reasoning: The paragraph describes the company's internal cybersecurity processes: incident response plans, business continuity management, exercises, and metrics reporting. The audit committee mention is subordinate to the process description. All plan names (Crisis Management Plan, Incident Response Plan, Business Resiliency Policy) are generic/descriptive rather than uniquely identified programs. Cadences ('at least annually', 'quarterly') are generic, 'audit committee' is on the NOT list, and no named frameworks, tools, firms, dates, or cybersecurity-specific roles appear.

thinking:
Let me analyze this paragraph.

Content: Describes incident response plans, business continuity, exercises, and reporting. The primary content is about internal processes - plans, policies, exercises, reporting.

Category: Risk Management Process - describes internal cybersecurity processes, IR planning, business continuity, exercises. The audit committee mention at the end is subordinate.

Specificity: Let me check for specific facts.
- "Crisis Management Plan" - generic program name
- "Incident Response Plan" - generic program name
- "Information Security Incident Management Policy" - this has a specific name but is it unique enough? It's a descriptive name, not a unique identifier like "CIRP"

- "Business Resiliency Policy" - similar
- "at least annually" - generic cadence
- "quarterly basis" - generic cadence
- "IT security team" - not a cybersecurity-specific title from the IS list
- "audit committee" - generic, on the NOT list
- "executive management" - generic

The codebook requires "Named internal programs with unique identifiers" to qualify, with a note that generic names like "incident response plan" don't cut it. All of these—Crisis Management Plan, Incident Response Plan, Information Security Incident Management Policy, Business Resiliency Policy—are descriptive but lack distinguishing identifiers, so none of them qualify as named programs.

This is just generic boilerplate with no frameworks or specific facts from the IS list.


content_category: Risk Management Process

category_confidence: medium

specificity_confidence: high

reasoning: This paragraph is a structural overview of how the company's cybersecurity program operates: incidents follow response procedures, the Audit Committee oversees, and a Senior Director coordinates initiatives through IT/cybersecurity personnel. No single category dominates strongly—it touches process, board oversight, and management—but the primary communicative purpose is describing the company's cybersecurity program structure and operations, making Risk Management Process the best fit. The Audit Committee mention is brief and generic (NOT list), and the Senior Director sentence describes what the role does functionally rather than who the person is. 'Senior Director - Information Security' is a cybersecurity-specific title (IS list), yielding Firm-Specific; no second QV-eligible fact is present.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Multiple topics: incident response procedures, Audit Committee oversight, and Senior Director - Information Security role.

Dominant category: This paragraph has three sentences covering three different things. Let me assess:
1. "Cybersecurity incidents are investigated and remediated in accordance with our incident response procedures" - Risk Management Process
2. "Cybersecurity is overseen by the Audit Committee of the Board of Directors" - Board Governance
3. "The Senior Director - Information Security coordinates with and directs cybersecurity initiatives through information technology and cybersecurity personnel throughout RPM" - Management Role

No single category dominates clearly.

Looking at this more carefully, the three sentences are fairly balanced between process, board oversight, and management function. The first describes incident response procedures, the second establishes board-level governance, and the third identifies a specific role responsible for coordinating cybersecurity initiatives. Since the paragraph is fundamentally describing how the company structures and manages its cybersecurity operations—from incident handling through board oversight to day-to-day coordination—Risk Management Process seems like the strongest fit, though it's close. I'm counting the text to see which topic dominates, and the Senior Director sentence is clearly the longest. But applying the person-versus-function test, this is describing what the role does structurally rather than who the person is, which points toward Risk Management Process. The title itself is cybersecurity-specific, and the sentence explains how this role coordinates and directs through IT and security personnel—that's organizational structure. Since the paragraph weaves together incident response procedures, board oversight, and management coordination, the unifying theme is really how the company operates its cybersecurity program, so Risk Management Process seems like the right fit, though I'm still working through whether the governance structure angle might be stronger.

Now I'm checking the specificity markers: "Audit Committee" is generic, but "Senior Director - Information Security" is a cybersecurity-specific title that would be Firm-Specific. There are no quantifiable facts like dates or dollar amounts, so this lands in Firm-Specific.

fact: Senior Director - Information Security


content_category: Management Role

category_confidence: high

reasoning: The entire paragraph describes the VP of IT as a person — their tenure, experience, career history, degrees, and certifications. This is squarely the person, not the function. Multiple QV-eligible hard facts: specific years of experience (25+), named certifications (CISM, Data Privacy), and quantified prior roles (three public companies).

thinking:
Classify this paragraph.

This is about the VP of IT's qualifications, experience, and certifications - clearly about the person, not the function.

Content category: Management Role

Specific facts:
- VP of IT (cybersecurity-specific? It's "VP of IT" not "VP of IT/Security" exactly, but it's a leadership role overseeing cybersecurity. Let me check the IS list: "CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security" - VP of IT is close to VP of IT/Security. Given context that this person leads cybersecurity programs, I'll treat it as a cybersecurity-specific title.)

- The candidate has over 25 years of experience, worked across three public companies, and holds both CISM and Data Privacy certifications - all of which are specific, verifiable facts that qualify this as Quantified-Verifiable.

fact: VP of IT (cybersecurity leadership role)

fact: over 25 years of experience in IT and information security

type: quantified

fact: led cybersecurity programs for three public companies

fact: Certified Information Security Manager (CISM)

fact: Data Privacy certification


reasoning: The paragraph describes the company's internal cybersecurity organizational structure — an incident response team and an information security advisory board — along with the advisory board's composition and responsibilities. The primary content is about internal processes and governance functions, not about any individual person's credentials (person-vs-function test favors RMP). The named 'information security advisory board' and its specific multi-department composition are firm-specific facts, but there are no QV-eligible hard verifiable facts (no dates, dollar amounts, headcounts, named firms, or tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes:
1. An incident response team headed by "Director and VP of IT" that reports material incidents to executive officers and Board
2. An "information security advisory board" comprised of senior leaders
3. The composition of that advisory board (product line, sales and marketing, manufacturing, legal, finance, human resources, supply chain, information technology, and regional representation)
4. Responsibilities of the advisory board (bullet points about advising on security policy, roadmap, education, compliance, risk mitigation)

**Content Category:**
- The paragraph describes internal cybersecurity processes and organizational structure.

The incident response team reports up to executives and the Board, but the real focus here is the advisory board itself—its makeup and what it does. This is fundamentally about how the organization manages cybersecurity risk through internal governance structures. The advisory board is a management-level committee, not a Board-level one, so this falls under Risk Management Process rather than Board oversight.

Looking at specificity, the "information security advisory board" is a named committee specific to this company, which counts. The team composition across product, sales, marketing, manufacturing, legal, finance, HR, IT, supply chain, and regional areas is also a concrete organizational detail. But there are no named frameworks, dates, dollar amounts, or external firms mentioned. So this qualifies as Firm-Specific information based on the named committee and departmental composition.

For quantifiable verification, the committee name and team structure aren't hard verifiable facts in the way dates or financial figures would be—they're just organizational setup. There's nothing here that meets the QV threshold.

fact: Information security advisory board (named internal committee)

fact: Advisory board comprises product line, sales and marketing, manufacturing, legal, finance, human resources, supply chain, information technology, and regional representation


content_category: Strategy Integration

reasoning: The paragraph makes a materiality assessment ('have not experienced any material cybersecurity threats or incidents') and discusses cybersecurity insurance coverage and potential financial impact, placing it in Strategy Integration per Rule 6. No named insurers, dollar amounts, frameworks, or firm-specific facts — all language is boilerplate.

thinking:
Let me analyze this paragraph.

Content: No material incidents + can't guarantee future safety + cybersecurity insurance mention + cross-reference to Risk Factors.

The paragraph contains a materiality assessment ("have not experienced any material cybersecurity threats or incidents") plus mentions cybersecurity insurance. Per Rule 6, materiality disclaimers → Strategy Integration.

Specificity: No named standards, no firm-specific facts from the IS list. Generic boilerplate materiality language, generic insurance mention, generic cross-reference.


content_category: Board Governance

reasoning: The paragraph's primary communicative purpose is how the board and leadership receive cybersecurity information and maintain oversight: the CIO updates the Audit Committee, Board members can raise concerns, and the CSIRP escalates material incidents to the Board. While the CIO is the grammatical subject of the first sentence, the person-vs-function test shows this is about the governance/reporting structure, not the CIO's qualifications. Two of three main points center on board-level oversight. Firm-Specific due to CIO (cybersecurity-specific title on the IS list), named Executive Leadership Team composition, and CSIRP as a named internal program with a distinguishing abbreviation.

thinking:
Let me analyze this paragraph.

Content: The paragraph discusses the CIO providing briefings to the Executive Leadership Team and updating the Audit Committee. Board members can raise concerns. The CSIRP includes escalation protocols.

Category analysis:
- CIO providing briefings to leadership and Audit Committee → could be Management Role or Board Governance
- Board members raising concerns → Board Governance
- CSIRP escalation protocol → Risk Management Process

The primary actors are the CIO (providing briefings, updating committee) and Board members (raising concerns). The paragraph is about communication/reporting flows and escalation protocols. The CIO is the grammatical subject in the first sentence, but the content is about oversight and reporting structures rather than the person's qualifications.

