic cadence
- "material cybersecurity threats or incidents" - "material" as adjective, not an assessment
- No domain terminology, no firm-specific facts, no QV facts

This is generic oversight language. Level 1.


reasoning: The paragraph states two materiality conclusions: (1) risks are not reasonably likely to materially affect the business (forward-looking assessment using SEC Item 106(b)(2) language), and (2) no material incidents occurred during the reporting period (backward-looking negative assertion). Both are SI per the materiality assessment rule. Specificity is Level 1 because the language is pure boilerplate with no domain terminology, firm-specific facts, or verifiable claims — the negative assertions about absence of incidents are not externally verifiable.

thinking: Materiality assessment paragraph.


fact: CISO (Chief Information Security Officer)

fact: CRO (Chief Risk Officer)

fact: over 18 years of experience in information technology leadership

fact: eight years of experience in leading information security oversight

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — it describes the CISO's responsibilities, reporting line to the CRO, the CRO's oversight scope, the CISO's qualifications, and team credentials. Person-removal test confirms MR: removing roles, reporting lines, and qualifications leaves only generic monitoring language. Specificity reaches Level 4 via quantified years of experience ('over 18 years' and 'eight years'), which are verifiable lower-bound claims.

thinking:
Let me analyze this paragraph.

Content Category: This is primarily about management's organizational role. It describes the CISO's responsibilities, reporting line to CRO, the CRO's oversight scope, the CISO's qualifications/experience, and team qualifications. Person-removal test: remove all person-specific content and very little substantive program description remains beyond generic monitoring language.

→ Management Role

Specificity: Let me scan for facts:
- "CISO" — firm-specific (named cybersecurity role)
- "CRO" (Chief Risk Officer) — this is a risk management role, not cybersecurity-specific per se, but it's a named role in context

- The experience requirements are quantified with concrete numbers: over 18 years in IT leadership and eight years specifically in information security oversight, both verifiable metrics. The mention of "various" certifications is vague and doesn't meet the specificity threshold, but those two experience figures are clearly Level 4.


fact: February 2023 ransomware attack

fact: ransomware

reasoning: The paragraph describes the consequences and remediation of an actual cybersecurity incident — the unauthorized release of personal information and subsequent response actions (scanning files, notifying individuals, providing credit monitoring). While expenditures are mentioned, they are framed as remediation activities rather than a financial impact analysis, keeping the incident frame dominant (Rule 4). 'February 2023' is a specific date tied to a real event, elevating to Level 4.

thinking:
Classify this paragraph.

This describes what happened in a cybersecurity incident - the February 2023 ransomware attack, its consequences (unauthorized release of personal info), and remediation actions taken.

But wait - it's about the financial/business impact (remediation expenditures). Let me check Rule 4: ID vs SI. "What happened (timeline, scope, response) → ID. Business/financial impact → SI. Mixed with incident frame dominant → ID. Mixed with financial frame dominant → SI."

This paragraph describes the consequences of an incident and the expenditures required. The frame is about costs/expenditures resulting from the incident.

Actually, looking closer, it's describing both what happened and what they spent money on, but the costs are tied to specific remediation activities like file scanning and credit monitoring rather than being analyzed as financial metrics. The incident response framing seems to dominate here, so I'd classify this as ID. The specificity markers are there too - the exact date in February 2023 and the concrete remediation actions like scanning and employee notification.


reasoning: The paragraph describes the company's incident response plan and what it covers (roles, responsibilities, recovery steps), answering 'what does the cybersecurity program do?' → RMP. All language is generic business terminology — 'incident response plan,' 'roles, responsibilities,' 'breaches,' 'contain' — none of which pass the ERM test as cybersecurity domain terms. No firm-specific or verifiable facts present.

thinking:
Classify this paragraph.

Content: Describes an incident response plan with roles, responsibilities, and recovery steps. This answers "What does the cybersecurity program do?" → RMP.

Specificity: Let me check for domain terms, firm-specific facts, and QV facts.
- "incident response plan" — explicitly listed as NOT domain terminology (Level 1)
- "breaches or cybersecurity incidents" — general
- "defining roles, responsibilities, and steps to recover" — general business language

No domain terms, no firm-specific facts, no QV facts. Level 1.


fact: vulnerability assessments

reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — it describes Audit Committee oversight, reporting on cybersecurity risks, incident escalation thresholds, and periodic discussions with IT leadership, all describing the board's oversight structure. 'Vulnerability assessments' is domain terminology (passes the ERM test), elevating to Level 2. 'Executive Director of IT' is a Director-level IT title without a security qualifier, so it does not qualify as firm-specific per the codebook.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph answers "How does the board oversee cybersecurity?" - Board/Audit Committee oversight, briefing topics, incident reporting thresholds, discussions with Executive Director of IT. This is clearly Board Governance.

Specificity: Let me scan for facts.
- "Audit Committee" - not firm-specific (every public company has one)
- "vulnerability assessments" - domain term
- "threat environment" - general
- "Executive Director of IT" - this is a title. Is it firm-specific? It's not a VP-level or above cybersecurity title.

