fact: cybersecurity awareness training

fact: data leakage and unauthorized access

reasoning: The paragraph lists key elements of the cybersecurity risk management program — risk assessments, security controls, training, incident response, third-party oversight, and AI security reviews — directly answering 'what does the program do?' → RMP. Specificity reaches Level 2 via domain terms like 'cybersecurity awareness training' and 'data leakage and unauthorized access,' but nothing is firm-specific (no named roles, committees, or unique identifiers) and nothing is externally verifiable.

thinking:
Let me analyze this paragraph.

Content: This is a list of key elements of the cybersecurity risk management program - risk assessments, security team, external service providers, training, incident response plan, third-party risk management, AI controls review.

Category: "What does the cybersecurity program do?" → RMP. It's describing program elements/activities.

Specificity: Let me scan for facts.

- "risk assessments" → general ERM language → L1
- "security team" → generic → L1
- "external service providers" → unnamed → L1
- "cybersecurity awareness training" → this is a domain term? Let me check...

"security awareness training" is listed as domain terminology → L2. Now checking the rest: "incident response plan" isn't domain-specific terminology, so that's L1. "third-party risk management process" is general ERM language → L1. "data leakage" is borderline—it's a cybersecurity concept that a general ERM professional might not use in the same way, so I'm leaning toward L2. "unauthorized access" is common incident language but could be used more broadly, so that feels like L1.

Looking at the rest: "controls framework" is general, and "artificial intelligence" terms aren't cybersecurity-specific. No firm-specific facts here—just a generic "security team" with no named roles or committees. This lands at Level 2.


content_category: Board Governance

fact: patching and vulnerability management

fact: security awareness training

category_confidence: high

specificity_confidence: high

reasoning: The paragraph answers 'How does the board oversee cybersecurity?' by describing briefing frequency and scope of topics presented to the full Board, making it Board Governance. Domain terms like 'patching and vulnerability management' and 'security awareness training' pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present (cadences are generic, Board of Directors is universal, and topics are listed hypothetically with 'may cover').

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Category: This describes how information flows to the board - briefing frequency and topics. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts.

- "At least annually" and "semiannual" - generic cadences, not specific dates
- "full Board of Directors" - generic governance
- Topics listed: "patching and vulnerability management" - domain term, "security awareness training" - domain term, "cybersecurity tabletop exercise" - this has a cybersecurity qualifier so it's domain, "information security organization" - borderline, "technical threats" - general, "information technology security infrastructure" - general, "supplier management" - general

- The domain-specific terms like patching and vulnerability management, security awareness training, and cybersecurity tabletop exercises would be unfamiliar to a general ERM professional, so they pass the test. But there are no firm-specific facts, named roles beyond generic titles, or quantifiable metrics here. This lands at Level 2.


reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — the audit committee's oversight role, its quarterly meetings with management, and the annual review structure are all describing the information flow to the board. The VP of Information Technology is a VP-level title whose portfolio includes IT, making it firm-specific (Level 3); 'quarterly' and 'annually' are generic cadences that don't qualify as QV.

thinking:
Let me analyze this paragraph.

Content category: This is about board oversight of cybersecurity. The audit committee oversees risks, meets quarterly with management, and receives annual reviews. This answers "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts.
- "Vice President of Information Technology" — VP-level title with IT portfolio → firm-specific
- "audit committee" — every public company has one → NOT firm-specific
- "quarterly" — generic cadence → not QV
- "annually" — generic cadence → not QV

So Level 3 (Firm-Specific) due to VP of Information Technology.


content_category: Risk Management Process

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing risk identification, policy development, employee training, and third-party engagement as part of ERM — all program activities (RMP). Third parties are mentioned as serving the company's own assessments (Rule 3 → RMP, not TP). Every term used ('enterprise risk management assessments,' 'identifying material cybersecurity risks,' 'policies and procedures,' 'cybersecurity training,' 'consultants and other third parties') is generic business/ERM language that any non-security professional could write; no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity as part of ERM, procedures for identifying risks, policies, training, and engaging third parties.

Category: "What does the cybersecurity program do?" → RMP. It describes activities and processes. Third parties are mentioned as one component serving the company's program (Rule 3 → RMP, not TP).

Specificity: Let me scan for facts.
- "enterprise risk management assessments" → general business term, L1
- "identifying material cybersecurity risks" → generic process language, L1

- "policies and procedures" → L1
- "cybersecurity training" → I'm checking whether this qualifies as domain terminology. The codebook lists "Security awareness training" as domain-specific, but "cybersecurity training" is more generic. Applying the ERM test—would a non-security professional use this phrasing? They might just say "training" across any risk domain, so this barely fails the specificity threshold.
- "consultants and other third parties" → unnamed, not firm-specific
- "risk mitigation" → generic
- "escalating issues" → generic

All of these are standard process language without domain expertise, so Level 1.


fact: CISO

fact: Chief Information Officer

reasoning: The paragraph primarily answers how the board oversees cybersecurity: Board delegates to Audit Committee, which receives updates from management, with escalation protocols. This is a classic governance-chain paragraph with BG as the purpose. Specificity is Level 3 due to named cybersecurity-specific roles (CISO, CIO), but no QV-eligible facts — cadences are generic ('quarterly or as needed') and Audit Committee is not firm-specific.

thinking:
Let me classify this paragraph.

Content Category: This paragraph answers "How does the board oversee cybersecurity?" - Board/committee oversight, briefing frequency, escalation protocols. → Board Governance

Specificity: Let me scan for facts.
- CISO → firm-specific (named cybersecurity role)
- Chief Information Officer (CIO) → firm-specific
- "quarterly or as needed updates" → generic cadence, not QV
- Audit Committee → not firm-specific (every company has one)

Firm-specific: CISO, CIO. Level 3.

No QV facts (no specific numbers, dates, named external entities, certifications).


content_category: Management Role

fact: over 20 years of experience in information security

type: quantified

fact: members of executive management and leaders of business functional areas

reasoning: The paragraph answers 'how is management organized?' by identifying the CISO and a steering committee as primarily responsible, then detailing the CISO's qualifications. Person-removal test leaves only generic 'assess and manage material risks from cybersecurity threats,' confirming MR. Specificity reaches Level 4 via 'over 20 years of experience' (verifiable lower bound) and 'CIO Executive Education Certificate from Stanford University' (named university credential, independently verifiable).

thinking:
Let me analyze this paragraph.

Category: The paragraph describes who is responsible for cybersecurity (CISO and steering committee) and then provides qualifications. The person-removal test: remove CISO, steering committee membership, 20 years experience, CIO certificate → nearly nothing remains except "assess and manage our material risks from cybersecurity threats." That's generic. So this is MR.

Specificity:
- CISO → firm-specific (named_role)
- "steering committee on information security" → named_committee (firm-specific)
- "members of our executive management as well as leaders of business functional areas" → specific team composition (firm-specific)

- The CISO also brings over 20 years of experience and holds a CIO Executive Education Certificate from Stanford University, both of which are verifiable qualifications that add concrete detail to the disclosure.

Level 4.


content_category: Strategy Integration

reasoning: The first sentence states a conclusion about materiality — no incidents have had or are reasonably likely to have a material impact on business strategy, results of operations, or financial condition — which is a backward-looking and forward-looking materiality assessment (SI per Rule 5). The cross-reference to Item 1A is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present; the negative self-assertion about absence of incidents is not externally verifiable, and the materiality language is standard boilerplate found in virtually every 10-K.

thinking:
Let me analyze this paragraph.

Content: Two sentences. First states no material cybersecurity incidents have occurred or are reasonably likely to materially impact the company. Second is a cross-reference to Item 1A.

Category: The first sentence is a materiality assessment - stating a conclusion about whether cybersecurity has affected business outcomes. This is SI per Rule 5. The cross-reference is subordinate.

Specificity: "Have not... had or are reasonably likely to have a material impact on the Company's business strategy, results of operations or financial condition" - this is boilerplate materiality language. The cross-reference adds nothing. "We are not aware of any cybersecurity incidents" is a negative self-assertion - not externally verifiable.

This disclosure lacks any domain-specific terminology, company-specific details, or quantifiable facts - it's purely generic boilerplate at the lowest specificity level.


fact: VP of IT

fact: cyber emergency response team

fact: Cybersecurity Response Committee

fact: NVP of Finance

fact: over 24 years of experience in IT and information security

fact: over 50 years of collective experience

fact: served as Chief Information Security Officer of a healthcare company

reasoning: The paragraph is entirely about the qualifications, credentials, and career history of management personnel (VP of IT, NVP of Finance, Cybersecurity Response Committee members) — person-removal test leaves nothing substantive, confirming MR. Specificity reaches Level 4 via quantified lower-bound experience claims: 'over 24 years' and 'over 50 years of collective experience,' both independently checkable against resumes/records.

thinking:
Let me analyze this paragraph.