I'm reconsidering the categorization here. The CIO is providing briefings and updates, but the real focus is on how information flows between management and the board, and how the board can escalate concerns through the CSIRP. While the CIO is the one doing the briefing, the substance is about board oversight and governance processes rather than the CIO's role itself. The escalation protocol to the board tips this toward Board Governance as the primary category. The CIO's briefing function is really about the governance structure—how the board and leadership stay informed and maintain oversight of cybersecurity. Even though the CIO is the grammatical subject performing the actions, the paragraph's core purpose is describing the board's role in receiving information and escalating concerns, not the CIO's qualifications or management responsibilities. So this falls under Board Governance.

Now I'm checking the specificity of the details: CIO is a cybersecurity-specific title that appears on the IS list, so that's a firm-specific fact. The Executive Leadership Team is a named group with defined composition. CSIRP is an internal program with its own identifier. The biannual frequency is just a generic cadence, and the Audit Committee isn't on the list, so those don't count as firm-specific facts.

Since there's at least one IS fact present, this qualifies as firm-specific. And there are no quantifiable values like dates, dollar amounts, headcounts, third-party firms, products, or certifications, so it's not QV.

fact: CIO (Chief Information Officer)

fact: Executive Leadership Team consisting of executive officers and senior leaders

fact: CSIRP (Cyber Security Incident Response Plan)


reasoning: The paragraph describes management-level governance structures overseeing cybersecurity: the CISO, CEO, and two named management committees (Information Security Council, Executive Information Security Committee). The primary actors are management figures, with the board mentioned only briefly at the end as a subordinate detail. While no individual credentials or backgrounds are described, the paragraph's focus is on management reporting structures and oversight cadence rather than technical processes, tools, or frameworks. Multiple firm-specific facts (two named non-generic committees and CISO role) place this at Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph from Radian Group Inc's 10-K filing.

Content category: This paragraph describes governance and oversight structures. Let me apply the person-vs-function test and category rules.

The paragraph mentions:
1. Information Security Council and Executive Information Security Committee (named committees)
2. CISO and colleagues with experience/education
3. CEO receives updates from CISO
4. Internal and external auditors
5. Quarterly reviews by management, executive committees, and board

This is a mix. The primary topic is oversight structure - who oversees the program. The grammatical subjects are "we" (the company), "our CEO", and management/committees.

Looking at the governance structure more closely, the focus is really on the management-level oversight mechanisms—the councils and committees that handle day-to-day cybersecurity governance, with the CISO and CEO playing central roles. The board's involvement is mentioned but appears secondary to the management structures that drive the program. This is fundamentally about how management organizes and oversees cybersecurity at the organizational level. The Information Security Council and Executive Information Security Committee are named committees specific to this organization, and the CISO is a cybersecurity-specific role, so those count as firm-specific details. But there's nothing quantifiable here—no dates, numbers, named vendors, or certifications—which means this falls into Firm-Specific rather than Quantifiable Verifiable. The core of this is Management Role, focusing on the governance structure and oversight mechanisms the organization has put in place for cybersecurity.

fact: Information Security Council

fact: Chief Information Security Officer


reasoning: The paragraph describes how the Board and Audit Committee exercise oversight through quarterly reports from the CISO, CTO, and ERM Committee members — the board/committee is the recipient and primary frame of reference, making this Board Governance. Contains multiple IS-list facts (CISO, CTO, ERM Committee, six program components) but lacks two QV-eligible hard verifiable facts (named roles and committees don't count toward QV; 'six components' is organizational detail), so it is Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

The paragraph discusses:
1. CISO reports to the Board quarterly
2. Reports address six components of Information Security program
3. Audit Committee oversight of data security
4. CTO, CISO, or ERM Committee members report to Audit Committee quarterly

Primary actor analysis: The paragraph is about board-level oversight structures. The Board and Audit Committee are receiving reports. The CISO/CTO are mentioned in terms of their reporting TO the board/committee.

This is Board Governance - the paragraph describes how the board and its committee exercise oversight through receiving reports.

Now I'm checking which elements are specific enough for the IS list. The CISO and CTO are cybersecurity-specific titles, and the Enterprise Risk Management Committee is a named committee, so those qualify. The "six components" reference gives me a quantified fact about the Information Security program. The Audit Committee and quarterly cadence are too generic to include.

Looking at what's actually hard-verifiable: "six components" is a number, but it's organizational detail rather than an external fact like a date or certification. Comparing to similar cases, this doesn't quite reach the QV threshold. So I'm left with multiple IS-list facts but essentially zero QV-eligible ones, which points to Firm-Specific classification.

fact: CISO reports to the full Board of Directors

fact: CTO mentioned as reporting to Audit Committee

fact: Enterprise Risk Management Committee

fact: Information Security program has six components


reasoning: The paragraph describes the composition and reporting structure of a management-led Risk Committee, with the committee as the grammatical subject. Its primary content is organizational structure — who sits on the committee and how it reports upward — making it about management's cybersecurity oversight structure rather than the processes themselves. Contains firm-specific facts (named Risk Committee, CIO membership, detailed departmental composition) but lacks two QV-eligible hard facts.

thinking:
Let me analyze this paragraph.

Content: Describes a management-led Risk Committee, its composition, and its role in reviewing cybersecurity risk and reporting to a board committee.

Category: This is about a management committee structure and composition. The grammatical subject is "The Risk Committee" (management-led). It describes who comprises the committee and what it does. This is Management Role - it's about the organizational structure of management's cybersecurity oversight, the composition of the committee, reporting lines.

Wait - let me reconsider. The Risk Committee is a management committee. The paragraph describes its composition and function. The person-vs-function test: is this about people or about what the function does? It lists specific roles that comprise the committee (person/structure), and then describes what the committee does (reviews risk, reports to board committee).

The committee composition is clearly named and specific - I can verify the Risk Committee exists, and the roles listed (CIO, CFO, General Counsel, Chief Internal Auditor, and others) are all identifiable positions. That's definitely two hard verifiable facts right there.

The university names like American InterContinental University and Colorado Technical University are subsidiary references, which don't count as QV-eligible since they're internal company self-references. And I'm not seeing the kinds of concrete data points that would push this into QV territory - no specific dates, dollar amounts, headcounts, or third-party certifications mentioned.

So this lands as Firm-Specific (3), and the category is Management Role since the core subject is the committee structure and its reporting relationships to the board.

fact: Named non-generic committee: Risk Committee

fact: CIO is a member of the Risk Committee

fact: Specific composition: President/CEO, CFO, General Counsel, CCO, Chief Internal Auditor, Risk & Insurance Program Manager, SVP-AIU, SVP-CTU, CIO, VP-HR


reasoning: The paragraph describes the composition of a named management committee (ISO Committee), detailing specific roles, their qualifications, and organizational structure. This is about the people and their positions — committee membership, operational expertise, and reporting structure — making it Management Role rather than Risk Management Process (no processes, tools, or frameworks are described). Multiple firm-specific facts exist (CISO, CTO, named committee, specific team composition, 25 years of experience), but only one QV-eligible hard fact (25 years), so it stays at Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

This describes the composition of the ISO Committee - naming specific roles and their expertise. Let me determine category and specificity.

Category: This is about management committee composition. The ISO Committee is a management-level committee. The paragraph describes who sits on it and their qualifications. This is about organizational structure and the people/roles involved.

Is this Management Role or Board Governance? The ISO Committee appears to be a management committee (not a board committee). The paragraph describes the composition and qualifications of committee members.

This is Management Role - it's about the people, their titles, qualifications, and committee structure at the management level.

The details are quite specific - the committee includes named executives with clearly defined roles like Co-Presidents, Vice-Chairman of data and analytics, President of the international division, and various C-suite officers. The paragraph also includes quantified experience metrics like "over 25 years in risk management," making this highly specific to the organization rather than generic.

Looking at what qualifies as a QV-eligible fact, I need to focus on concrete metrics: the "over 25 years of experience" is the only one that fits the criteria of a specific number. Named roles and titles don't count toward QV eligibility, so that leaves just one QV-eligible fact here, placing this in the Firm-Specific category.

fact: ISO Committee (named management committee)

fact: CISO is a participant on the ISO Committee

fact: CTO is a participant on the ISO Committee

fact: Chief Intellectual Property and Privacy Officer role

fact: Chief Risk Officer chairs the committee with over 25 years of experience in risk management

fact: Committee includes Co-Presidents of First American Title Insurance Company, Vice-Chairman of data and analytics business, President of international division


reasoning: The paragraph is primarily about the people who lead cybersecurity — their titles, qualifications, years of experience, degrees, and committee memberships. While the final sentences describe committee reporting to the Audit Committee, the dominant content is credentials and organizational structure of named cybersecurity roles. Two QV-eligible hard facts: 27 years experience (CIO) and 27 years experience (Director of Information Security).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes multiple management roles and their qualifications, plus committee structures. Let me break it down:

1. VP and CIO oversees cybersecurity programs
2. Director of Information Security leads day-to-day administration
3. VP/CIO has 27 years experience + Doctor of Business Administration
4. Director of Info Security has 27 years experience + degree in IT Management
5. Director of Info Security chairs Information Security Committee
6. Executive Information Security Oversight Committee composition
7. That committee facilitates notification to Audit Committee

Primary content: This is heavily about the PEOPLE - their qualifications, credentials, experience, reporting lines, and committee memberships.