"Executive Director of IT" isn't a security-qualified title, so it doesn't meet the firm-specific criteria. "Information security considerations" and "reporting thresholds" are both general terms. But "vulnerability assessments" as domain terminology pushes this to Level 2. Reconsidering "Executive Director of IT" against the codebook rules—it's not VP-level or above, and without a security qualifier like "Director of Security," it doesn't qualify as firm-specific.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — it describes requirements imposed on vendors, a vendor management policy, and risk-tiered security controls for external parties, making it clearly TP. Specificity remains Level 1 because the language is entirely general ERM vocabulary (risk assessments, ongoing monitoring, contractual controls, information access restrictions); 'Vendor Management Policy' is a generic program name without a distinguishing identifier, and no cybersecurity domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Third-party risk management is the central topic here.

Facts: "Vendor Management Policy" - named internal program with distinguishing identifier → firm-specific. "enhanced risk assessments, ongoing monitoring, or additional contractual controls" - generic process language. "restrict their levels of information access" - generic.

Actually, "Vendor Management Policy" - is this a distinguishing identifier? It's a pretty generic name. Let me reconsider. The codebook says named internal programs WITH distinguishing identifiers qualify. "Vendor Management Policy" is fairly generic - many companies have one.

Comparing this to something like "Cyber Incident Response Plan (CIRP)" which has a clear acronym, "Vendor Management Policy" feels borderline as a firm-specific identifier. The language throughout is pretty standard ERM terminology - "risk assessments," "ongoing monitoring," "contractual controls," "IT security infrastructure" - nothing that really signals specialized cybersecurity domain knowledge.

Looking at the codebook's standard, a named internal policy needs to be genuinely distinguishing. Since many companies have a generic "Vendor Management Policy," this doesn't quite meet that bar. The central topic is third-party risk oversight, but the execution is boilerplate business language, so I'm settling on Level 1.


reasoning: The paragraph states a backward-looking materiality conclusion — 'risks from cybersecurity threats have not materially affected our Company' — which is an SI assessment per the codebook rule. The cross-reference to Item 1A is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present; the negative assertion about no material impact is a self-reported claim about absence and is not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: Discusses threat severity, defensive measures, past incidents without material effect, and cross-references Item 1A.

Category: The key sentence is "risks from cybersecurity threats have not materially affected our Company" — this is a backward-looking materiality assessment → SI. The cross-reference is subordinate.

Specificity: Let me scan for facts:
- "have not materially affected" — negative self-assertion, not externally verifiable
- No domain terminology beyond general language
- No firm-specific facts
- No QV facts

- The reference to Item 1A is just a pointer to other content, not substantive here.

This reads as generic boilerplate with no concrete details. Level 1.


reasoning: This is a governance-chain paragraph (IT employee → CEO → Board) describing how cybersecurity information flows upward to the board, defaulting to BG per Rule 1. No domain terminology (prevention/detection/mitigation/remediation are generic risk management language), no firm-specific facts (CEO and Board exist at every company; 'information technology employee' is not a cybersecurity-specific title at VP+ level), and no verifiable claims, yielding Level 1.

thinking:
Let me analyze this paragraph.

Content: An IT employee monitors systems and cybersecurity incidents, consults with CEO, who reports to the Board.

Category: This describes an oversight/reporting chain from IT employee → CEO → Board. The purpose is describing how information flows upward to the board. This is a governance-chain paragraph. The primary question answered is "How does the board oversee cybersecurity?" — through the CEO reporting risks. But it's also about management organization. The paragraph describes both the IT employee's monitoring role and the reporting chain to the board.

Actually, let me re-read. The paragraph has two sentences:

1. IT employee monitors systems and cybersecurity incidents in consultation with CEO
2. CEO reports risks to the Board

This is a governance-chain paragraph (IT employee → CEO → Board). Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. The purpose here is describing how cybersecurity information flows up to the board.

Category: **Board Governance**

Specificity: Let me scan for facts. The titles mentioned—information technology employee, Chief Executive Officer, Board—are all generic roles that don't reveal anything firm-specific. The only substantive detail is that the IT employee monitors prevention, detection, mitigation and remediation activities, but that's standard cybersecurity practice, not unique to this company.

No domain terms, no firm-specific facts, no QV facts. Level 1.


fact: National Institute of Standards and Technology (NIST)

type: framework

fact: Center for Internet Security Controls (CIS Controls)

reasoning: The paragraph describes the cybersecurity program's foundation on industry frameworks (NIST, CIS Controls), answering 'what does the program do?' → RMP. Named standards are domain terminology elevating to Level 2, but 'based on' / 'aligned with' is not a verifiable certification claim, and no firm-specific or QV facts are present.

thinking:
Let me classify this paragraph.

Content: Describes the cybersecurity program's basis on frameworks (NIST, CIS Controls). This answers "What does the cybersecurity program do?" → RMP.

