reasoning: This paragraph states a conclusion about whether cybersecurity has materially affected or is reasonably likely to materially affect the company — both backward-looking and forward-looking materiality assessments, triggering SI under Rule 5. The language is standard SEC boilerplate with no domain terminology, firm-specific facts, or verifiable claims.


content_category: Management Role

fact: IT Security Steering Committee

fact: VP of Software Engineering

fact: vulnerabilities

fact: security and awareness training

fact: over 40 years of experience

type: quantified

category_confidence: high

specificity_confidence: high

reasoning: The paragraph primarily answers 'how is management organized?' — it describes the IT Security Steering Committee's composition and leadership, the IT Security Team's membership, and how responsibilities are divided, with program activities (monitoring, training) subordinate to the organizational structure. Person-removal test: removing all roles, committee membership, and experience leaves only generic vendor testing and training language, confirming MR. Specificity reaches Level 4 due to 'over 40 years of experience,' a lower-bound quantified claim that is independently verifiable.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content Category: This paragraph describes the IT Security Steering Committee composition, leadership, and the IT Security Team's responsibilities. It covers committee membership, roles, reporting structure, and what the team does.

The primary question: "How is management organized to handle cybersecurity?" - describes committee structure, membership, roles. But it also describes program activities (testing, monitoring, training).

Person-removal test: Remove titles, committee membership, experience. What remains? "works with various vendors and external providers to test and monitor for vulnerabilities and threats" and "employees to complete annual security and awareness training." Some program description remains but the bulk is about organizational structure.

Now I'm breaking down the sentence-by-sentence content to determine the dominant category. The first three sentences focus on committee composition and leadership structure, the fourth mixes organizational details with program activities around vendor testing and monitoring, and the fifth covers employee training. The organizational and management structure clearly dominates, so this falls under Management and Reporting.

Looking at specificity, the IT Security Steering Committee is a named entity specific to this organization, while the CFO role is a generic governance position that wouldn't count as firm-specific per the codebook. The VP of Software Engineering represents a firm-specific leadership title.

The Director of Information Systems and Security is a director-level position with explicit security responsibilities, making it firm-specific. The mention of over 40 years of experience provides a concrete, verifiable quantitative detail. Combined with domain-specific terminology like vulnerability monitoring and security awareness training, this pushes the passage into the Quantitative Verification category.


content_category: Risk Management Process

reasoning: The paragraph describes the company's use of a third party to assess its own cybersecurity processes, which per Rule 3 (third parties hired to serve the company) is RMP, not TP. Specificity is Level 1: 'third party' is unnamed, 'processes and practices for managing and mitigating cybersecurity risks' is generic ERM language, and no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: Describes using a third party to assess the company's own processes for managing cybersecurity risks. The third party is hired to serve the company's own program (Rule 3: third parties hired to serve the company → RMP). This answers "What does the cybersecurity program do?"

Specificity: No domain terminology (just generic "processes and practices for managing and mitigating cybersecurity risks" - ERM language). No firm-specific facts ("a third party" is unnamed). No QV facts. Level 1.


reasoning: The paragraph answers 'How is management organized to handle cybersecurity?' by describing management's responsibilities, general qualifications (advanced degrees, unnamed industry certifications), and how they stay informed — all centered on who is responsible and what qualifies them. Person-removal test confirms MR: removing management references leaves no substantive program description. For specificity, CCO is a generic business role (not cybersecurity-specific), certifications are unnamed ('industry certifications focused on financial services and information technology' — no CISSP, CISM, etc.), and all other language (prevention, detection, mitigation, remediation, risk management) passes the ERM test as generic business vocabulary. No domain terms, firm-specific facts, or verifiable claims survive validation.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph answers "How is management organized to handle cybersecurity?" - it describes management's responsibilities, qualifications/expertise, and how they stay informed. Person-removal test: remove management roles, qualifications, expertise → what remains is generic monitoring language. → MR.