Now I'm checking the specificity of the credentials mentioned. The CIO and Director of Information Security both have quantified experience, and the Director has a named degree in IT Management. The CIO's Doctor of Business Administration is generic without a university name, so that doesn't count toward qualifications. The Information Security Committee and Executive Information Security Oversight Committee are the structural elements here, with clear reporting relationships to the Audit Committee. I'm identifying which facts qualify as quantified-verifiable by checking for specific numbers and named entities. The two instances of 27 years of experience both count, so this meets the threshold for a Quantified-Verifiable classification.

fact: Vice President and Chief Information Officer

fact: Director of Information Security

fact: 27 years of technology leadership experience (CIO)

fact: Doctor of Business Administration (CIO)

fact: 27 years of experience in infrastructure and security operations (Director)

fact: Information Security Committee

fact: Committee composed of VP/CIO, SVP/CFO, SVP/CLO, SVP/CHRO


reasoning: The CISO is mentioned as receiving threat intelligence updates, but the paragraph's substantive content describes the cybersecurity team's processes: monitoring information systems, following a written incident response runbook, and mitigating incidents. Removing the CISO reference, the paragraph still functions as a process description. The CISO title (despite the typo 'CICSO') is a cybersecurity-specific role triggering Firm-Specific, but no second hard verifiable fact exists to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Talks about CICSO (likely typo for CISO) being informed about cybersecurity developments, then describes what the cybersecurity team does - monitoring, incident response using a runbook.

Category: The paragraph mentions CISO briefly but the bulk is about processes - monitoring, incident response runbook. Apply person-vs-function test: remove "The CICSO is regularly informed" and the paragraph still describes processes. → Risk Management Process.

Specificity:
- "CICSO" (typo for CISO) - cybersecurity-specific role → Firm-Specific fact

- "written security incident response runbook" is a generic program name without unique identifiers, and there are no named frameworks, dates, dollar amounts, or specific tools mentioned

So I'm counting one firm-specific fact here - the CISO role reference - which puts this at a Firm-Specific level (3).

fact: CICSO (CISO) role referenced


reasoning: The paragraph's primary purpose is identifying WHO manages cybersecurity — the CTO and CISO with their experience, and the specific departmental composition of the cross-functional team. While processes are mentioned, they are not described in detail; the focus is on the people and organizational structure responsible for the program. Specificity is Firm-Specific: multiple IS-list facts (CTO, CISO, specific team composition, 25 years of experience), but only one QV-eligible hard fact (25 years), which is insufficient for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content category: This paragraph mentions CTO and CISO and their experience, but also describes the program and cross-functional team. Let me apply the person-vs-function test.

The paragraph starts with "cybersecurity risk assessment and management processes" and "Information Security program" - these are processes. The CTO and CISO are mentioned with "25 years of experience" which is about the person. But then it goes on to describe the cross-functional team and departmental composition.

If I remove the CTO/CISO titles and experience, the paragraph still describes processes and team composition.

Looking more closely, the core focus is really on the people implementing these processes - the CTO and CISO with their experience level, and the cross-functional team structure they lead. The paragraph's main point is establishing who's responsible for cybersecurity management, not just what processes exist. This is Management Role. The only quantifiable fact here is the "25 years of experience" — that's just one QV-eligible detail, and I need at least two to classify this as QV. Since the named roles like CTO and CISO are IS facts but don't count toward QV, this lands in Firm-Specific with a score of 3.

fact: CTO

fact: CISO

fact: 25 years of experience in cybersecurity and IT Operations

fact: Information Technology, Legal, Privacy, Finance, Regulatory, Quality, and Compliance teams


reasoning: The paragraph describes internal cybersecurity processes — audits, maturity assessments, threat intelligence, vulnerability management, and IR drills — making it Risk Management Process. The WISP is a named internal program with a unique identifier (pushing beyond Sector-Adapted), while NIST CSF is a named framework. However, there are no two hard verifiable facts (no dates, dollar amounts, named firms, or named tools), so it stays at Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes internal audit reviews, third-party assessments against NIST CSF, and various security activities (threat intelligence, vulnerability management, IR drills, etc.). This is about the company's own internal processes and program components.

Category: Risk Management Process - describes internal cybersecurity processes, framework alignment, and program activities.

Specific facts:
- "WISP" - named internal program with unique identifier → IS list
- "Internal Audit department" - generic organizational unit
- "NIST Cyber Security Framework" - named framework → Sector-Adapted

- "third-party experts" / "third-party maturity assessments" - unnamed entities → NOT list
- "threat intelligence, vulnerability management, incident response drills" - common practices → NOT list

So I'm identifying WISP as a named internal program with a unique identifier that qualifies for the IS list, similar to how "Cyber Incident Response Plan (CIRP)" would be classified. That gives me one IS fact categorized as Firm-Specific. For QV purposes, there are no specific dates mentioned.

fact: WISP (Written Information Security Program) - named internal program

fact: NIST Cyber Security Framework

type: framework


reasoning: The paragraph describes what the CISO and multidisciplinary teams do operationally — implementing a program, monitoring threats, deploying teams, responding to incidents. Applying the person-vs-function test: no credentials, background, or qualifications are mentioned; replacing 'CISO' with 'the Company' leaves a coherent process description. The CISO and reporting to the board are incidental attribution, not the primary content. The CISO title is a firm-specific fact per the IS list, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present, so specificity stays at Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes what the CISO does in coordination with teams to implement a cybersecurity program. The paragraph is about the function/program - what the CISO does operationally (implement program, monitor threats, deploy teams, respond to incidents). The person-vs-function test: remove the CISO title and the paragraph still describes processes. But the CISO is mentioned multiple times as the actor, and reporting lines to audit committee/board are mentioned.

Actually, let me re-read. The CISO is the grammatical subject performing actions: implements program, monitors prevention/detection, reports to audit committee/board.

When I apply the person-vs-function test and replace "CISO" with "the Company," the paragraph still reads as a coherent process description about protecting systems and responding to incidents through multidisciplinary teams. There's nothing about credentials, background, or qualifications—just operational functions. This is clearly about the risk management process itself, not the individual. Looking at specificity, "CISO" is a cybersecurity-specific title that belongs on the list, but "audit committee" and "Board of Directors" are generic governance references that don't.

The CISO title makes this Firm-Specific, though I'm noting that named roles alone don't qualify as QV-eligible facts. The mention of "AGM Technology and ERM teams" could suggest specific team composition, but it reads more like standard organizational structure rather than a distinctive fact. I'll categorize this as Firm-Specific based on the CISO reference.

fact: CISO (cybersecurity-specific title)

fact: AGM Technology and ERM teams (named internal teams)


reasoning: The audit committee of the Board is the grammatical subject throughout, performing oversight actions: interacting with management, receiving reports and presentations on cybersecurity risks. Although AGM's CSO/CISO is mentioned, they are subordinate actors reporting TO the board committee, making this Board Governance. Specificity is Firm-Specific because it names AGM (a specific external entity) and cybersecurity-specific roles (CSO/CISO), but only one QV-eligible fact (named firm AGM) prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the audit committee of the Board of Directors overseeing cyber risks, receiving reports from management and service providers, and getting presentations from AGM's CSO or CISO. The grammatical subject is primarily the audit committee - it "interacts with," "receives reports," "receives presentations."

Content Category: Board Governance - The audit committee (board committee) is the primary actor overseeing cybersecurity risks, receiving reports and presentations.

Specific facts:
- CSO or CISO (cybersecurity-specific titles) - named_role ✓
- "at least annually" - generic cadence ✗

- AGM (Apollo Global Management) - named firm ✓
- Audit Committee - generic ✗
- "vulnerability assessments, third-party and independent reviews" - common practices ✗
- "Investment Adviser" - generic ✗

So the QV-eligible facts here are the named cybersecurity roles and the named firm AGM itself.

Looking at what qualifies for QV: specific dates, dollar amounts, headcounts, named third-party firms, named products, certifications, years of experience, and named universities. AGM as a named firm gives me one QV-eligible fact, which isn't enough to cross the threshold. The CSO/CISO titles are firm-specific but don't count toward QV eligibility since they're generic role names rather than specific identifiers.

fact: CSO or CISO (cybersecurity-specific roles at AGM)

fact: AGM (named firm — Apollo Global Management)


reasoning: The paragraph describes the company's own internal safeguards — redundant telecom, off-site backups, fire suppression, power protection, and disaster recovery planning — all of which are internal cybersecurity/IT resilience processes. No named frameworks, tools, roles, dates, or other specific facts from the IS list are present; the descriptions are generic practices applicable to any company with a data center.

thinking:
Let me analyze this paragraph.

Content: Describes internal safeguards - redundant telecom, data backups, fire suppression, power protection, disaster recovery plan, alternate processing. These are all internal processes/controls.

Category: Risk Management Process - describes the company's own internal cybersecurity/IT safeguards and disaster recovery capabilities.

Specificity: No named frameworks, no named tools/products, no specific dates, no dollar amounts, no named roles, no named firms. The practices described (redundant facilities, backups, fire suppression, disaster recovery) are common/generic. No IS-list items present.