Content: Describes qualifications, experience, and credentials of VP of IT, NVP of Finance, and Cybersecurity Response Committee members. This is about who these people are and what qualifies them.

Category: Management Role - person-removal test: remove all person-specific content and nothing substantive remains. This is about qualifications, credentials, career history.

Specificity: Let me scan for facts.
- "VP of IT" - firm-specific cybersecurity leadership role (VP level with IT/security portfolio)
- "over 24 years" - quantified, verifiable (lower bound ≥ 24)

- "Chief Information Security Officer" - previous role showing career progression in security
- "cyber emergency response team" - domain-specific committee
- "undergraduate and graduate degrees in computer science" - educational background without institution names
- "professional certifications in cybersecurity" - referenced but not specifically named
- "NVP of Finance" - non-security executive role
- "Cybersecurity Response Committee" - firm-specific named committee
- "over 50 years of collective experience" - aggregate quantified metric (lower bound)

The verifiable facts here are the experience thresholds and the firm-specific roles and committee names.


content_category: None/Other

category_confidence: medium

reasoning: The paragraph is predominantly risk acknowledgment ('could have a material adverse effect' is speculation, not an assessment), a negative incident assertion without materiality framing ('we have not had a cybersecurity incident'), generic regulatory risk language, and a cross-reference to Item 1A. While one sentence mentions detecting and investigating unauthorized attempts, this language is extremely generic ('changes or updates to internal processes and tools') and subordinate to the paragraph's overall purpose of acknowledging risk rather than describing a program. No domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: Mixed content - risk acknowledgment, negative incident assertion, some process description, cross-reference.

Category analysis:
- "could have a material adverse effect" → speculation, not SI
- "To date, we have not had a cybersecurity incident" → negative assertion but without "material" framing
- "We proactively seek to detect and investigate unauthorized attempts..." → describes activities but very generically
- "See Item 1A" → cross-reference
- Overall this is mostly generic risk language with no substantive cybersecurity disclosure. The detection/investigation language is very generic ("detect and investigate unauthorized attempts and attacks against our IT assets"). No domain terminology.

- The negative assertion about not having had a cybersecurity incident lacks the materiality qualifier that would make it substantive disclosure, so it reads as generic risk boilerplate rather than meaningful information.

- The process description around detecting and investigating attacks is too vague and lacks any domain-specific details that would elevate it beyond standard corporate language.

- Rule 5 is pushing back on my classification though—it says even generic process descriptions should count as substantive disclosure if they describe any actual measure. I need to reconsider whether this crosses that threshold or remains primarily risk acknowledgment with minimal substance. even if it's generic. So maybe this should be RMP after all. But then I'm weighing that single sentence against the rest of the paragraph, which is dominated by risk acknowledgment and boilerplate language. The detection and investigation language is there, but it's thin and doesn't really substantiate how the program actually works. I think N/O is the right call—the paragraph is mostly hedging and risk talk rather than meaningfully describing their cybersecurity measures.


reasoning: This paragraph acknowledges general cybersecurity risk exposure and states a commitment to improvement, but does not describe any specific program, process, governance structure, or materiality assessment — it answers none of the six substantive questions. No domain terminology, firm-specific facts, or verifiable claims are present.


fact: Senior Vice President of Engineering

fact: Chief Information Security Officer (CISO)

fact: Chief Privacy Officer

fact: Privacy and Security Council

fact: CISO reports to CEO; CPO reports to General Counsel

reasoning: The paragraph primarily answers 'How is management organized to handle cybersecurity?' by enumerating specific roles (SVP of Engineering, CISO, Chief Privacy Officer), their reporting lines, and the Privacy and Security Council. The person-removal test leaves only generic program language ('understand threats, establish priorities, determine scope'), confirming MR over RMP. Multiple firm-specific roles and a named committee elevate to Level 3, but no QV-eligible facts (no numbers, dates, certifications, or named external entities) are present.

thinking:
Let me analyze this paragraph.

Category: This describes management's organizational structure for cybersecurity - who is involved, their roles, reporting lines. The person-removal test: remove all person-specific content and what remains is "helps us understand cybersecurity threats and risks, establish priorities, and determine the scope, elements, and implementation of a cybersecurity program... integrating cybersecurity considerations into our overall risk management strategy, and communicating key priorities to employees." That's fairly generic program description but the bulk of the paragraph is about WHO is involved and HOW they're organized. The primary question answered is "How is management organized to handle cybersecurity?" → MR.

The specificity here comes from firm-specific titles and roles like the SVP of Engineering, CISO, and Chief Privacy Officer, plus the named Privacy and Security Council and their reporting structure to the CEO and General Counsel. There are no quantifiable facts or external references, just internal organizational details. This is clearly Level 3 - Firm-Specific.


reasoning: The first sentence offers only a generic statement ('evaluated by senior leadership') with no substantive cybersecurity detail, and the second sentence is a cross-reference directing readers to Item 1A — pointing elsewhere rather than disclosing anything here. N/O paragraphs always receive Specificity 1.

thinking:
Let me classify this paragraph.

Content: Generic statement about senior leadership evaluating cyber risks, plus a cross-reference to Item 1A.

Category: The first sentence is generic ("evaluated by senior leadership") - no substantive detail. The second sentence is a cross-reference. This is essentially N/O - no substantive cybersecurity disclosure.

Wait - "evaluated by senior leadership" could be a minimal management role or board governance statement. But it's so generic and the cross-reference dominates. The cross-reference rule says pointing elsewhere → N/O.

Specificity: N/O always gets Level 1.


content_category: Third-Party Risk

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing processes for monitoring third-party service providers, requiring them to manage cybersecurity risks, and subjecting them to audits, making TP the clear category. All language is generic ERM vocabulary ('processes to identify, monitor and address,' 'cybersecurity audits,' 'manage their cybersecurity risks in specified ways') with no domain terminology passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Let me analyze this paragraph.

Content: About third-party risk management - processes to identify/monitor risks from third-party service providers, requiring them to manage cybersecurity risks, subject to audits.

Category: This is centrally about how third-party cyber risks are managed → Third-Party Risk (TP)

Specificity: Let me scan for facts:
- "processes to identify, monitor and address material risks" → generic ERM language, L1
- "third-party service providers" → generic
- "supply chain" → generic
- "cybersecurity audits" → this is borderline. "Audits" in general is not domain-specific, but "cybersecurity audits" - would an ERM professional use this? Probably yes, it's just "audits" with "cybersecurity" prepended. Not really domain terminology.

- "recommend securities measures" → generic
- "manage their cybersecurity risks in specified ways" → generic

No domain terminology that passes the ERM test. No firm-specific facts. No QV facts. This is Level 1.


reasoning: The first clause states a backward-looking materiality conclusion ('has not experienced any material cybersecurity breaches during the reporting period'), which per the codebook is a negative assertion with materiality framing → SI. The second clause ('could have a material adverse effect') is generic speculation present in every 10-K and does not override the assessment. No domain terminology, firm-specific facts, or verifiable claims are present — the negative self-assertion about absence of breaches is not externally verifiable — so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: "Although CLEAR has not experienced any material cybersecurity breaches during the reporting period, we acknowledge that cyber incidents, if they were to occur, could have a material adverse effect on our financial results."

Category: Two parts here:
1. "has not experienced any material cybersecurity breaches" - negative assertion with materiality framing → SI
2. "could have a material adverse effect" - speculation, "could" = NOT SI

The first clause is a materiality assessment (backward-looking negative assertion). Per the codebook: "We have not experienced any material cybersecurity incidents" → SI (negative assertion with materiality framing).

The second clause is just speculation with "could have," which doesn't qualify as SI. The real substance here is that materiality assessment in the opening clause, so this lands as SI overall.

Looking at specificity, I see materiality language and generic timeframes, but nothing firm-specific or externally verifiable—just boilerplate language about material breaches and adverse effects. This is Level 1 materiality language.


fact: Chief Information Officer (CIO)

reasoning: The paragraph primarily answers 'How does the board oversee cybersecurity?' — the Audit Committee receives reports, evaluates cybersecurity risks, and provides information to the Board, describing the oversight flow. The CIO and CISO are named as firm-specific cybersecurity leadership roles (Level 3), but no verifiable claims (specific dates, numbers, certifications) elevate it to Level 4.

thinking:
Let me analyze this paragraph.