Specificity: Let me scan for facts.
- "CCO" - Chief Compliance Officer, not a cybersecurity-specific title (CFO, CCO, etc. are generic business roles → NOT firm-specific)
- "advanced degrees in business administration and legal studies" - generic qualifications, not specific numbers or named credentials

- The certifications mentioned don't name specific ones like CISSP or CISM, just vaguely reference information security credentials → not QV
- The team composition lists departments like risk management, legal, IT, and compliance, but uses "and/or" language that's too flexible to be specific
- CCO is a standard business role, not firm-specific
- Terms like "detection, mitigation, and remediation" are generic risk management language, not specialized domain expertise
- "Cybersecurity incidents" and "threats" are the subject matter of the filing itself, not evidence of domain knowledge
- I'm questioning whether any of this actually demonstrates domain expertise or if it's just standard business terminology that anyone could use

This looks like Level 1 - Generic Boilerplate. The language is all general management qualification stuff with no specific cybersecurity domain terms that would pass the ERM test. I'll classify it as MR, Level 1.


content_category: Board Governance

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the Board and Audit Committee's role in overseeing risk assessment and cybersecurity. No domain terminology, firm-specific facts, or verifiable claims are present—'Board,' 'Audit Committee,' 'processes for assessing and managing risk,' and 'data protection and cybersecurity risks' are all generic governance language that could appear in any public company filing.

thinking:
Let me classify this paragraph.

Category: "How does the board oversee cybersecurity?" → Board Governance. The paragraph describes board and Audit Committee oversight of risk assessment and cybersecurity.

Specificity: Let me scan for facts.
- "Board" / "Audit Committee" — NOT firm-specific (every public company has these)
- "processes for assessing and managing risk" — generic ERM language, Level 1
- "data protection and cybersecurity risks" — "data protection" is borderline but "cybersecurity risks" is just the topic of the filing
- No domain terminology, no firm-specific facts, no QV facts

- This is just standard boilerplate language that any company would use.


content_category: None/Other

reasoning: This is a fragment of a cross-reference or section header pointing to a risk factor discussion, not a substantive cybersecurity disclosure. It contains no actual cybersecurity measures, processes, or assessments — just a title/heading fragment. N/O always receives Specificity 1.


fact: CISSP (Certified Information Systems Security Professional)

fact: CCSP (Certified Cloud Security Professional)

fact: penetration testing

fact: email phishing test campaigns

fact: real-time vulnerability scanning

fact: intrusion detection

fact: email security monitoring

reasoning: Person-removal test: removing the Director's title, experience, and certifications leaves a full program description (penetration testing, vulnerability scanning, intrusion detection, phishing campaigns, etc.) → RMP. CISSP and CCSP are named certifications verifiable via (ISC)², elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

Content category: The paragraph starts with the Director of Information Security and Privacy's experience and certifications, then describes what the information security team does. Person-removal test: remove the Director title, experience, certifications → "The information security team conducts periodic assessment and testing... These efforts include penetration testing, adoption and regular evaluation of incident response plans, phishing test campaigns, email security monitoring, real-time vulnerability scanning and intrusion detection, cybersecurity awareness programming, regular audits, and continuous improvement of the information security management system." That's a substantial program description → RMP.

Specificity:

The Director role is firm-specific with a security qualifier, and while "decades of experience" is vague, the CISSP and CCSP certifications are both verifiable credentials that qualify as QV. The technical practices mentioned—penetration testing, phishing campaigns, vulnerability scanning, and intrusion detection—are all domain-specific terms that demonstrate concrete security capabilities, pushing this to Level 4.


fact: Mr. Tao (named individual)

reasoning: The paragraph describes a named individual's qualifications and career experience within Item 1C, answering 'how is management organized to handle cybersecurity?' — making it Management Role. 'More than 20 years' is a verifiable lower bound (checkable against a resume), elevating specificity to Level 4, though notably the experience is in general business/marketing rather than cybersecurity.

thinking:
Classify this paragraph about Mr. Tao's experience.

This describes a person's qualifications/experience. It's about management's background → Management Role.

Specificity: "more than 20 years" is a lower bound, verifiable. But wait - his experience is in "business consultation, operations, and management" with focus on "marketing industry" - not cybersecurity. Let me check if this still counts.

The paragraph mentions a named individual (Mr. Tao) in the context of a cybersecurity filing section (Item 1C), and "more than 20 years of professional experience" is a quantified lower bound.