This looks like generic boilerplate language.


reasoning: The paragraph contains an explicit materiality assessment ('have to date not materially affected... our business strategy, results of operations or financial condition'), which per Rule 6 is Strategy Integration regardless of the appended cross-reference to Risk Factors. No named frameworks, firm-specific facts, or verifiable details are present.

thinking: Materiality assessment paragraph with cross-reference.


content_category: Third-Party Risk

reasoning: The first and longer sentence describes requirements imposed on third-party service providers (security measures, breach reporting), making vendor oversight the central topic. The second sentence is a brief, generic board oversight statement subordinate to the third-party focus. No named frameworks, specific roles from the IS list, dates, or other firm-specific facts are present.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two sentences:
1. Third-party service provider evaluation
2. Board/Audit Committee oversight

Dominant category: The first sentence is about third-party risk oversight. The second sentence is about board governance. I need to determine which is dominant.

The first sentence is longer and more detailed about vendor evaluation processes. The second sentence is a brief, generic board oversight statement. By the dominant category rule, the first sentence about third-party evaluation takes more space and is more substantive.

Actually, let me reconsider. The first sentence describes requirements imposed ON vendors (verify ability, maintain security measures, report breaches). This points to Third-Party Risk per Rule 3.

The second sentence just mentions board and audit committee oversight without any specifics, so Third-Party Risk is clearly the dominant topic here. Looking at the specificity, I don't see any named frameworks, specific roles, dates, numbers, or named firms—just generic governance language like "Board of Directors" and "Audit Committee." This is Generic Boilerplate.


reasoning: The paragraph identifies the CISO, describes their 36 years of IT/security experience and 24+ years of tenure as CISO, and details a named steering group with specific departmental composition — all focused on who the people are and their qualifications. Two QV-eligible hard facts (36 years experience, 24+ years as CISO) push specificity to Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes management's involvement in cybersecurity. Mentions a cybersecurity operations risk steering group chaired by Chief Insurance Officer, includes executives from technology, security, privacy, and legal teams. Then describes the CISO's responsibility and background (36 years IT/security experience, 24+ years as company's CISO).

Category: This is about management roles and the people filling them. The steering group composition, the CISO's credentials and tenure. The person-vs-function test: the paragraph describes who chairs the committee, the CISO's experience and tenure - this is about the people. → Management Role

Now I'm checking what's verifiable here. The CISO title is cybersecurity-specific, the steering group is a named committee with specific team composition, and there are two concrete numbers: 36 years of experience and 24 years in the CISO role. Those quantified facts are independently verifiable.

fact: Chief Information Security Officer (CISO)

fact: Cybersecurity operations risk steering group chaired by Chief Insurance Officer

fact: Technology, security, privacy, and legal teams

fact: 36 years in information technology and information security

fact: Over 24 years as the Company's CISO


reasoning: The paragraph contains an explicit materiality assessment ('cybersecurity threat risks may materially affect... business strategy, results of operations or financial condition') and a statement that no material incident has occurred. Per Rule 6, the materiality conclusion makes this Strategy Integration even though a cross-reference to Risk Factors is appended. No firm-specific facts from the IS list are present — the language is standard boilerplate materiality disclaimer.

thinking:
Let me analyze this paragraph from Bitwise 10 Crypto Index ETF's 10-K filing.

The paragraph contains:
1. A materiality assessment: "neither the Sponsor nor the Trust has experienced a material cybersecurity incident" and "cybersecurity threat risks may materially affect either the Sponsor or the Trust, including the Trust's business strategy, results of operations or financial condition"
2. A cross-reference to Risk Factors

Per Rule 6 and the codebook, any paragraph with an explicit materiality assessment is Strategy Integration, even with a cross-reference appended.

Specificity: No named frameworks, no firm-specific facts from the IS list.

But looking at the language more closely, this is just standard boilerplate materiality language that appears across many filings.


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected us, including our business strategy, results of operations or financial condition'), which per Rule 6 makes this Strategy Integration regardless of the appended cross-reference to Risk Factors. No named frameworks, cybersecurity-specific roles, dates, or other specific facts are present — the language is boilerplate materiality disclaimer.

thinking:
Let me analyze this paragraph.

Content: Contains a materiality assessment ("have not materially affected us, including our business strategy, results of operations or financial condition"), mentions past threats/breaches, and cross-references to Risk Factors.

Category: The paragraph makes an explicit materiality assessment - this is Strategy Integration per Rule 6. The cross-reference doesn't change that.

Specificity: Let me check for facts. No specific dates, no dollar amounts, no named firms, no named tools, no cybersecurity-specific roles, no named frameworks. The materiality language is boilerplate.

This is just generic boilerplate language without any substantive detail.


reasoning: The paragraph's central topic is oversight of external parties — partnering with cybersecurity vendors, managing risks that third-party suppliers pose to the company, assessing their practices, and imposing contractual security requirements. While the early sentences describe using external cybersecurity partners (which could lean RMP), the dominant frame is third-party risk governance. No named firms, tools, frameworks, dates, or other specific facts appear; all language is generic (unnamed vendors, 'from time to time,' 'outsourced security operations center').

thinking:
Let me analyze this paragraph from Organogenesis Holdings Inc.'s 10-K filing, Item 1C.

Content Category: This paragraph is primarily about third-party service providers and vendor risk management. It discusses partnering with cybersecurity companies, engaging vendors to monitor the environment, and processes for overseeing third-party risks including assessing practices and requiring controls. The central topic is oversight of external parties. → Third-Party Risk

However, there's a mix - the first part describes using third-party cybersecurity partners as part of their own infrastructure (which could be Risk Management Process), and the second part is about managing risks from third parties. Let me re-read...

Actually, looking more carefully at the structure: the opening discusses their use of external cybersecurity services like outsourced SOC and pen testing, which are tools supporting their own risk management. But the bulk of the paragraph focuses on how they oversee and manage risks posed by their own vendors and suppliers—assessing their practices, requiring contractual controls, and monitoring their cyber posture. That's clearly Third-Party Risk management.

On specificity, I'm checking for concrete details: the services mentioned are generic descriptions without named providers, the practices are standard industry approaches without specific frameworks or dates, and there are no named tools, metrics, or standards cited. This is boilerplate language about vendor oversight processes.


reasoning: The paragraph is primarily about the CTO as a person — their reporting line to the Risk Committee, their degree, and their 25 years of experience. While the first sentence touches on what the team does, the dominant content is the CTO's qualifications and background, making this Management Role per the person-vs-function test. Two QV-eligible hard facts: named university (University of Virginia) and specific years of experience (25 years).

thinking:
Let me analyze this paragraph carefully.

The paragraph has two sentences:
1. First sentence: CTO updates Risk Committee and oversees a team - this describes both reporting (to Risk Committee) and what the team does (enterprise-wide cybersecurity strategy, policies, etc.)
2. Second sentence: CTO's credentials - BS in Computer Engineering from University of Virginia, 25 years of experience

Person-vs-function test: The paragraph is primarily about the CTO as a person - their reporting line, their credentials, their background. The first sentence mentions what the team does but it's framed as what the CTO oversees. The second sentence is entirely about the person's qualifications.

Removing the person's identity leaves the first sentence partially intact but the second sentence completely falls apart - it's entirely about who this person is and their qualifications. So this is clearly a person-focused paragraph.

Looking at the specificity: CTO is a cybersecurity-specific title, Risk Committee is a named committee, University of Virginia is a named institution in a credentials context, and 25 years is a concrete number. These are all factual details that qualify for inclusion.

Since there are two QV-eligible facts here - the named university and the specific years of experience - this meets the threshold for a Quantified-Verifiable classification.

fact: Risk Committee

fact: Bachelor of Science in Computer Engineering from the University of Virginia

fact: 25 years of experience


reasoning: The paragraph describes the company's internal processes for evaluating cybersecurity risks, detecting vulnerabilities, and maintaining notification policies. The CISO is mentioned as a collaborator in these processes, not as the subject of credential/background disclosure, so this is about the function (Risk Management Process) not the person. The CISO title and the specific team composition (risk management team + CISO + Head of Legal) qualify as firm-specific facts, but there are no QV-eligible hard facts (no dates, amounts, named firms, or named tools).

thinking:
Let me analyze this paragraph.

Content: Describes the risk management team collaborating with CISO and Head of Legal, processes to detect vulnerabilities, policies for notification.

Category: This is about internal processes - risk assessment, vulnerability detection, policies. The CISO is mentioned but as part of the team composition, not about the person's credentials. The paragraph is about what the company does (processes, safeguards, policies) → Risk Management Process.

Specificity:
- "CISO" - cybersecurity-specific title → IS list item → Firm-Specific

- "Head of Legal" - general corporate role, not cybersecurity-specific
- The team composition itself references specific departments within the organization
- No named frameworks, dates, dollar amounts, or external tools mentioned

QV check: CISO is a named role but doesn't qualify for QV. No other quantifiable facts present. Not QV.
IS check: CISO appears on the Firm-Specific list.

Specificity: Firm-Specific (3)

fact: Team composition: risk management team, CISO, Head of Legal


reasoning: The Board and Audit Committee are the grammatical subjects performing oversight actions (monitors, delegated, are informed), making this clearly Board Governance. No specific facts from the IS list are present: 'Audit Committee' is generic governance, 'Chief Operating Officer' is generic C-suite (COO is on the NOT list), 'periodic reports' is a generic cadence, and 'GECM' is a company self-reference. No named frameworks, cybersecurity-specific roles, dates, or verifiable facts appear.

thinking:
Let me analyze this paragraph.

Content: Board monitors cybersecurity risk, delegated to Audit Committee, informed through periodic reports from GECM's COO. Reports include updates on cybersecurity program, threats, preparedness.