Category: This paragraph discusses how cybersecurity risk is integrated into risk management, and then focuses on the Audit Committee receiving reports from CIO/CISO, evaluating risks, and reporting to the Board. The primary question answered is "How does the board oversee cybersecurity?" - this is about the oversight structure (Audit Committee receiving reports, evaluating risks, providing info to Board). → Board Governance

Specificity: Let me scan for facts:
- "Chief Information Officer" - CIO is a firm-specific cybersecurity leadership role (VP+ level)

- "Chief Information Security Officer" - CISO is firm-specific
- "Internal Audit Group" - this is a named team, but internal audit exists at every public company, so not firm-specific
- "quarterly" and "annually" - these are generic cadences

The CIO and CISO roles are firm-specific cybersecurity positions, which puts this at Level 3.


fact: Chief Technology Officer (CTO)

fact: CISO reports under the Chief Risk Officer (CRO)

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity — the CISO operates under the CRO, in coordination with CEO, CFO, CTO, and CLO. Person-removal test: stripping out all roles and reporting lines leaves only a generic statement about implementing a program to protect systems and respond to incidents, which collapses to near-nothing substantive → MR. Specificity is Level 3 due to firm-specific cybersecurity leadership roles (CISO, CTO) and explicit reporting structure (CISO under CRO), but no QV-eligible facts (no numbers, dates, named external entities, or certifications).

thinking:
Let me analyze this paragraph.

Category: The paragraph describes how the CISO works under the CRO with the executive team to implement the Information Security Program. This is about how management is organized to handle cybersecurity - the reporting lines (CISO under CRO), coordination with executive team, and the program they implement.

Person-removal test: Remove CISO, CRO, CEO, CFO, CTO, CLO, executive team, reporting lines. What remains? "implement the Information Security Program, which is 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." - This is generic program description but fairly thin.

The core here is organizational structure - the CISO reporting to the CRO and working with other executives - while the actual program details are boilerplate. I need to check whether CRO qualifies as a cybersecurity leadership role for classification purposes, since the codebook specifies CISO, CTO, CIO, and IT leadership roles, but CRO is a broader risk management position.


reasoning: The paragraph primarily describes an IT consultant hired to serve the company's own cybersecurity program (design, implement, monitor, test safeguards), which per Rule 3 makes it RMP rather than TP. The oversight language about the consultant's own security practices has a TP flavor, but the dominant framing is the consultant's role in the company's risk assessment processes. All language is generic business/risk management terminology ('risk assessment processes,' 'cybersecurity policies and procedures,' 'monitor and test safeguards,' 'security measures') with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Describes an IT consultant hired to help with risk assessment, design/implement cybersecurity policies, monitor and test safeguards. Also describes oversight of that consultant.

Category: This is about a third-party (IT consultant) but the consultant is hired to serve the company's own security program (design, implement, monitor, test). Per Rule 3: "Third parties hired to serve the company (assessors, consultants, pen testers) → RMP." However, the second half discusses oversight OF the consultant (ensuring they maintain security measures, report breaches) which is TP-like.

The paragraph is split: first part = consultant serving the company's program (RMP), second part = oversight of the consultant's own security (TP).

Looking more closely at the specific language, the opening sentences focus on what the consultant delivers for the company's risk management efforts, while the final sentence shifts to requirements we're imposing on the consultant itself—like maintaining their own security measures and reporting breaches that could affect us. So it's genuinely a two-part structure: the consultant's role in our program versus our oversight of their security posture.

The consultant is clearly hired to serve the company under Rule 3, which points toward RMP. The oversight language is really just about ensuring they can fulfill that role properly. As for specificity, I'm seeing mostly generic terms—"IT consultant" without a firm name, "risk assessment processes" and "cybersecurity policies" that are standard ERM language, and "monitor and test our safeguards" which is vague. Nothing here is firm-specific or detailed enough to push beyond Level 1.


reasoning: The paragraph describes the company's incident response process — what happens when an incident occurs (initial assessment, cross-functional meeting, evaluation of scope/impact/materiality) — answering 'what does the cybersecurity program do?' This is a procedural description, not an actual incident. Specificity remains Level 1: 'IT team,' 'cross-functional team,' 'initial assessment,' 'scope and potential impact,' and 'measures of materiality' are all general business/ERM language that would appear in any enterprise risk context; no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me classify this paragraph.

Content: Describes what happens when a cybersecurity incident occurs - IT team assessment, cross-functional team meeting, evaluation of scope/impact/materiality.

Category: This describes incident response processes - what the program does when an incident occurs. This is RMP (Risk Management Process). It's not an actual incident (ID), it's describing the process.

Specificity: Let me scan for facts.
- "IT team" - generic
- "cross-functional team" - explicitly listed as NOT firm-specific
- "materiality" - used as adjective describing what they assess, not a materiality conclusion

- No domain terminology that passes the ERM test - "initial assessment," "scope and potential impact," "incident response" processes are all general ERM language
- No named roles, no specific tools, no frameworks

This is a generic incident response process description. Level 1.


fact: Director of ITD (leads cybersecurity teams, reports to CFO)

fact: over 7 years of experience leading cybersecurity teams and programs

reasoning: The paragraph's primary content describes how management is organized for cybersecurity: the Director of ITD's role, responsibilities, reporting line to the CFO, qualifications, and escalation process to the Board. While board oversight is mentioned as bookends, the bulk of the text details the management structure. Person-removal test confirms MR — removing the Director of ITD, CFO, and reporting lines leaves only generic risk management language. Specificity reaches Level 4 because 'over 7 years of experience' is a quantified lower bound that is independently verifiable against the individual's career history.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph covers multiple topics - board oversight, management roles, and some program description. Let me apply the "what question" test.

The paragraph mentions:
- Board oversight (brief)
- Leadership team direction
- ITD led by Director of ITD, reports to CFO
- Director of ITD's experience (7 years)
- Director's responsibilities
- Reporting to Board annually + escalation process

This is a governance-chain paragraph (Board → CFO → Director of ITD → program). The primary content is about how management is organized - the Director of ITD role, reporting to CFO, qualifications, responsibilities.

When I strip away the specific roles and reporting lines, what's left is fairly generic language about cybersecurity risk management - identifying risks, monitoring exposures, implementing mitigations. The substance of this paragraph really centers on the Director of ITD's position, their qualifications, and where they sit in the organizational hierarchy. The board oversight bookends the discussion but isn't the main focus. So this reads as management-related content.

Now looking at the specificity markers: "Director of ITD" is a director-level title, but ITD (Information Technology Department) isn't a security-specific qualifier, so it doesn't meet the firm-specific threshold. The CFO reference is generic. But "over 7 years of experience" is a quantified fact with a specific number, which counts as verifiable. The "Eos leadership team" is a company self-reference, and "annual basis" is just standard cadence language.

That quantified experience threshold pushes this to Level 4, with the key verifiable fact being the 7-year minimum for leading cybersecurity teams.


reasoning: The paragraph describes a governance chain (Board → Audit Committee → CFO → program), with the primary purpose of showing how oversight flows from the board down; per Rule 1, governance-chain paragraphs default to BG. Specificity is Level 1 because all terms are general business language: 'Board of Directors,' 'Audit Committee,' and 'CFO' are generic governance structures present at every public company, and 'risk management process' / 'enterprise risk assessment' fail the ERM test. No domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content category: This paragraph describes both board oversight and management roles. The first three sentences are about board/committee oversight (BG). The last two sentences are about the CFO's role in cybersecurity (MR).

Looking at the text split: ~3 sentences about board/audit committee oversight, ~2 sentences about CFO responsibility. The governance chain (Board → Audit Committee → CFO) is described, and per Rule 1, governance-chain paragraphs default to BG when the purpose is describing the oversight structure. This paragraph describes how oversight flows from board to committee to management - it's an oversight structure description.

The CFO mention is part of describing the delegation chain rather than highlighting a cybersecurity-specific responsibility, so this still fits the board governance category. Checking the specificity: Board of Directors, Audit Committee, and CFO are all generic corporate roles, not firm-specific details, so there's no factual content that would push this toward MR.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — it describes policies governing third-party security risks and assessing vendors' security controls, making TP the clear category. Despite the 'TPRM' acronym, this is a standard industry abbreviation (like 'IRP') rather than a firm-distinguishing identifier, and the remaining language ('policies and practices,' 'assess potential risks,' 'security controls') is general enterprise risk management vocabulary that would not require cybersecurity domain expertise to produce — staying at Level 1.

thinking:
Classify this paragraph.