The named individual and quantified timeframe push this to Level 4 - the specific years of experience are verifiable against his resume, even though the expertise isn't cybersecurity-focused.


fact: Chief Information Officer (CIO) covers cybersecurity matters in executive sessions with the Board

reasoning: The paragraph primarily answers 'How does the board oversee cybersecurity?' — describing Board-level review of cybersecurity risks, policies, and updates from management/CIO. The CIO reporting to the board is part of the oversight flow (BG pattern). The mention of the CIO as a named cybersecurity-relevant leadership role elevates specificity to Firm-Specific, but there are no quantified or externally verifiable facts to reach Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes board oversight of cybersecurity - the Board oversees risks, reviews policies, receives updates from management and CIO. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

The CIO reporting to the board is part of the oversight flow (BG pattern: "Management reports TO the board").

Specificity: Let me scan for facts.
- "Chief Information Officer" / "CIO" — this is a firm-specific cybersecurity leadership role (VP-level or above)

- The remaining terms like "key risk indicators," "emerging risks," "identified incidents," and references to the "Board" and "management team" are all generic risk management language that don't add firm-specific detail.

Since the CIO is the only firm-specific element here and it's already in the codebook, this rates at Level 3 with no quantitative or verifiable facts present.


content_category: Strategy Integration

reasoning: The paragraph states a conclusion about whether cybersecurity has or is likely to materially affect business strategy, results of operations, or financial condition — this is a materiality assessment (both backward- and forward-looking), making it SI. No domain terminology, firm-specific facts, or verifiable claims are present; the language is generic boilerplate that could appear in any company's filing.

thinking:
Materiality assessment conclusion → SI. "no cybersecurity incident that has or is likely to materially affect us" is a backward-looking + forward-looking assessment.

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


content_category: Third-Party Risk

reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — it describes vendor risk assessments and alignment requirements imposed on external parties, making TP the clear category. Specificity remains Level 1 because the language is entirely generic: 'rigorous cybersecurity risk assessments,' 'robust policies,' and 'align with our cybersecurity standards' contain no domain terminology (fails ERM test — swap 'cybersecurity' for 'financial' and it still reads naturally), no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Content: About third-party service provider cybersecurity oversight. The Sponsor conducts risk assessments of vendors/partners. This answers "How are third-party cyber risks managed?" → Third-Party Risk.

Specificity: Let me scan for facts.
- "rigorous cybersecurity risk assessments" - generic process description
- "all vendors and business partners" - no specific number
- "access to our networks or sensitive information" - generic
- No domain terminology beyond general risk management language
- No firm-specific facts (no named roles, committees, etc.)

- No QV facts

"Cybersecurity risk assessments" is just a generic risk management concept with a cybersecurity label—the kind of language that appears in any ERM framework. "The Sponsor" is a placeholder reference, not a defined role. This lands at Level 1 - Generic Boilerplate, the type of disclosure that could fit into virtually any filing without modification.


fact: more than seven years of operational IT responsibility

reasoning: The first sentence mentions board oversight, but the bulk of the paragraph describes management's organizational role — the Deputy CEO/CFO and external IT team's responsibilities, and qualifications. Person-removal leaves little substance, confirming MR. 'More than seven years' of operational IT responsibility is a lower-bound quantified fact verifiable against a resume, elevating to Level 4.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph covers both board oversight and management roles. The first sentence is about board oversight (BG). The rest is about management organization - who manages the program (Deputy CEO/CFO and external IT team), their responsibilities, and qualifications (7+ years). The majority of text is about management's organizational role.

Using Rule 1: The board sentence is brief. The primary content is about management roles, responsibilities, and qualifications. Person-removal test: remove Deputy CEO/CFO, external IT team, 7 years experience - very little remains. → MR.

Now I'm checking whether the Deputy CEO/CFO role counts as firm-specific. The codebook lists standard executive titles like CEO, CFO, and COO as not cybersecurity-specific, but this is a Deputy CEO combined with CFO managing cybersecurity - an unusual arrangement that doesn't match typical cybersecurity titles like CISO or CTO. This atypical structure suggests the role itself is defined by the firm's particular organizational approach rather than a standard cybersecurity function.