Category: The board and Audit Committee are the primary subjects - they monitor, delegate, are informed. This is Board Governance.

Specificity: Let me check facts:
- "Audit Committee" - NOT list (generic governance)
- "Chief Operating Officer" - NOT list (generic C-suite: COO)
- "GECM" - company reference, NOT list
- "periodic reports" - generic cadence

- No named frameworks, no cybersecurity-specific roles, no specific dates, no named tools or firms, no named standards

This is clearly generic boilerplate - the COO is just a standard C-suite role, the Audit Committee is a standard governance structure, and there's nothing specific enough to indicate real implementation details.


reasoning: The paragraph identifies who leads cybersecurity risk management (VP of Informatics), their experience (20+ years), and the composition of their department. While the opening clause references 'risk assessment and management processes,' the substantive content is about the person — their title, experience level, and organizational scope. Applying the person-vs-function test: removing the VP's title, experience, and department description leaves only a generic statement about processes being maintained by 'executive leadership.' Specificity is Firm-Specific: the VP of Informatics title is a cybersecurity-specific role (IS list), and 20+ years of experience is a specific number, but only one QV-eligible hard fact (years of experience), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph mentions "Vice President of Informatics" leading cybersecurity risk assessment and management processes, with "more than 20 years of experience" and describes what the Informatics department includes.

Person-vs-function test: The paragraph starts with "cybersecurity risk assessment and management processes are implemented and maintained by..." - so it's about processes, but then pivots to describing WHO leads them - the VP of Informatics, their experience, and what they oversee.

The primary content is about the person: their title, experience level, and departmental scope. The processes are mentioned as context for the role.

Looking at the full sentence structure, it's grammatically centered on the processes but substantively focused on the person leading them. The VP's qualifications and departmental oversight are the real meat of what's being communicated, while the processes themselves remain undefined and generic. remove the VP title, experience, and department description, what's left? "Our cybersecurity risk assessment and management processes are implemented and maintained by our executive leadership team." That's very thin - generic statement.

The paragraph's primary communicative purpose is to identify WHO manages cyber risk and their qualifications. → Management Role.

Specific facts:
- "Vice President of Informatics" - this is a cybersecurity-specific title (VP of IT/Security equivalent) → named_role
- "more than 20 years of experience" → quantified (years of experience as specific number)
- Department composition: "hardware, software, help desk, and cybersecurity team" → named_team

QV check: "more than 20 years" is a specific number that qualifies as a QV-eligible fact. Named role and department composition don't count toward QV. That's only one QV fact, so I need two for QV classification - this lands as Firm-Specific instead.

fact: Vice President of Informatics

fact: more than 20 years of experience in information technology

fact: Informatics department includes hardware, software, help desk, and cybersecurity team


reasoning: The paragraph centers on the Committee's oversight activities — receiving quarterly CTO briefings, reporting to the full Board, and receiving cybersecurity presentations. The board committee is the primary actor/recipient throughout, making this Board Governance. The CTO is a cybersecurity-specific title on the IS list, yielding one firm-specific fact, but no second QV-eligible hard fact exists (cadences like 'quarterly' and unnamed entities like 'external experts' are on the NOT list).

thinking:
Let me analyze this paragraph.

The paragraph describes the Committee receiving reports from the CTO, and the Committee reporting to the Board. The grammatical subject alternates between the CTO and the Committee, but the overall frame is about the Committee's oversight activities - receiving briefings, reporting to the Board, receiving presentations.

Category: Board Governance - The Committee (a board committee) is the primary entity being described in terms of its oversight role. The CTO reports TO the committee, the committee reports to the board, committee members receive presentations.

Specific facts:
- CTO (Chief Technology Officer) - this is a cybersecurity-specific title per the IS list

- The other details like quarterly cadence, generic committee references, and unnamed staff are too vague to count as firm-specific facts.

So I have one QV-eligible fact here, which means this is Firm-Specific (3).

fact: Chief Technology Officer (CTO) reports to the Committee


reasoning: The Board is the grammatical subject throughout — it oversees ERM, delegates cyber oversight to the Audit Committee, and receives briefings. The CTO mention is subordinate to the board's oversight framing. The CTO (a cybersecurity-specific title per the IS list) is the one firm-specific fact; Audit Committee is generic, 'periodic briefings' is a generic cadence, and 'third-party experts' are unnamed.

thinking:
Let me analyze this paragraph.

Content: Board oversees ERM, delegated cyber oversight to Audit Committee, Board receives briefings from management including CTO, information security team, and third-party experts.

Category: Board Governance - the Board is the grammatical subject throughout, describing board/committee oversight of cyber risk.

Specificity: Let me check facts:
- "Audit Committee" - NOT list (generic governance)
- "CTO" - this is on the IS list as a cybersecurity-specific title
- "information security team" - generic team reference

- "third-party experts" - NOT list (unnamed entities)
- "periodic briefings" - NOT list (generic cadence)

So CTO is one specific fact → Firm-Specific (3). No QV-eligible facts since CTO is a named role, not QV-eligible. Only one IS fact.

fact: CTO provides presentations on cybersecurity topics


reasoning: The paragraph contains an explicit materiality assessment ('not experienced a cybersecurity threat or incident that materially affected its business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. The cross-reference and forward-looking caveat are secondary. No firm-specific facts, named frameworks, or verifiable details appear—the risk factor titles are generic descriptions, not specific facts from the IS list.

thinking:
Materiality assessment + cross-reference. The paragraph explicitly states cybersecurity threats have not "materially affected its business strategy, results of operations or financial condition" — this is a materiality assessment, making it Strategy Integration per Rule 6. The cross-reference doesn't change that.

Specificity: No named standards, no firm-specific facts from the IS list. Generic boilerplate materiality language.


reasoning: The paragraph is about the people responsible for cybersecurity: the SVP of Finance and Accounting's operational background and the senior IT consultant's 20+ years of experience and career history at Fortune 500 companies. The person-vs-function test confirms Management Role — remove the individuals' credentials and backgrounds and virtually no content remains. Specificity is Firm-Specific: 'over 20 years of experience' is one quantified fact (IS list), but there is only one QV-eligible hard fact (the titles are finance/generic IT, not cybersecurity-specific per the IS list, and 'Fortune 500 companies' are unnamed), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a dedicated team of internal/external IT professionals, reports to SVP of Finance and Accounting, describes that person's background, then describes a senior IT consultant's experience (20 years, Fortune 500 companies, life sciences).

Category: This is about the people - their qualifications, experience, backgrounds. The person-vs-function test: the paragraph names specific roles (SVP finance and accounting, senior IT consultant) and describes their backgrounds and qualifications. This is Management Role.

Specificity: Let me check facts:
- "senior vice president, finance and accounting" - this is not a cybersecurity-specific title (it's finance/accounting).

Not on the IS list. "Senior IT consultant" is borderline—it's IT-related but not explicitly cybersecurity-focused like the titles on the IS list (VP of IT/Security, Information Security Officer, Director of IT Security), though the context mentions IT and cybersecurity risk management experience. The "over 20 years" is a specific, quantifiable detail, but "Fortune 500 companies" and "life sciences industry" lack the specificity needed for qualification verification.

Looking at the team composition more carefully: "senior vice president, finance and accounting" is clearly a finance role, not cybersecurity-specific. "Senior IT consultant" remains generic IT without explicit cybersecurity credentials per the IS list. The only QV-eligible fact I can identify is the specific number of years of experience—that's just one qualifying element, which isn't enough for QV status. Specific numbers: headcounts, dollar amounts, percentages, exact durations"). So that's one IS fact → Firm-Specific.

Actually, wait. Let me reconsider the titles. The IS list says "VP of IT/Security" qualifies. "Senior vice president, finance and accounting" is NOT IT/Security. "Senior IT consultant" - this could be considered similar to IT leadership but it's not on the explicit list. The NOT list says "Generic IT leadership (NOT cybersecurity-specific): 'Head of IT', 'IT Manager', 'Director of IT'" - "senior IT consultant" seems to fall in this category.

So specific facts:
- "over 20 years of experience" (quantified) - IS fact
- "Fortune 500 companies" - not named firms, generic
- "life sciences industry" - not specific

One IS fact → Firm-Specific. Now looking at the category: this paragraph focuses on the people themselves—their qualifications, backgrounds, and experience levels—which fits the Management Role category based on the person-versus-function test.

fact: Senior IT consultant has over 20 years of experience


reasoning: The paragraph's central topic is identifying cybersecurity risks from third parties — vendors, service providers, and external users — making Third-Party Risk the dominant category. It contains no named frameworks, standards, specific roles, dates, or any firm-specific details; the language is entirely generic and could apply to any company.

thinking:
Classify this paragraph.

The paragraph discusses third-party risk - vendors, service providers, external users, and third-party systems. The central topic is oversight of external parties' cybersecurity risk.

No named frameworks, no specific facts, no named roles. Generic language throughout.

Content category: Third-Party Risk (vendor oversight is the central topic)
Specificity: Generic Boilerplate (no named standards, no firm-specific facts)


reasoning: Although the paragraph opens with 'risk assessment and management processes,' the substantive content is about the people — the VP of IT's 25 years of experience, DoD Research background, reporting line to the CFO, and the CFO's 23 years of experience. Applying the person-vs-function test, if you remove the people's credentials, almost nothing remains. Multiple QV-eligible hard facts: specific years of experience (25, 23) and a named organization (Department of Defense Research).

thinking:
Let me analyze this paragraph carefully.