Content: About third-party security risk management - TPRM program, gathering info from third parties to assess their security controls.

Category: This answers "How are third-party cyber risks managed?" → Third-Party Risk. The central topic is oversight of external parties' cybersecurity posture.

Specificity:
- "third-party risk management (TPRM) program" - named internal program with distinguishing identifier → firm-specific (Level 3)
- "security controls" - let me check... this is somewhat domain-adjacent but "security controls" could be used in general ERM context. Borderline.

- Wait, I need to reconsider whether TPRM is actually a firm-specific identifier. TPRM is an industry-standard acronym for third-party risk management, not something unique to this company. It's more like using a generic term with an acronym rather than a true distinguishing identifier like the CIRP example in the codebook. So this might actually be general domain language rather than firm-specific.

- "Security controls" is borderline—it could be used by non-security ERM professionals in general risk contexts, so I'll treat it as general terminology rather than domain-specific.

- Looking at the whole paragraph, the language stays general throughout: policies and practices, gathering information, assessing risks, security controls. There's no firm-specific facts, no verifiable claims, and no specialized cybersecurity terminology beyond what a general risk professional might use. This is Level 1 - Generic Boilerplate.


fact: VP of IT provides reports to the Audit Committee

specificity_confidence: medium

reasoning: The paragraph primarily answers how the board oversees cybersecurity: the Board delegates to the Audit Committee, which receives reports from the VP of IT — a governance-chain paragraph defaulting to BG. The VP of IT is a VP-level role qualifying as firm-specific (Level 3); remaining content (Audit Committee, generic cadences, unnamed security professionals, general risk language) does not elevate further.

thinking:
Let me analyze this paragraph.

Category: This describes board oversight structure - Board delegates to Audit Committee, VP of IT reports to Audit Committee. The governance chain (Board → Audit Committee → VP of IT) is the primary structure. It answers "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts.
- "VP of IT" — this is a general IT title, not cybersecurity-specific. Per the codebook, "Head of IT," "IT Manager," "Director of IT" are NOT firm-specific. VP of IT... the codebook says "VP/SVP/EVP of IT" IS firm-specific.

Now checking the codebook language: "cybersecurity leadership roles at VP level or above (CISO, CTO, CIO, VP/SVP/EVP of IT, VP/SVP/EVP of Information Technology..." — yes, VP of IT qualifies as firm-specific. "Audit Committee" is generic since every company has one. The "at least annually" cadence is standard language, and "internal and external security professionals" are unnamed and generic. The domain terms like "cyber risks," "information security systems," and "emerging threat landscape" are all standard business risk vocabulary, not domain-specific enough to meet the ERM test.

So the VP of IT designation is what pushes this to Level 3.


reasoning: The paragraph describes the CISO's responsibilities: providing oversight, coordinating across functions, recommending adjustments, and communicating risk posture. Person-removal test: removing the CISO leaves a description of generic organizational responsibilities ('provides oversight and direction for the Program, coordinates with other corporate functions') — no substantive cybersecurity program activities remain, confirming MR. Specificity is Level 3 due to the named CISO role; the remaining language ('changes in technology, internal or external threats, business processes, regulatory requirements') is generic management vocabulary with no domain terminology.

thinking:
Let me analyze this paragraph.

Category: The paragraph is about the CISO's role - providing oversight, coordinating, recommending adjustments, communicating risk posture. Person-removal test: remove CISO and person-specific content → "provides oversight and direction for the Program and coordinates with other corporate functions and business segments to address all aspects of the Program, including recommending adjustments in response to changes in technology, internal or external threats, business processes, and regulatory or statutory requirements, and communicates the information security risk posture to the relevant internal individuals, committees and departments." This describes responsibilities of the role, not program activities per se. The paragraph is about what the CISO does organizationally - their responsibilities and coordination role. This is MR.

The CISO reference makes this firm-specific, while "Corebridge" is just a self-reference and the language stays generic around risk and program management without domain-specific terminology or QV facts. This lands at Level 3.


fact: CISSP certification

fact: CCNP certification

fact: CISA certification

fact: CySA+ certification

reasoning: The paragraph answers 'how is management organized?' by describing the management team's qualifications and certifications — squarely MR. The named certifications (CISSP, CCNP, CISA, CySA+) are independently verifiable via their respective issuing bodies ((ISC)², Cisco, ISACA, CompTIA), elevating specificity to Level 4.

thinking:
Classify this paragraph.

Content: Describes management team's experience and certifications for cybersecurity.

Category: Management Role - about who is responsible and their qualifications.

Specificity: CISSP, CCNP, CISA, CySA+ are named certifications verifiable via issuing bodies → Level 4.


fact: Three Directors with cybersecurity risk management experience

fact: Ann Bordelon, Chair of the Audit Committee

fact: Paulette Dodson

fact: Noah Glass

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — describing Audit Committee periodic updates, forward-looking IT discussions, and information flow to the broader Board, making it clearly Board Governance. Specificity reaches Level 4 due to the specific headcount ('three Directors') and three named individuals (Ann Bordelon, Paulette Dodson, Noah Glass) whose board membership and committee roles are independently verifiable via proxy filings.

thinking:
Let me analyze this paragraph.

Content: Board and Audit Committee oversight of cybersecurity, periodic updates, forward-looking discussions about IT changes, sharing with broader Board, three named directors with cybersecurity experience.

Category: Board Governance - clearly answers "How does the board oversee cybersecurity?"

Specificity: Named individuals (Ann Bordelon, Paulette Dodson, Noah Glass) - these are named individuals in cybersecurity context. "three Directors" is a specific number. These are QV-eligible facts (named individuals with verifiable claims about their roles, and "three" is a specific number).

The "three Directors" count is clearly quantified and QV-eligible, but I need to reconsider the named individuals themselves. While the names are verifiable against proxy filings, the codebook distinguishes between naming individuals as identification versus making a quantified claim about them. The names combined with their cybersecurity expertise claim might push this toward QV if the expertise is the quantified element, but I should focus on what's actually being quantified here.


fact: Chief Information Security Officer (CISO)

reasoning: Person-removal test: removing CISO and management references leaves 'a program designed to protect information systems... multidisciplinary teams deployed to address cybersecurity threats... monitor prevention, detection, mitigation and remediation in real time' — a substantive (if generic) program description remains, so RMP over MR. The CISO title elevates to Level 3, but the rest of the language (incident response plans, multidisciplinary teams, monitor/detect/mitigate) is generic ERM vocabulary without domain-specific terminology, and 'Audit Committee' is not firm-specific.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the CISO working with management to implement a cybersecurity program, deploying multidisciplinary teams, and monitoring/responding to incidents. It also mentions reporting to the Audit Committee.

Person-removal test: Remove CISO, management references. What remains? "a program designed to protect the Company's information systems from cybersecurity threats and to promptly respond to any cybersecurity incidents... multidisciplinary teams throughout the Company are deployed to address cybersecurity threats and to respond to cybersecurity incidents in accordance with the Company's incident response and recovery plans...

The paragraph continues with real-time monitoring of prevention, detection, mitigation and remediation activities, with incident reporting to the Audit Committee as needed. There's still substantive program description here, though it's fairly generic. The core focus is on what the program does—RMP seems like the right fit. The CISO is just the attribution, and the Audit Committee reporting is secondary to the main program description.

Looking at the three sentences together: the first establishes the program's purpose, the second describes the team structure and incident response framework, and the third covers the monitoring and reporting mechanisms. This is really describing the program's operational structure and processes rather than the CISO's role specifically.