Specificity: NIST (domain term/framework), CIS Controls (domain term/framework). These are named standards → Domain-Adapted (Level 2). No firm-specific facts or QV facts.


fact: Risk Committee (named non-generic committee that presents the enterprise risk management matrix to the Audit Committee)

reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — the Audit Committee's briefing cadence, its review of the risk management matrix, and the topics covered in that review all describe board-level oversight structure → Board Governance. The 'Risk Committee' is a named non-generic committee (not every public company has one, unlike the Audit Committee), elevating to Level 3. The listed review topics (risk assessment, risk management, service provider arrangements, test results, security incidents) are general ERM language that fails the domain-specificity test, so no Level 2 domain terms are present beyond the firm-specific committee fact.

thinking:
Let me analyze this paragraph.

Content Category: The paragraph describes the Audit Committee's oversight of cybersecurity risks - briefing frequency, what they review, etc. This answers "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts.
- "Audit Committee" - every public company has one, NOT firm-specific
- "at least once each calendar year" - generic cadence
- "Risk Committee" - this is a named committee... but wait, is this a board-level or management-level committee? It says "presented by the Risk Committee" - this could be a named non-generic committee. Actually, "Risk Committee" is somewhat common but not as universal as "Audit Committee." Let me think...

The codebook distinguishes between universal committees like Audit Committee and named non-generic ones like Cybersecurity Committee or Technology Risk Committee. "Risk Committee" falls somewhere in between—it's not as standard as Audit Committee, but it's also not as specialized as firm-specific committees, so I need to determine whether this counts as firm-specific or generic for the purposes of classification.

Looking at the terminology in the topics list—risk assessment, risk management, control decisions, service provider arrangements, test results, security incidents, and policy updates—these are all standard enterprise risk management language rather than domain-specific terminology. Even "security incidents" here is being used in a general ERM context rather than as specialized cybersecurity jargon.

The key distinguishing factor is the "Risk Committee" itself, which is a named committee that not all companies have, making it firm-specific. That pushes this to Level 3.


fact: BNY Mellon named as the entity managing third-party service provider risk

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' by describing BNY Mellon's framework for evaluating and mitigating risks from its third-party service providers, including risk-based protocols and contractual obligations — this is vendor oversight as the central topic → TP. The language itself is generic (no domain terminology — 'governance framework,' 'mitigate risks,' 'contractual obligations' all pass the ERM test as general risk management language), but BNY Mellon is a named external entity whose role as trustee is independently verifiable, elevating to Level 4.

thinking:
Let me analyze this paragraph from Chesapeake Granite Wash Trust's 10-K filing.

This is about BNY Mellon (the trustee) describing their third-party governance framework for managing vendor/service provider cybersecurity risks. The central topic is how third-party cyber risks are managed.

Content Category: Third-Party Risk - the paragraph answers "How are third-party cyber risks managed?" It describes vendor oversight, risk evaluation, contractual requirements, and controls for service providers.

Wait - but this is describing BNY Mellon's own third-party risk management.

So BNY Mellon, as the trustee for Chesapeake Granite Wash Trust, is outlining how it manages cybersecurity risks from its own vendors and service providers. The paragraph details the trustee's vendor oversight program, including risk assessment, contractual safeguards, and monitoring controls. Looking at the specifics, I can see BNY Mellon is named as the external entity managing these third-party relationships. BNY Mellon as the trustee is a named external entity whose role is verifiable, so I'd classify this as Level 4. The rest of the language is generic risk management terminology without specialized domain vocabulary. So I'm settling on classifying this as a TP with Level 4 verification—BNY Mellon is a named entity whose role as trustee is independently verifiable through public records.


fact: penetration testing

fact: vulnerability assessment

fact: managed security service monitoring

fact: Management Enterprise Risk Committee

fact: Vendor Management Committee

reasoning: While the first sentence mentions third parties hired to serve the company's own security (RMP per Rule 3), the bulk of the paragraph describes vendor oversight processes — due diligence reviews, contractual cybersecurity requirements, ongoing oversight procedures, and risk-based assessment of vendors — making TP the dominant frame. Two named non-generic committees (Management Enterprise Risk Committee, Vendor Management Committee) elevate specificity to Level 3.

thinking:
Let me analyze this paragraph.

Content: The paragraph discusses third-party vendors in two ways: (1) vendors hired to assist the company's own security (monitoring, pen testing, vulnerability assessment) and (2) vendor risk management processes (due diligence, contractual requirements, oversight).

Category: The central topic is how third-party cyber risks are managed. While the first sentence mentions vendors serving the company (which would be RMP per Rule 3), the bulk of the paragraph is about requirements imposed on and oversight of third-party vendors - due diligence, contractual requirements, ongoing oversight. This is TP.

Specificity:
- Domain terms: "penetration testing", "vulnerability assessment", "managed security service monitoring" → Level 2

- Firm-specific: The paragraph references named committees like "Management Enterprise Risk Committee" and "Vendor Management Committee" → Level 3
- QV-eligible: None

This pushes the overall specificity to Level 3.