The paragraph talks about "cybersecurity risk assessment and management processes" but then focuses on the VP of IT's qualifications and reporting structure.

Person-vs-function test: The paragraph mentions "risk assessment and management processes" but the bulk of the content is about WHO implements them - the VP of IT, their experience (25 years, DoD Research), reporting line (to CFO), and the CFO's experience (23 years). The substantive content is about the people, not the processes.

Category: Management Role

Specific facts:
- VP of IT (cybersecurity-specific? Let me check... "VP of IT/Security" is on the IS list.

Now I'm checking whether "VP of IT" qualifies - the IS list explicitly includes "VP of IT/Security" so this role counts, and I can note the 25 years of IT experience and the DoD Research background as specific, quantifiable qualifications. The CFO connection is also relevant here. I'm seeing that the Department of Defense Research counts as a named organization, and combined with the specific years of experience mentioned, there are multiple quantified-verifiable facts here—so this qualifies as Quantified-Verifiable overall.

fact: VP of IT

fact: over 25 years of experience in information technology

fact: IT leadership in Department of Defense Research

fact: 23 years of experience as a CFO with supervisory responsibility over IT and cybersecurity


reasoning: The paragraph primarily describes the qualifications and credentials of the CSO and the Information Security team — who they are and what makes them qualified — satisfying the person-vs-function test for Management Role. The ERM Committee mention is introductory context, while the bulk of the paragraph details personnel credentials. Multiple named certifications (CISSP, CISA, CISM, CEH, CompTIA Security+, CySA+, CASP+, PenTest+) provide well over two QV-eligible hard verifiable facts.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Enterprise Risk Management Committee (board-level) oversight of cybersecurity
2. Directors' experience
3. Chief Security Officer's responsibilities and qualifications
4. Information Security team certifications

Let me determine the dominant category. The paragraph mentions:
- Board-level committee (Enterprise Risk Management Committee)
- Directors' experience
- CSO responsibilities and qualifications
- Team certifications

The bulk of the paragraph is about the people - the CSO's qualifications and the team's certifications. The ERM Committee mention is brief. The primary content is about management personnel qualifications.

Applying the person-versus-function test, this is clearly about WHO these people are based on their experience, education, and certifications rather than WHAT processes they manage, so this falls under Management Role. Looking at the specific facts, the Enterprise Risk Management Committee is a named committee on the IS list, the Chief Security Officer is a cybersecurity-specific role, and the paragraph lists multiple named certifications like CISSP, CISA, CISM, CEH, and others that are all QV-eligible facts.

Since there are clearly more than two named certifications held by team members, this qualifies as Quantified-Verifiable.

fact: Chief Security Officer

fact: CISSP certification

fact: CISA certification

fact: CISM certification

fact: CEH certification

fact: CompTIA Security+

fact: CompTIA CySA+

fact: CompTIA CASP+

fact: CompTIA PenTest+


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident: the CrowdStrike-caused outage on July 19, 2024, including detection, response actions, and recovery timeline. It contains multiple hard verifiable facts — a specific date (July 19, 2024), a named third-party firm (CrowdStrike), and quantified recovery timelines (24 hours, three calendar days) — meeting the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a specific incident (CrowdStrike outage on July 19, 2024), what happened, response actions, and recovery timeline.

Category: Incident Disclosure - describes what happened, when, scope, response actions.

Specific facts:
- July 19, 2024 (specific date)
- CrowdStrike (named firm)
- "within 24 hours" (specific duration)
- "fewer than three calendar days" (specific duration)

QV check: specific date + named firm = 2 hard verifiable facts → Quantified-Verifiable

fact: CrowdStrike

fact: within 24 hours for majority of client facing systems

fact: fewer than three calendar days for full restoration


reasoning: The paragraph is about the CISO as a person — their reporting line (CISO → CIO → Executive Chairman/CEO), years of experience, and team qualifications. This passes the person-vs-function test: the content is about who the person is and their credentials, not about what the program does. Two hard verifiable facts (40 years IT experience + 20+ years in IT security) meet the QV threshold.

thinking:
Let me analyze this paragraph.

Content: About the CISO's reporting lines, experience, and team qualifications. This is about the person/people - their experience, credentials, reporting structure.

Category: Management Role - the paragraph is about the CISO (person), their reporting line, their experience (40 years IT, 20+ in security), and team qualifications.

Specific facts:
- CISO (cybersecurity-specific role) ✓
- CIO (cybersecurity-specific role) ✓

- 40 years of IT experience (specific number) ✓
- over 20 years focused on IT security (specific number) ✓

These are concrete, quantified facts that can be verified, so this qualifies as Quantified-Verifiable.

fact: CISO

fact: CIO

fact: 40 years of IT experience

fact: over 20 years focused on IT security


reasoning: The paragraph's primary frame is governance oversight: sentences 1-2 establish the Audit Committee and Board as overseers of cybersecurity risk with annual briefings, and sentence 3 describes the CIO reporting TO the Audit Committee (board receiving information). Only the final sentence is purely about the CIO's credentials. Board/committee oversight is the dominant communicative purpose. Specificity is Firm-Specific: CIO is a cybersecurity-specific title (IS list), and '20 years' is one QV-eligible fact, but only one hard verifiable fact prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Executive team + Audit Committee assess/manage cyber risk as part of business strategy
2. Audit Committee and Board briefed on cyber risks annually
3. CIO reports to Audit Committee - describes what the report covers
4. CIO's background - 20 years experience

Let me determine the dominant category. The paragraph has:
- Board governance elements (Audit Committee oversight, briefing cadence)
- Management Role elements (CIO reporting, CIO background)
- Strategy Integration elements (business strategy, financial planning, capital allocation)

The grammatical subjects shift: "executive team along with Audit Committee" → "Audit Committee and Board" → "CIO" → "CIO"

The paragraph starts with board and executive oversight, then pivots to focus on the CIO's reporting responsibilities and qualifications, making this a dual-category case that blends governance structure with management role definition. Looking at how the sentences break down by category, the first two clearly establish board governance as the frame, sentence three describes reporting relationships to the committee, and only the final sentence about the CIO's credentials is purely about management role. So board governance is the dominant theme here, even though there's some management role content mixed in. Now I'm evaluating the specificity of what's actually stated about the CIO's background and responsibilities. I'm realizing I need to double-check my classification—the "over 20 years" detail is the only QV-eligible fact here, which means this should land at Firm-Specific level despite having that one qualifying element.

fact: Chief Information Officer (CIO) — cybersecurity-specific title

fact: over 20 years of experience in senior IT/information security roles


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected us... including our business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. The generic threat acknowledgment and cross-reference are noise. No named entities, dates, dollar amounts, frameworks, or firm-specific facts are present — boilerplate materiality language usable by any company.

thinking: Materiality assessment + cross-reference. Per Rule 6 and the codebook examples, this is Strategy Integration.


reasoning: Although the paragraph opens with a Board oversight sentence and mentions the CISO's 15 years of experience, the dominant content describes what the IS Program does — preventing, detecting, and responding to incidents — along with the incident response team's role and the detailed incident response plan. Applying the person-vs-function test, removing the CISO's title and experience leaves a coherent process description, making Risk Management Process the dominant category. Specificity is Firm-Specific: CISO title and 15 years of experience are specific facts, but only one QV-eligible hard fact (years of experience), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Board approval/oversight of IS Program (Board Governance)
2. CISO designation, experience (Management Role)
3. What the IS Program does - preventing, detecting, responding (Risk Management Process)
4. Information Security Incident Response Team (Risk Management Process)
5. Incident response plan details (Risk Management Process)

The opening sentence mentions the Board, but the rest is about the CISO and the program's processes. The dominant content is Risk Management Process - what the program does, incident response team, incident response plan steps.

But let me apply the person-vs-function test: The CISO is mentioned with "over 15 years of relevant experience" - that's about the person.

Looking at the rest of the paragraph, there's definitely a mix. The Board sentence is brief, the CISO gets credentials but then the focus shifts to what the IS Program actually does under that leadership. The majority of the text describes the processes - the incident response team, the incident response plan, and how the program prevents, detects, and responds to incidents. Risk Management Process is clearly dominant here.

For the specific facts, I'm identifying the CISO as a named role, the "over 15 years of relevant experience" as a quantified credential, and the "Information Security Incident Response Team" and "IS Program Coordinator" as named internal designations. The "Information Security Program" itself with its abbreviation counts as a named internal program with a unique identifier.

Now checking what's QV-eligible: "over 15 years" qualifies as a specific number of years of experience, while the CISO title and internal program names don't. That gives me just one QV-eligible fact, which puts this at Firm-Specific level 3.

fact: CISO designated as IS Program Coordinator

fact: over 15 years of relevant information technology, security and program management experience

fact: Information Security ('IS') Program — named program with unique abbreviation


reasoning: The paragraph's primary communicative purpose is describing how the company manages cybersecurity risk — primarily through unnamed third-party consulting firms and by selecting reputable service providers. Per Rule 3, external parties hired to serve the company's risk management function are Risk Management Process. The closing materiality disclaimer is subordinate to the two preceding sentences about the company's risk management approach. No named frameworks, roles, firms, dates, or other specific facts appear — everything is generic and could apply to any small company.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three distinct parts:
1. Management works with third parties to identify/assess/manage cyber risks
2. Company uses third-party service providers and seeks reliable ones
3. Materiality disclaimer

Let me determine the dominant category. The first two sentences are about third-party reliance and vendor selection. The third sentence is a materiality disclaimer.