On specificity, the CISO reference is firm-specific at Level 3, but "multidisciplinary teams," "incident response and recovery plans," and "prevention, detection, mitigation and remediation" are all generic Level 1 terms. The Audit Committee isn't firm-specific either. So the CISO attribution alone doesn't push this into a different category—the substance is still about the program itself.


reasoning: The paragraph describes internal risk identification and mitigation procedures including employee communication about the cybersecurity program, answering 'what does the program do?' All language is generic — 'safeguards,' 'limiting risks,' 'communication to employees' — with no domain terminology, firm-specific details, or verifiable facts.


content_category: Incident Disclosure

fact: January 2023 - specific date of the security incident

reasoning: Describes an actual security incident at the company's advisor including timeline and response actions, directly answering 'what happened?' → Incident Disclosure. 'January 2023' is a specific date tied to a real event, elevating specificity to Quantified-Verifiable.

thinking: Incident disclosure about an actual security event.


reasoning: The opening clause states a backward-looking materiality conclusion ('we do not believe that our business strategy, results of operations or financial condition have been materially adversely affected by any cybersecurity incidents'), which is an SI assessment per Rule 5. The remainder is generic threat landscape language and a cross-reference to Risk Factors. No domain terminology passes the ERM test—'assess risks,' 'invest in enhancements,' and 'engage in forums' are general business language—and there are no firm-specific or verifiable facts, leaving this at Level 1.

thinking:
Let me analyze this paragraph.

Content: The paragraph starts with a materiality assessment ("we do not believe that our business strategy, results of operations or financial condition have been materially adversely affected"), then discusses cybersecurity threats generally, mentions some generic activities (assess risks, invest in enhancements, engage in forums), and ends with a cross-reference to Risk Factors.

Category: The opening sentence states a conclusion about materiality - "we do not believe that our business strategy, results of operations or financial condition have been materially adversely affected by any cybersecurity incidents." This is a backward-looking materiality assessment → SI per Rule 5.

The materiality assertion itself is the key disclosure here, but it's a negative self-assessment that can't be independently verified. I'm also noticing what looks like boilerplate language—references to "global financial institutions" don't fit for a battery company, and the rest is just generic threat landscape terminology without specific facts or domain details.


fact: encryption

fact: data loss prevention technology

fact: authentication technology

fact: anti-virus and anti-malware software

fact: National Institute of Standards and Technology Cybersecurity Framework (NIST CSF)

type: framework

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing protective measures (encryption, DLP, authentication, anti-malware) and noting alignment with NIST CSF — clearly RMP. Multiple domain terms elevate to Level 2, but there are no firm-specific facts (no named roles, committees, or unique organizational details) and no QV-eligible facts (NIST CSF is referenced as informing the program, not as a certification held).

thinking:
Classify this paragraph.

Category: It describes what the cybersecurity program does - encryption, DLP, authentication, access control, anti-virus, etc. This is RMP.

Specificity: Many domain terms present - encryption, data loss prevention, authentication technology, access control, anti-virus, anti-malware, NIST CSF. These are all domain terms. No firm-specific facts beyond generic program description. No QV facts. Level 2.


reasoning: The paragraph's central topic is how third-party cyber risks are managed — contractual obligations imposed on service providers, mandated pre-engagement reviews, annual re-evaluations, and data deletion at contract termination — answering 'How are third-party cyber risks managed?' While the opening mentions ERM integration and risk escalation, the majority of the text describes vendor oversight requirements, making TP the dominant category. Specificity remains Level 1 because the language is entirely general business/risk management vocabulary ('contractual obligations,' 'industry best practices,' 'risk objectives,' 'defined thresholds,' 'at least annually') with no cybersecurity domain terminology (no SOC 2, encryption, specific security standards), no firm-specific facts (Blend's self-reference doesn't qualify), and no verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity program processes for third-party risk management, integration with ERM, risk escalation, contractual obligations for service providers, annual re-evaluation, and data deletion requirements.

Category: The central topic is how third-party cyber risks are managed - requirements imposed ON vendors (contractual obligations, annual re-evaluation, data deletion). While it mentions ERM integration, the bulk of the text is about vendor oversight. → Third-Party Risk

Specificity:
- "internal audit team" - generic

- "Blend's internal audit team" - company self-reference, not firm-specific
- "enterprise risk program" - general ERM language
- "contractual obligations" - general
- "at least annually" - generic cadence
- "sensitive data" - general
- "delete such data at the time of termination" - specific process but general language

The language throughout is mostly standard risk management terminology without specialized cybersecurity domain vocabulary. Terms like "cybersecurity objectives," "cybersecurity risk," and "risk thresholds" are general, and the vendor risk language around system access and data handling is similarly broad rather than domain-specific.

There's no firm-specific identifier here either—no CISO, named committees, or distinguishing program names. The processes described, like contractual reviews and annual re-evaluations, are specific actions but expressed in generic business language rather than technical or specialized terms. This stays at Level 1 as generic boilerplate that could apply to any company's filing.


reasoning: The paragraph states a backward-looking materiality conclusion ('these incidents have not had a material impact on our business strategy, results of operations, or financial condition'), making it SI per the materiality assessment rule. The subsequent speculation ('could have a material adverse effect') and cross-reference to Item 1A 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 — so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: States past incidents haven't had material impact, then speculates about future, then cross-references Item 1A.

Category: The key sentence is "to date, these incidents have not had a material impact on our business strategy, results of operations, or financial condition" — this is a backward-looking materiality assessment → SI per Rule 5.

The "could have a material adverse effect" is speculation (not SI), and the cross-reference is subordinate.

Specificity: Let me scan for facts.
- No domain terminology
- No firm-specific facts
- No QV facts

- The materiality claim is self-asserted without external verification, and there are no named roles, numbers, or certifications to support it.

Level 1.


fact: Enterprise Risk Committee ("ERC") — named non-generic committee

fact: Operational Risk Committee ("ORC") — named non-generic committee

fact: Chief Information Security Officer ("CISO")

fact: Specific team coordination with Compliance, Human Resources, Internal Audit and Legal

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity: two named committees (ERC led by CEO, ORC), the CISO's reporting lines between them, and the Cybersecurity team's coordination with named internal functions. Person-removal test confirms MR — removing roles, committees, and reporting lines leaves almost no substance. No board-level oversight is mentioned. Specificity is Level 3 due to named non-generic committees (ERC, ORC), CISO, and specific departmental composition, but no QV-eligible facts (no numbers, dates, named external entities, or certifications).

thinking:
Let me analyze this paragraph.

Content Category: This describes management-level committee structure (ERC, ORC), leadership roles (CEO, CISO), reporting lines between them, and team coordination. The primary question answered is "How is management organized to handle cybersecurity?"

The governance chain here is: ERC (led by CEO) → ORC → CISO → Cybersecurity team. This is about management's organizational structure, not board oversight. No board or board committee is mentioned.

Person-removal test: Remove CEO, CISO, titles, reporting lines, committee membership. What remains? "...cybersecurity risks identified by the Cybersecurity team" and "coordinates with other key stakeholders within the Firm, including Compliance, Human Resources, Internal Audit and Legal." The paragraph collapses substantially - the core content IS about the organizational structure. → MR.

Now looking at the specificity markers: The ERC and ORC are named committees specific to this firm, the CISO role is firm-specific, and the stakeholder list—Compliance, Human Resources, Internal Audit, Legal—identifies the actual team composition. The CEO reference is generic, and there are no quantifiable facts or external certifications mentioned. This lands at Level 3.


fact: CSO (Chief Security Officer) role leading cybersecurity team

fact: Executive Vice President and Chief Operations Officer (reporting line for CSO)

fact: over 20 years of security experience

fact: Certified Information Systems Security Professional (CISSP)

fact: Certified Information Security Manager (CISM)

reasoning: While the paragraph opens with board oversight (BG), the bulk of the text describes management's organizational role: the CSO's responsibilities, reporting line to EVP/COO, qualifications, and team composition — person-removal test collapses most of the paragraph, confirming MR. Specificity is Level 4 due to multiple verifiable facts: 'over 20 years' (lower-bound number), and named certifications CISSP and CISM which are independently verifiable via issuing bodies.

thinking:
Let me analyze this paragraph carefully.

**Content Category:**
This paragraph covers multiple topics:
- Board oversight ("Board of Directors considers cybersecurity... risk oversight function")
- Board/Audit Committee briefings ("annual briefing," "quarterly reports")
- CSO role, reporting lines, responsibilities
- CSO qualifications ("over 20 years of security experience")
- Team qualifications ("decades of relevant experience," certifications)
- Training mention

The paragraph starts with board oversight but quickly shifts to management organization. Let me assess what dominates:
- Board oversight: ~2 sentences
- Management role (CSO, reporting lines, responsibilities, qualifications, team): ~4-5 sentences

- The governance chain (Board → Audit Committee → CSO → team) is present, but the bulk of the text focuses on management's organizational role and structure rather than board oversight itself.

So the primary content is about how management is organized to handle cybersecurity — the CSO's position, reporting structure, qualifications, and team composition are what carry the substance. If I remove the CSO details, titles, qualifications, and team composition, very little remains beyond "Board receives briefings" and "we invest in training." That confirms management organization is the dominant category.