For the experience requirement, "more than seven years" of operational IT responsibility qualifies as a quantifiable verifiable claim - it's a lower bound that can be checked against a resume, just like "more than 20 years" in the codebook examples. This makes it QV-eligible and pushes the qualification to Level 4.


fact: VP Security

fact: IT Risk and Compliance Team

category_confidence: medium

reasoning: The paragraph describes internal audit and IT compliance activities (monitoring IT systems controls) rather than focusing on who holds the roles or their qualifications. Person-removal test: removing 'VP Security' and team name still leaves a description of auditing and monitoring IT controls integrated into internal controls — a process description, though thin. However, this is borderline between RMP and MR given the reporting-line content. The VP Security title and named IT Risk and Compliance Team are firm-specific facts elevating to Level 3.


fact: Senior Director, Information Technology identified as primarily responsible for cybersecurity

fact: Incident Response Team with specific composition (SVP Finance and General Counsel)

fact: over twenty years of experience in IT, security and cybersecurity

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' by identifying responsible roles (Senior Director IT, Incident Response Team members), their qualifications, and team composition. Person-removal test: removing titles, qualifications, experience, and team membership leaves only a thin reference to unnamed service providers — confirming MR. Specificity reaches Level 4 because 'over twenty years of experience' is a lower-bound quantified fact (≥20 years) that is independently checkable against a resume.

thinking:
Let me analyze this paragraph.

Category: This paragraph describes management roles, responsibilities, qualifications, and team composition for cybersecurity. It answers "How is management organized to handle cybersecurity?"

Person-removal test: Remove all person-specific content (titles, qualifications, experience, team composition, reporting lines). What remains? "supported by an experienced managed service provider and an incident response provider with extensive global cybersecurity expertise, who each monitor, assess and report threats to us." - This is thin. The paragraph is primarily about WHO is responsible and their qualifications. → MR

Now I'm checking whether specific titles and team compositions qualify as firm-specific. The Senior Director of Information Technology lacks an explicit security qualifier in the title itself, though the context is cybersecurity-related. The Incident Response Team is generically named but has specific role-based composition listed, which could push it toward firm-specific. I'm also noting that the Senior Vice President of Finance appears in the team composition, which is unusual for a cybersecurity discussion and might indicate firm-specific organizational structure.

For quantifiable facts, "over twenty years of experience" is a hard lower bound that counts as verifiable. The unnamed service providers and generic cybersecurity terms don't add firm-specific value, but the particular combination of Finance leadership and General Counsel in the incident response structure does suggest firm-specific organizational detail.

Now I'm reconsidering the Senior Director title—the codebook distinguishes between Director-level roles with security qualifiers versus generic IT directors. Since this person appears in a cybersecurity context as part of the incident response team, I need to check whether that context elevates it to firm-specific status. The SVP Finance is trickier because while SVP-level roles in IT functions are explicitly firm-specific per the codebook, Finance isn't a cybersecurity-specific domain, so that might not qualify under the same rule.

However, the team composition itself—listing specific executives like the SVP Finance and General Counsel together—does constitute a firm-specific team structure. For domain terms, "managed service provider" in this security context counts, but "incident response" and "remediation" are too general. So I'm settling on MR category with high confidence, driven by the quantifiable experience of over twenty years and the firm-specific incident response team composition.


content_category: Incident Disclosure

fact: ransomware attack

fact: January 18, 2023 — specific date of announced incident

fact: fewer than 300 restaurants closed

fact: one market for one day — quantified scope and duration

reasoning: The paragraph describes an actual ransomware attack with timeline, scope, and impact details, squarely answering 'what happened?' → Incident Disclosure. Multiple QV-eligible facts drive Level 4: a specific date (January 18, 2023), a quantified impact (fewer than 300 restaurants), and a quantified duration (one day in one market).

thinking:
Let me analyze this paragraph.

Content: Describes an actual cybersecurity incident - a ransomware attack on January 18, 2023, with specific details about impact (fewer than 300 restaurants closed, one market, one day), data affected (employee personal information), and what wasn't affected (customer databases).