By Rule 6, materiality disclaimers → Strategy Integration. But is that the dominant content? Two sentences about third-party risk management, one sentence about materiality. The third-party content is more about how the company manages risk through third parties rather than imposing requirements ON vendors. Actually, sentence 1 is about using third parties to help manage risk (Risk Management Process - external assessors serving the company).

Sentence 2 is about vendor selection (Third-Party Risk). Sentence 3 is materiality (Strategy Integration). This is a mixed paragraph with the materiality statement as a full sentence, but the first two sentences describe how the company relies on third parties for cybersecurity management and vendor oversight. The materiality disclaimer is significant but represents only one of three sentences, so the dominant theme is the company's reliance on external parties for risk management and vendor selection. The core issue is whether this paragraph is fundamentally about Third-Party Risk or Strategy Integration. The first two sentences clearly focus on how the company relies on and manages third parties for cybersecurity, while the materiality statement is just boilerplate closure. Given that vendor oversight dominates the actual content, I'm settling on Third-Party Risk as the primary category. The core issue is whether this is fundamentally about the company's risk management process or about third-party risk management. The paragraph describes how the company manages cybersecurity—primarily through outsourcing to third parties—and then notes no material impact. Since the third parties are functioning as the company's risk management mechanism rather than being evaluated as vendors, I think Risk Management Process is the right classification here, with the materiality statement as supporting context rather than the dominant focus. Third-Party Risk makes the most sense as the dominant category—the paragraph keeps circling back to the company's reliance on third parties for cybersecurity functions, whether that's consultants helping with risk assessment or operational vendors maintaining their own security programs. The materiality statement at the end is just the required disclosure, not the main point.

Looking at the specificity now: everything here is generic—unnamed consulting firms, unspecified service providers, no frameworks mentioned, no dates or numbers. The only concrete element is the materiality disclaimer, which by the rules points to Strategy Integration. So this lands as Generic Boilerplate with a Strategy Integration tiebreaker.

Actually, wait—the materiality statement isn't standalone here; it's embedded in a paragraph about third-party risk management. The paragraph's main purpose is explaining *how* the company manages cyber risk through vendors, so Risk Management Process should dominate. The materiality comment is just a closing qualifier, not the primary message.

I'm going with Risk Management Process as the category. The paragraph fundamentally describes the company's approach to managing cybersecurity risk through third parties, and that's what drives the content. Specificity is Generic Boilerplate—nothing specific enough to qualify.


reasoning: The paragraph's primary content is the management committee structure responsible for cybersecurity: the Information Technology Steering Committee's composition (CIO, CTO, ISO), its charter, and its reporting line to the board. While the board is mentioned as approving the committee and receiving reports, the grammatical subjects throughout are the committee and the Information Security Officer — this is about management-level organizational structure and reporting lines, fitting Management Role's coverage of 'management committees responsible for cybersecurity.' Multiple cybersecurity-specific titles and a named non-generic committee qualify as firm-specific facts, but none are QV-eligible (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the Information Technology Steering Committee - its approval by the board, its composition, its meeting cadence, and its reporting to the board.

Content Category: This is about a management committee structure. The board approved it, but the paragraph's primary content is about the committee itself - who chairs it, who's on it, what it does, how often it meets, and how it reports back. The grammatical subjects are mostly "this committee" and "the Information Security Officer."

The board is mentioned as approving the committee and receiving reports, but the bulk is about the committee's structure and function. This feels like Management Role - it's about the management committee structure, composition, and reporting lines.

I'm second-guessing myself here. Looking at what's actually dominant in the text - the committee's structure, who sits on it, what responsibilities it holds, and how it reports - this is clearly about the management committee itself rather than broader governance or risk processes. The CIO, CTO, and ISO are the key players, and their roles within this committee structure are what's being defined.

For the specificity check, I have the named committee and the cybersecurity-specific titles, but the quarterly cadence is too generic to count. And for the QV threshold, named roles and committee names alone don't give me the two hard verifiable facts I'd need - I'm missing concrete details about what they actually do or decide.

fact: Chief Information Officer

fact: Chief Technology Officer

fact: Information Security Officer


reasoning: The first sentence attributes the program to the SVP of IT and notes their experience, but the vast majority of the paragraph describes what the team does: preventing/detecting/mitigating risks, analyzing threat intelligence, reviewing alerts from security tools, and reporting to senior management. Applying the person-vs-function test, removing the SVP's title and experience leaves a fully coherent process description — the paragraph is about the function, not the person. Specificity is Firm-Specific: the SVP of IT role (analogous to 'VP of IT/Security' on the IS list) and '20 years of experience' are firm-specific facts, but only one QV-eligible fact (the 20 years figure) prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes the SVP of IT's experience and team, then extensively describes what the team does (prevent, detect, mitigate, remediate, supervise internal/external personnel, threat intelligence, security tools, reporting).

Person-vs-function test: The first sentence mentions the SVP's experience (20 years) and role. But the bulk of the paragraph is about what the team does - processes, activities, responsibilities. If I removed the SVP title and experience, the paragraph still describes the team's functions. The dominant content is about the function/process, not the person.

Now I'm checking the title specificity. "Senior Vice President of Information Technology" is close to the IS list's "VP of IT/Security," though it's not explicitly cybersecurity-focused. The NOT list flags generic IT leadership titles like "Head of IT" and "IT Manager," but SVP of IT seems specific enough to count as cybersecurity-related leadership.

For the QV check, I have "over 20 years" as one quantifiable fact, but I need two for QV eligibility. The SVP role itself is firm-specific but doesn't count as a quantifiable fact. With only one QV-eligible element, this falls into Firm-Specific rather than QV.

fact: over 20 years of experience in the information technology sector


reasoning: The paragraph describes how the company identifies, assesses, and evaluates cybersecurity risks through senior management — this is a risk assessment process description, not about the people's qualifications (Management Role) or board oversight. No named frameworks, cybersecurity-specific titles, dates, or firm-specific facts are present; 'senior management' is generic per the NOT list.

thinking:
Classify this paragraph.

Content: Senior management identifies, assesses, evaluates risks including cybersecurity. They consider severity and likelihood based on knowledge and experience.

Category: This is about risk assessment methodology performed by management. The person-vs-function test: it's about what management does (identifies, assesses, evaluates risks), not about who the people are. No credentials, no named roles beyond generic "senior management." This is Risk Management Process.

Specificity: No named frameworks, no specific facts from the IS list. "Senior management" is generic. No dates, no tools, no named roles (CISO etc.).

So this falls into generic boilerplate—it's describing standard risk management activities without any distinguishing details or specificity.


reasoning: The paragraph names a Director of IT as attribution but then describes what the cybersecurity program does — monitoring, threat intelligence, scans, tools. Applying the person-vs-function test, the substantive content is about processes, not the person's qualifications or background. 'Director of Information Technology' is a generic IT title (not cybersecurity-specific per the IS list), 'managed information technology service provider' is unnamed, and all practices described are generic, yielding no specific facts.

thinking:
Let me analyze this paragraph.

The paragraph describes who leads cybersecurity risk management (Director of IT) and then extensively describes what the program does - monitoring, evaluating, using tools, subscribing to reports, analyzing threat intelligence, conducting scans, etc.

Person-vs-function test: Remove "Our Director of Information Technology" and the paragraph still describes processes. The bulk is about what the group does, not about the person's qualifications/credentials/background.

However, the Director of IT is the grammatical subject leading the processes. But the content is overwhelmingly about the processes themselves. Per the person-vs-function test, this is Risk Management Process.

Now I'm checking the title itself - "Director of Information Technology" is actually a generic IT leadership role, not a cybersecurity-specific position. The exclusion list specifically flags titles like this as non-cybersecurity roles. Beyond that, there are no named frameworks, no specific vendor names, and no firm-specific details - just generic references to tools, reports, and services. This reads as boilerplate language without substantive specificity.


reasoning: The paragraph contains an explicit materiality assessment ('does not believe that it has experienced any cybersecurity threats or incidents that have materially affected or are reasonably likely to materially affect the Company and its business strategy, results of operations and/or financial condition'), which per Rule 6 triggers Strategy Integration. The remaining text is generic risk language about potential business disruptions. No named frameworks, roles, dates, or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: Contains a materiality assessment ("does not believe that it has experienced any cybersecurity threats or incidents that have materially affected or are reasonably likely to materially affect the Company and its business strategy, results of operations and/or financial condition"). Then generic risk language about potential impacts.

Category: The materiality assessment is the substantive content → Strategy Integration per Rule 6.

Specificity: No named frameworks, no specific facts from the IS list, no dates, no names. Pure boilerplate materiality language. → Generic Boilerplate.


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected us... business strategy, results of operations or financial condition'), which per Rule 6 is Strategy Integration regardless of the appended cross-reference to Risk Factors. The enumerated risk types (phishing, ransomware, etc.) are generic examples, and the cross-reference is noise. No firm-specific facts appear — the risk types listed are common practices/boilerplate, not specific to this company.

thinking: Materiality assessment with cross-reference.


reasoning: The paragraph makes an explicit materiality assessment ('have the potential to materially affect the Company's business, financial condition and results of operation'), which per Rule 6 is Strategy Integration even though it includes a cross-reference to Risk Factors. The remaining content is generic language about evolving threats and no guarantee of protection. No named frameworks, roles, dates, or other specific facts appear.

thinking:
Let me analyze this paragraph.