Now looking at specificity: "CSO" is firm-specific terminology for the cybersecurity leadership role, and "Executive Vice President and Chief Operations Officer" provides the exact title and reporting line.

The CSO holds multiple verifiable qualifications — over 20 years of security experience, CISSP certification, and CISM certification — all of which are named, verifiable credentials. That's multiple QV facts pointing to Level 4 specificity.


fact: Audit & Finance Committee (named non-generic committee)

fact: CISO

fact: CIO

reasoning: The paragraph primarily answers how the board oversees cybersecurity — the Audit & Finance Committee's oversight role, periodic reviews, and briefing structure from CISO/CIO. The named 'Audit & Finance Committee' is a non-generic committee name (distinct from a standard 'Audit Committee'), and CISO/CIO are cybersecurity-specific leadership roles, elevating to Level 3. No QV-eligible facts (no specific numbers, dates, named external firms, or certifications).

thinking:
Let me classify this paragraph.

Content: Describes how cybersecurity risks are reported to senior management and the Audit & Finance Committee, how the committee oversees cybersecurity, and how it receives briefings from CISO/CIO.

Category: This primarily answers "How does the board oversee cybersecurity?" — the Audit & Finance Committee's oversight role, briefing structure, information flow. → Board Governance

Specificity:
- "Audit & Finance Committee" — this is a named non-generic committee (not just "Audit Committee"), so firm-specific
- "CISO" — firm-specific cybersecurity role

- "CIO" — firm-specific (VP-level+)
- No QV facts (no specific numbers, dates, named external entities, certifications)

Level 3.


fact: Vice President of IT

fact: Named individual Randy Jepsen

fact: Named individual Russell Devendorf

fact: from 2008 to 2017 overseeing IT and risk management at a publicly traded homebuilder

fact: combined experience of almost 50 years

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — it details who holds responsibility (VP of IT, CFO), names the individuals, describes their qualifications and career histories, and summarizes combined experience. The person-removal test leaves only generic program references. Multiple quantified facts (25 years, 19 years, 2008–2017, ~50 years combined) are independently verifiable against resumes/public records, placing this at Level 4.

thinking:
Let me analyze this paragraph.

**Content Category:** This paragraph is about management's organizational role in cybersecurity. It names specific individuals (Randy Jepsen, Russell Devendorf), their titles (VP of IT, CFO), their responsibilities, qualifications, and experience. The person-removal test: remove all person-specific content and very little substantive program description remains. → **Management Role**

**Specificity:** Let me scan for facts:
- "Vice President of IT" — VP-level IT title → firm-specific
- Named individual "Randy Jepsen" → firm-specific

- Named individual "Russell Devendorf" → firm-specific
- "over 25 years of experience in the IT industry" → quantified-verifiable fact
- "19 years at Smith Douglas and The SMART Builder Solutions" → quantified-verifiable fact
- "from 2008 to 2017" → quantified-verifiable fact
- "almost 50 years" → quantified-verifiable fact
- CFO is NOT a cybersecurity-specific role per the codebook, but VP of IT at VP level qualifies as firm-specific

Multiple quantified-verifiable facts combined with firm-specific details puts this at Level 4.


fact: vulnerability scans related to vendors

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing a vendor management program with tiered assessments and contractual obligations imposed on providers. 'Vulnerability scans' is cybersecurity domain terminology elevating specificity to Level 2, but no named roles, committees, or verifiable facts are present.

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

Facts: vulnerability scans (domain term), security questionnaires, vendor risk management program details. Let me check specificity.

Domain terms: "vulnerability scans" passes ERM test. "Security questionnaires" - this is somewhat domain-specific. "Information Systems" is generic. "cybersecurity risks" is generic.

Actually, "vulnerability scans related to vendors" - vulnerability scans is domain terminology.

No firm-specific facts (no named roles, committees, etc.). No QV facts.

Level 2.


reasoning: The paragraph contains a backward-looking materiality assessment ('we have not experienced a cybersecurity event that was determined to be material'), which per the codebook is SI as a negative assertion with materiality framing. The opening sentences about periodic assessments are generic RMP-like language, and the closing sentence is a cross-reference to Item 1A, but the materiality conclusion is the most distinctive content. Specificity is Level 1 because there are no domain terms (only generic 'assessments and testing' and 'policies, standards, processes'), no firm-specific facts, and no verifiable claims — the negative materiality assertion is a self-reported claim about absence, which is not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: Discusses periodic assessments and testing, adjusting policies, mentions past cybersecurity incidents (not material), then cross-references Item 1A for materiality discussion.

Category: The paragraph has multiple elements:
1. Periodic assessments and testing of policies/processes → RMP-like but very generic
2. "have not experienced a cybersecurity event that was determined to be material" → SI (materiality assessment, negative assertion)
3. "whether any risks from cybersecurity threats are reasonably likely to materially affect" → cross-reference to Item 1A → N/O

4. The backward-looking materiality statement about not experiencing material incidents is the SI component, while the forward-looking assessment about reasonably likely risks gets deferred to Item 1A

. Looking at the specifics now—"periodic assessments," "policies and standards," "cybersecurity threats"—these are all generic terms without any firm-specific details, domain terminology, or quantified facts. This is clearly Level 1 boilerplate.


fact: CIO (cybersecurity-relevant leadership role)

fact: CIO has over two decades (~20+ years) of experience

fact: CEO, CFO, and GC each have over 15 years of experience managing enterprise risks including cybersecurity

reasoning: The paragraph is entirely about management qualifications, credentials, and experience — answering 'how is management organized to handle cybersecurity?' Person-removal leaves nothing substantive. Specificity reaches Level 4 because 'over two decades' and 'over 15 years' are lower-bound quantified claims that could be checked against resumes or public records.

thinking:
Let me classify this paragraph.

Content: Describes management expertise - CIO's experience, qualifications, and other executives' experience and degrees.

Category: Management Role - this is about who manages cybersecurity and their qualifications. Person-removal test: remove all person-specific content and nothing substantive remains.

Specificity:
- CIO = firm-specific cybersecurity role (Level 3)
- "over two decades of experience" = "over 20 years" = lower bound, verifiable → Level 4
- "over 15 years of experience" = lower bound, verifiable → Level 4
- CEO, CFO, GC = NOT firm-specific (generic roles at every company)

- "Over two decades" and "over 15 years" both establish verifiable thresholds that count as lower bounds, so these qualify as Level 4 specificity.


reasoning: The paragraph primarily answers 'How does the board oversee cybersecurity?' — management provides quarterly updates and annual program overviews to the board, and an enterprise risk assessment is reviewed with the board. This is about information flow to the board, making it BG. For specificity, 'Risk Committee' is a common governance structure similar to Audit Committee (not firm-specific), and all other language (quarterly updates, annual cybersecurity program overview, enterprise risk assessment) is generic governance/ERM vocabulary that any business professional could write — no cybersecurity domain terminology passes the ERM test.

thinking:
Let me analyze this paragraph.

Content Category: The paragraph describes how management provides updates to the board about cybersecurity matters, including quarterly updates and annual overviews. The primary question answered is "How does the board oversee cybersecurity?" — it's about information flow to the board. This is Board Governance (BG).

Specificity: Let me scan for facts.
- "Risk Committee" — this is a named committee, but is it firm-specific? The codebook says "Risk Committee of the Board" → BG. As a committee name, "Risk Committee" exists at many companies but is not as universal as "Audit Committee." Actually, looking at the NOT firm-specific list: "Board, Audit Committee, CEO, CFO, General Counsel" — Risk Committee isn't on the NOT list.

I'm reconsidering whether Risk Committee qualifies as firm-specific. It's fairly common at public companies but not universal like Audit Committee, so it's borderline. Since Audit Committee is explicitly listed as NOT firm-specific and Risk Committee isn't on that list, I'll treat it as somewhat more firm-specific, though I should be conservative given how prevalent these committees are across companies.

Now looking at the domain terminology — cybersecurity strategy, assessment, risks, enterprise risk assessment, cyber events, cybersecurity program — these are all standard governance and risk management language, not specialized domain expertise terms.


fact: threat intelligence

fact: Team composition specified as legal, finance, and internal audit

reasoning: The paragraph describes which members of management supervise cybersecurity efforts and the information channels they use; person-removal test leaves only generic means of staying informed (briefings, intelligence, alerts), so the substance is about management's organizational role → MR. Specificity reaches Level 3 because the specific departmental composition ('legal, finance, and internal audit') is a firm-specific organizational detail, and 'threat intelligence' is a domain term (Level 2).

thinking:
Let me analyze this paragraph.