Content: This paragraph discusses material effects of cybersecurity threats. It contains a materiality assessment ("have the potential to materially affect"), some generic language about strengthening framework and evolving threats, and a cross-reference to Risk Factors.

Category: This contains a materiality assessment - "Cybersecurity risks have the potential to materially affect the Company's business, financial condition and results of operation." Per Rule 6, materiality disclaimers → Strategy Integration. The cross-reference doesn't change this.

Specificity: No named frameworks, no specific facts from the IS list, no dates, no numbers.

The language is boilerplate throughout, lacking any concrete details or substantive commitments.


reasoning: The Board of Directors and Audit Committee are the grammatical subjects performing oversight of cybersecurity risks and receiving updates, making this Board Governance. 'Senior Director of Information Technology' is a generic IT title (per the NOT list: 'Director of IT'), 'Chief Financial Officer' is generic C-suite, 'Audit Committee' is standard governance, and 'periodic updates' is a vague cadence — no specific facts survive the validation filter.

thinking:
Let me analyze this paragraph.

The paragraph is about the Board of Directors and Audit Committee overseeing cybersecurity risks. The board/committee is the grammatical subject. This is Board Governance.

Now for specificity:

Specific facts check:
- "Senior Director of Information Technology" - this is a cybersecurity-adjacent title. Let me check the IS list... "VP of IT/Security, Information Security Officer, Director of IT Security" are listed. "Senior Director of Information Technology" is close to "Director of IT Security" but it's more of a general IT title. Actually, looking at the NOT list: "Head of IT", "IT Manager", "Director of IT" are listed as NOT specific.

The "Senior Director of Information Technology" is generic IT leadership rather than cybersecurity-specific, so it doesn't meet the criteria. The CFO, Board of Directors, and Audit Committee are all on the NOT list, and "periodic updates" is too vague. There are no named frameworks, specific dates, or firm-specific details that would qualify this as having specificity.


reasoning: The paragraph describes the company's internal information security processes for identifying, assessing, and managing cybersecurity risks to its systems and data. This is squarely Risk Management Process. No named frameworks, specific roles, dates, tools, or other firm-specific facts are present — the language is generic and could apply to any retailer.

thinking:
Classify this paragraph.

Content: Describes the company's information security processes designed to identify, assess, and manage cybersecurity risks. This is about internal processes - Risk Management Process.

No named frameworks, no specific roles, no dates, no named tools. Everything is generic language.

Specificity: Generic Boilerplate - no named standards, no firm-specific facts. "outfitters" is just what they call employees, not a specific fact per the IS list.


reasoning: The paragraph primarily describes Fortress's internal cybersecurity processes — third-party assessments of its own systems, annual penetration testing, and vulnerability remediation — with vendor assessment mentioned as one component in the final sentence. Per Rule 3, external assessors hired to test the company are Risk Management Process, and third parties mentioned as one component of an internal program remain RMP. No named frameworks, firms, tools, dates, or specific numbers appear; 'industry frameworks,' 'third parties,' 'annual,' and 'IT Management' are all on the NOT list.

thinking:
Let me analyze this paragraph.

Content: Describes third-party assessments of cybersecurity processes, penetration testing, vendor assessment. The paragraph covers both internal processes (using third parties to assess their own security) and vendor oversight.

Category: The paragraph describes multiple things:
1. Third-party assessment of Fortress's own cybersecurity (Risk Management Process - external assessors serving the company)
2. Annual penetration testing (Risk Management Process)
3. Vendor cybersecurity assessment when vendors access sensitive data (Third-Party Risk)

Per Rule 3: "External assessor hired to test the company → Risk Management Process" and "Third parties mentioned as ONE component of internal program → Risk Management Process." The first three sentences are about using third parties to assess Fortress's own security - that's RMP.

The last sentence focuses on vendor assessment, but since the bulk of the content centers on the company's internal security processes, this falls under Risk Management Process overall. The specifics are fairly generic too - no named frameworks, tools, or firms mentioned, just standard practices like annual penetration testing and infrastructure team references. This reads as a general description of their security oversight approach rather than detailed policy documentation.


reasoning: While the paragraph opens with a brief mention of Board oversight, the dominant content describes the company's internal cybersecurity program — policies, standards, processes, framework alignment (NIST, ISO), and its cross-functional approach to risk management. The Board mention is subordinate framing. Named frameworks (NIST, ISO) elevate beyond Generic Boilerplate, but no firm-specific facts (no cybersecurity-specific roles, no dates, no named tools/firms) keep it at Sector-Adapted.

thinking:
Let me analyze this paragraph.

Content: Board oversight mentioned briefly, then shifts to describing the company's risk management program, frameworks (NIST, ISO), and approach to cybersecurity.

Category: The paragraph starts with board involvement but quickly moves to describing the company's internal processes - policies, standards, frameworks, cross-functional approach. The dominant content is about the risk management process. → Risk Management Process

Specificity: Names NIST and ISO frameworks → Sector-Adapted. Any firm-specific facts? "Board" is generic, "cross-functional approach" is generic. No cybersecurity-specific roles, no specific facts from the IS list.

So this lands at Sector-Adapted (2) - it references recognized frameworks but lacks company-specific details or governance structures.

fact: National Institute of Standards and Technology (NIST)

fact: International Organization for Standardization (ISO)


reasoning: The paragraph describes the company's internal incident response escalation procedures — policies designed to route incidents to an Incident Management Team and then to a disclosure committee and Audit Committee. This is about the function (process/procedures), not about any person's credentials or the board's oversight role. No named frameworks, cybersecurity-specific titles, specific dates, or other IS-list facts are present; 'Incident Management Team', 'disclosure committee', and 'Audit Committee' are all generic governance terms.

thinking:
Let me analyze this paragraph.

Content: Describes incident response escalation procedures - policies escalate to Incident Management Team, which mitigates/remediates incidents, and further escalation to disclosure committee and Audit Committee.

Category: This is about internal processes - incident response policies and escalation procedures. The person-vs-function test: this is about what the processes do, not about any person. → Risk Management Process

Specific facts check:
- "Incident Management Team" - this is a named internal team, but is it unique enough? It's a generic program name without a unique identifier. Similar to "incident response plan" being generic.

- "Audit Committee" is on the NOT list, and "disclosure committee" is just generic governance language. "Incident Management Team" itself is fairly generic too - many organizations have teams with this name, and there's no distinguishing identifier like an abbreviation. Per the guidelines, generic program names don't qualify.

No named frameworks, specific dates, named roles from the IS list, or specific numbers present.

Specificity: Generic Boilerplate (1)


reasoning: The paragraph describes the company's internal protocols for reporting cybersecurity incidents to management, stakeholders, and regulatory bodies — these are internal process descriptions. The Board mention is brief and subordinate to the process description. No named frameworks, specific roles from the IS list, dates, or other firm-specific facts are present; all language is generic and could apply to any company.

thinking:
Classify this paragraph.

Content: Describes incident reporting protocols - reporting to management, stakeholders, regulatory bodies. Board is informed about material incidents.

Category: This is about incident reporting protocols as part of the company's risk management process. The Board mention is brief. The dominant topic is the reporting/communication protocols. This is Risk Management Process.

Wait - let me reconsider. "Incident Reporting and Communication" - this describes protocols for reporting incidents. It's about internal processes. The Board mention is subordinate. → Risk Management Process.

Specificity: No named frameworks, no specific facts from the IS list. "The Board" is generic. "management, stakeholders, and regulatory bodies" is generic.

There are no dates, named roles, or specific tools mentioned either, which confirms this is generic boilerplate content.


reasoning: The paragraph describes the company's security governance structure with Board oversight and CFO direction. While it touches on management (CFO) and process (evaluate and address cyber risk), its primary communicative purpose is establishing the oversight/governance arrangement, making Board Governance the best fit. No specific facts from the IS list are present — CFO is a generic C-suite title, 'the Board' is standard, and no frameworks, dates, or firm-specific details are provided.

thinking:
Classify this paragraph.

The paragraph mentions board oversight and CFO direction over security governance. The primary subject is the governance structure itself. The board is mentioned but briefly ("with oversight from the Board"). The CFO is mentioned as directing the structure.

Category: This is about governance structure. The CFO is the grammatical subject directing things, with board oversight mentioned. But CFO is a generic C-suite title (NOT list). The paragraph describes maintaining a "security governance structure to evaluate and address cyber risk" - this is about organizational structure/governance.

The board is mentioned as having oversight, and the CFO is mentioned as directing. This is a hybrid. The primary communicative purpose seems to be describing who oversees cybersecurity governance.

The CFO directs the governance structure while the Board provides oversight, making the CFO the primary actor here. The sentence structure emphasizes the CFO's role as director with the Board in a secondary oversight capacity. This could fit either Board Governance or Management Role, but the framing suggests the CFO is the main driver. Looking at the tiebreakers, both the board and management are mentioned only briefly, so the deciding factor is what the paragraph is actually about—the governance structure and oversight arrangement itself. That points to Board Governance. Then checking against the specificity criteria: the CFO, Board, and security governance structure are all generic terms with no named frameworks or specific details, which confirms this falls into Generic Boilerplate.