Category: This describes management team members and their supervision of cybersecurity efforts. The primary question: "How is management organized to handle cybersecurity?" vs "What does the cybersecurity program do?"

Person-removal test: Remove "Other members of our management team, including those from legal, finance, and internal audit, will supervise efforts to..." → what remains is "prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel; threat intelligence and other information obtained from governmental, public or private sources, including external consultants we engage; and alerts and reports produced by security tools deployed in the IT environment."

That's a list of information sources, not substantive program activities. The paragraph is really about the organizational structure—who supervises and how they stay informed to do that supervising. The "means" are just information channels like briefings, threat intelligence, and tool alerts. This is management representation, not a program description.

Looking at the specificity markers: "threat intelligence" is domain-specific terminology that an ERM professional wouldn't naturally use, and "legal, finance, and internal audit" lists specific departments involved in the effort. Both of those push this toward Level 3. The future tense "will supervise" suggests this hasn't been fully implemented yet, but the content is still fundamentally about management's organizational role.


reasoning: The paragraph states a backward-looking materiality conclusion ('risks from cybersecurity threats have to date not materially affected us, our business strategy, results of operations or financial condition'), which per the codebook is a materiality assessment → SI. The cross-reference to Risk Factors is subordinate. Specificity is Level 1: the negative materiality assertion is not externally verifiable, there are no domain terms (no cybersecurity-specific practices/tools), no firm-specific facts, and no QV-eligible claims.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. "risks from cybersecurity threats have to date not materially affected us, our business strategy, results of operations or financial condition" - This is a backward-looking materiality assessment → SI
2. "we do, from time to time, experience threats and communicate security incidents" - vague acknowledgment
3. Cross-reference to Risk Factors section

The materiality assessment is the primary substance here. Per Rule 5, a backward-looking materiality conclusion → SI.

Specificity: Let me scan for facts.
- "have to date not materially affected us, our business strategy, results of operations or financial condition" - This is a negative self-assertion about materiality.

The negative assertion about materiality isn't externally verifiable, and there's no domain-specific terminology, firm-specific facts, or quantitative details—just generic boilerplate language at Level 1.


fact: confidentiality, integrity, and availability (CIA triad)

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing policies, procedures, monitoring, and incident response — all program activities, making it RMP. Nearly all language is generic boilerplate ('comprehensive approach,' 'robust protective measures,' 'assessing, identifying, and managing material risks'), but the explicit invocation of the CIA triad ('confidentiality, integrity, and availability') is an information security domain concept that a non-security ERM professional would not naturally use as a specific trio, pushing this narrowly to Level 2.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity program in general terms - policies and procedures, risk management integration, protective measures, monitoring, responding to incidents.

Category: "What does the cybersecurity program do?" → RMP. It describes activities and approach.

Specificity: Let me scan for facts:
- "policies and procedures for assessing, identifying, and managing material risks" → generic ERM language
- "integrated into the Company's overall risk management strategy" → ERM integration, generic

- "robust protective measures" → generic
- "promoting user awareness and education" → generic
- "continuously monitoring for potential threats" → generic
- "swiftly responding to any security incidents" → generic
- "confidentiality, integrity, and availability" → This is the CIA triad, foundational to information security. A general ERM professional wouldn't naturally use this specific phrase, so it does signal some domain expertise, though it could also appear in broader data privacy or business contexts.

Looking at the rest of the paragraph, most of it is genuinely generic—"assessing, identifying, and managing material risks" and "measures to protect our systems and data" aren't domain-specific at all. The CIA triad stands out as the clearest indicator of information security knowledge, even if it's borderline. enough in corporate governance contexts that it qualifies as domain terminology rather than pure infosec jargon. I'll settle on Level 2 with moderate confidence—the CIA triad is specific enough to suggest some security expertise, but not so specialized that a general ERM professional couldn't reasonably use it.


fact: Enterprise Risk Committee (ERC)

fact: Operational Risk Committee (ORC)

fact: Team coordinates with compliance, human resources, internal audit and legal

fact: 17-year period at one of the world's largest banking institutions

fact: Bachelor of Science in Electrical Engineering and Mathematics from University of Texas at Arlington

fact: Certified Information Systems Security Professional (CISSP)

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity: it describes TPG's committee structure (ERC, ORC), the CISO's role and reporting lines, CISO qualifications, and team composition. Person-removal test: removing the CISO, committees, qualifications, and reporting lines leaves almost nothing substantive, confirming MR over RMP. Specificity reaches Level 4 via multiple verifiable facts: CISSP certification (verifiable via (ISC)²), 17-year tenure (specific number), and a named university (University of Texas at Arlington).

thinking:
Let me analyze this paragraph carefully.

This is a dense paragraph covering multiple topics. Let me break it down:

1. Externally managed company relying on TPG's systems
2. TPG's Enterprise Risk Committee (ERC) - manages overall risk including cyber
3. Operational Risk Committee (ORC) - applies ERC policy decisions
4. CISO role - reports to ORC and ERC, leads cybersecurity team
5. CISO qualifications - 17 years at banking institution, BS from UT Arlington, CISSP
6. Cybersecurity team composition and expertise

Primary question: This paragraph covers governance structure (committees), management roles (CISO, team), and qualifications.

Now I'm seeing the organizational hierarchy more clearly - the ERC sits at the top under TPG's CEO, the ORC translates those policies into operations, and the CISO bridges both committees while leading the actual cybersecurity work. The paragraph really hinges on this chain of command and the CISO's background, which establishes credibility for the role. The next thinking fragment appears to be a continuation referencing specific qualifications—CISSP certification, 17 years of experience, and University of Texas at Arlington. These details are already captured in my current analysis as QV (quantifiable/verifiable) specificity markers, so there's nothing new to add here.


fact: CISO

fact: CIO

fact: Morgan Stanley's Cybersecurity Program

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — the Board receives periodic updates from various officers about the cybersecurity program, threat landscape, and incidents, which is classic Board Governance. Specificity reaches Level 4 because 'Morgan Stanley' is a named external/parent entity whose cybersecurity program is explicitly referenced, which is independently verifiable; CISO and CIO are firm-specific roles that establish at least Level 3.

thinking:
Let me classify this paragraph.

Content: Board oversight of cybersecurity, receiving updates from CCO, CIO, CISO, and Operational Risk functions about Morgan Stanley's Cybersecurity Program, threat landscape, risks, and incidents.

Category: "How does the board oversee cybersecurity?" → Board Governance (BG). Clear.

Specificity: Let me scan for facts.
- "CCO" - Chief Compliance Officer, not a cybersecurity-specific role
- "CIO" - firm-specific cybersecurity-adjacent role (VP+ level overseeing IT)

- "CISO" - firm-specific named role
- "Operational Risk functions" - not firm-specific
- "Morgan Stanley's Cybersecurity Program" - named entity, though Morgan Stanley appears to be the parent or affiliated entity whose program covers this fund

The CIO and CISO are firm-specific roles, and Morgan Stanley is named as the entity whose cybersecurity program applies here, which suggests a Level 4 classification.

Actually, I'm reconsidering whether Morgan Stanley counts as an external verifiable entity in the QV sense. It's the parent organization providing cybersecurity services, not a third-party firm like Mandiant or Deloitte. But it is a named, externally identifiable entity—the question is whether naming the parent company's program as the coverage mechanism constitutes a verifiable organizational fact or just an internal structural detail.

I think the key is that someone outside could verify T Series is a Morgan Stanley entity and confirm their cybersecurity program covers it, so I'll classify Morgan Stanley as a named firm (QV) and mark the CISO/CIO roles as firm-specific. This puts it at Level 4.


fact: Non-Financial Risk Committee

fact: Head of Operational Risk

fact: Firm Risk Committee

fact: BOTC

reasoning: This is a governance-chain paragraph describing how cybersecurity risks flow from management-level committees through escalation to Non-Financial Risk Committee and ultimately to board-level committees (Firm Risk Committee, BOTC, MS Board, Company Board) — the primary question answered is how the board oversees cybersecurity. Multiple named committees and the CIO role elevate to Level 3, but no quantified or externally verifiable facts are present.

thinking:
Let me analyze this paragraph.

This is about LGAM Private Credit LLC, which appears to be a subsidiary/affiliate of Morgan Stanley based on the content.

Content Category: This paragraph describes governance-chain from management committees up to the board. It covers both management-level committees and board reporting. The primary question answered is about oversight structure - how cybersecurity risk flows from committees to the board.

The paragraph starts with management-level cybersecurity risk committees, then escalation to Non-Financial Risk Committee, then CIO/Head of Operational Risk reporting to Firm Risk Committee, BOTC, and MS Board, and finally reporting to the Company Board.

Looking at the structure more carefully, this is fundamentally about how cybersecurity risks flow upward through the governance chain - from management committees through escalation points to board-level oversight. The management-level committee details support the main narrative of risk monitoring and reporting, making this a governance-chain paragraph focused on oversight structure. I'm evaluating the specificity level of these governance references. The CIO title qualifies as firm-specific according to the codebook, and there are multiple named committees like the Non-Financial Risk Committee and BOTC. However, there aren't any quantifiable facts—no specific numbers, dates, or named external entities that would elevate this to QV-eligible status.


fact: Security Operations Center (SOC)

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing processes, compliance policies, framework usage, and security infrastructure — all program activities making it RMP. ISO 27001:2022 is referenced as a standard driving risk assessment (aligned with, not certified → Level 2), and SOC is cybersecurity domain terminology, yielding Domain-Adapted specificity.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity program activities - processes, resources, technical defenses, compliance, ISO 27001 standard usage, SOC.

Category: "What does the cybersecurity program do?" → RMP. This is about activities, tools, frameworks.

Specificity facts:
- ISO 27001:2022 - domain term/framework (Level 2). "utilize the ISO 27001:2022 information security standard to drive our risk assessment" - this is "aligned with" not "maintain certification" → Level 2
- SOC (Security Operations Center) - domain term (Level 2)

- "insurance coverage" is too generic to be meaningful
- The mention of maintaining a SOC with enterprise event visibility is still just describing a standard domain tool, not a unique organizational capability, so it stays at Level 2
- ISO 27001:2022 with the specific version year doesn't change the classification since they're aligned with it rather than certified
- Overall this falls under RMP at Level 2, with domain terminology including ISO 27001 and SOC


fact: Vice President of IT

fact: Information Security Manager

fact: Weekly report from Information Security Manager to VP of IT

fact: United States Computer Emergency Readiness Team (US-CERT) alerts

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity — the CFO, VP of IT, and Information Security Manager roles, their reporting lines to each other, and what flows up to the board. Four of six sentences detail management-to-management reporting structure, making MR the dominant category over BG. Specificity reaches Level 4 because the paragraph references the United States Computer Emergency Readiness Team (US-CERT), a named external government entity whose alerts are independently verifiable. VP of IT and Information Security Manager are firm-specific roles that elevate to at least Level 3.

thinking:
Let me analyze this paragraph.

**Category:** This paragraph describes management's role in cybersecurity, including specific roles (CFO, VP of IT, Information Security Manager), reporting lines between them, and how information flows up to the board. The primary question answered is "How is management organized to handle cybersecurity?" - the bulk of the text is about reporting lines between management roles and what reports contain. The board briefing is mentioned but is subordinate to the management reporting structure.

Actually, let me reconsider. The paragraph covers both management organization AND board oversight. Let me assess which dominates:
- Sentence 1: Management responsibility (MR)

- Sentence 2: Who oversees the program (MR)
- Sentence 3: ISM → VP of IT reporting (MR)
- Sentence 4: VP of IT → CFO reporting (MR)
- Sentence 5: Board briefed quarterly on incidents (BG)
- Sentence 6: Board overview annually (BG)

Management reporting lines dominate (4 sentences vs 2 for board). But Rule 1 says governance-chain paragraphs (Board → Committee → Officer → Program) default to BG when describing oversight structure. This paragraph describes information flowing UP from management to board - it's a governance chain. The content focuses heavily on how management roles relate to each other, but the overall structure traces accountability back to board oversight, which makes this a board governance category.

Looking at specificity now: VP of IT is firm-specific, Information Security Manager falls below the Director threshold so it's not firm-specific, CFO isn't firm-specific per the codebook. Weekly reporting cadence is specific but generic. US-CERT is a named external government entity, which counts as verifiable. Preventative maintenance tools is generic.

So this hits Level 4 because of the US-CERT reference and the VP of IT role.


reasoning: The paragraph contains speculation ('could have a material adverse effect' — not an assessment), a brief mention of maintaining cybersecurity insurance (a substantive SI fact about how cybersecurity affects finances), and a lengthy cross-reference to Item 1A. Per Rule 6, the insurance mention prevents N/O classification; it answers 'how does cybersecurity affect the business?' making SI the best fit. Specificity is Level 1: 'cybersecurity insurance' is general business language (any ERM professional would discuss insurance), no domain terminology, no firm-specific or verifiable facts.

thinking:
Let me analyze this paragraph.

Content: Speculation about incidents, mention of cybersecurity insurance, cross-reference to Item 1A.

Category: The paragraph has three parts:
1. "may not be successful in preventing or mitigating a cybersecurity incident that could have a material adverse effect" — speculation, "could have" → NOT SI
2. "we maintain cybersecurity insurance, the costs related to cybersecurity threats or disruptions may not be fully insured" — mentions insurance, which is SI territory
3. Cross-reference to Item 1A risk factors — N/O

The insurance mention is a real SI element.

But the insurance statement is brief and hedged, and the speculation about potential adverse effects doesn't qualify as an assessment. The cross-reference to Item 1A takes up significant space but doesn't count. The paragraph is fundamentally structured around speculation and a cross-reference, with only a passing acknowledgment that insurance may not cover all costs—so the SI content is minimal relative to the overall text. The insurance disclosure is substantive—it describes an actual cybersecurity measure—so this should be Strategy Integration rather than pure N/O, even though the cross-reference dominates by text volume. The insurance mention is the only real disclosure about how cybersecurity affects the business, making it the key content despite being brief. As for specificity, "cybersecurity insurance" is just standard business terminology, not domain-specific jargon or firm-specific detail, so this lands at Level 1.


fact: Cybersecurity Manager

reasoning: The bulk of the paragraph answers 'How are third-party cyber risks managed?' — describing pre-engagement security assessments, ongoing monitoring, and compliance oversight of third-party providers. The final sentence is a materiality assessment (SI), but the TP content dominates by volume. For specificity, 'Cybersecurity Manager' is a cybersecurity-qualified title identifying a specific role in this company's posture (analogous to 'Information Security Officer' on the firm-specific list), elevating to Level 3. The remaining language ('security assessments,' 'data breaches,' 'quarterly') is general business/ERM vocabulary that does not pass the domain-term ERM test or qualify as QV.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers two distinct topics:
1. Third-party risk oversight (the bulk of the text)
2. A materiality assessment statement at the end

**Content Category:**
The primary question answered is "How are third-party cyber risks managed?" - the majority of the text describes vendor oversight processes. The last sentence is a materiality assessment (SI), but it's a single sentence subordinate to the main TP content.

→ **Third-Party Risk**

**Specificity:**
Let me scan for facts:
- "quarterly assessments" - generic cadence, not QV

- "Cybersecurity Manager" - this is a named role, but it's below Director level and the codebook specifies Director-level titles with security qualifiers or VP+ roles, so this doesn't meet the threshold for a firm-specific role.
- "security engineers" - generic team reference, not firm-specific
- "security assessments" - general business language
- "data breaches" - this is fairly general business language now, not domain-adapted

I'm reconsidering "Cybersecurity Manager" though. The NOT list explicitly excludes general IT titles like "IT Manager" and "Director of IT," but "Cybersecurity Manager" has a security qualifier that makes it more specialized. The pattern suggests the codebook excludes broad IT roles while including security-specific ones, so Manager-level with a security qualifier might actually fall into that firm-specific category after all. Looking at the codebook examples more carefully, "Information Security Officer" is listed despite not being VP or Director level, which suggests the threshold isn't strictly about seniority but about having a cybersecurity-specific title. "Cybersecurity Manager" has that clear cybersecurity qualifier unlike generic "IT Manager," and since not every company maintains this role, it effectively signals their security posture—so this should count as Level 3.

I'm also reconsidering whether "security engineers" as a named team qualifies as firm-specific. The codebook accepts specific team compositions like "Legal, Compliance, and Finance," but "security engineers" is just a role description rather than a named team structure, so it doesn't meet that threshold.

This comes down to Third-Party Risk at Level 3, with "Cybersecurity Manager" as the firm-specific element.