Category: Incident Disclosure - clearly answers "What happened in a cybersecurity incident?"

Specificity: Let me scan for facts:
- "January 18, 2023" - specific date → QV
- "ransomware attack" - domain term (specific threat type)

- "fewer than 300 restaurants" - quantified impact → QV
- "one market for one day" - quantified scope

This is Level 4 - it has concrete dates, specific numbers, and clear delineation of what was and wasn't compromised.


reasoning: The paragraph states a conclusion about materiality ('has not experienced any material cybersecurity events or incidents' and third-party incidents 'have not resulted in a material impact'), making it a backward-looking materiality assessment → SI. No domain terminology, firm-specific facts, or verifiable claims are present; negative self-assertions about absence of incidents are not externally verifiable per the codebook.

thinking:
Let me analyze this paragraph.

Content: States no material cybersecurity events, and third-party providers' incidents haven't materially impacted the company.

Category: This is a materiality assessment - stating a conclusion about whether cybersecurity has affected the business. "Has not experienced any material cybersecurity events" is a negative assertion with materiality framing → SI.

Specificity: The paragraph uses general business language. No domain terminology, no firm-specific facts, no verifiable facts. "Has not experienced any material cybersecurity incidents" is a negative self-assertion - NOT externally verifiable per the codebook. No domain terms beyond general language.

This lands at Level 1 - it's a broad negative claim without specifics or external verification.


reasoning: This paragraph answers 'what does the cybersecurity program do?' by listing a program element (asset identification, assessment, monitoring, classification). However, the language is entirely generic — 'identify, assess, monitor, classify' are standard ERM terms that would work in any risk management context. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph describes third-party consultants hired to serve JLL's own cybersecurity program (testing, advisory, risk identification), which per Rule 3 is RMP, not TP—these firms augment the company's program rather than being vendors whose cybersecurity posture is overseen. The language is entirely general business terminology ('assessing, identifying and managing material risks,' 'testing and advisory services,' 'improve the quality of controls') with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Let me classify this paragraph.

Content: Describes third-party consultants hired to help with the company's own cybersecurity program - assessing, testing, advisory services.

Category: Per Rule 3, third parties hired to serve the company (assessors, consultants) → RMP. These aren't requirements imposed ON vendors; these are firms helping JLL's own program.

Specificity: Let me scan for facts.
- "third-party consultants" - unnamed, not firm-specific
- "testing and advisory services" - generic
- "assessing, identifying and managing material risks" - generic ERM language
- "cybersecurity incidents" - general

- No domain-specific terminology beyond generic business language, no firm-specific details or qualified vendor facts.

This is Level 1 - generic boilerplate throughout.


reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' — evaluating safeguards, monitoring, testing, and training employees. The IT leadership/CEO reporting line is subordinate context; applying the person-removal test, the program description (evaluate safeguards, monitor, test, train) remains substantive → RMP. All language is generic ERM vocabulary ('risk assessments,' 'safeguards,' 'monitor and test,' 'train employees') with no cybersecurity domain terminology, no firm-specific facts (CEO and 'IT leadership' are generic; 'human resources, IT, and management' is too generic to be distinguishing), and no verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Describes evaluating safeguards, IT leadership reporting to CEO, monitoring/testing safeguards, training employees, promoting cybersecurity culture.

Category: This touches on risk management processes (evaluating safeguards, monitoring, testing, training) and has a management reporting line (IT leadership reports to CEO). The person-removal test: remove "Our IT leadership reports to our Chief Executive Officer (CEO) to manage the risk assessment and mitigation process" - the remaining text describes safeguards evaluation, monitoring, testing, training. That's still substantive → RMP.

Specificity: Let me scan for facts:

- "IT leadership" and "CEO" are generic titles that appear in every company
- "human resources, IT, and management" names departments but they're pretty standard across organizations. Comparing this to something like "Legal, Compliance, and Finance" which feels more distinctive, I'd say this is borderline generic. "Management" especially is too broad to count as firm-specific detail.
- The language throughout—"risk assessments," "safeguards," "monitor and test," "train our employees"—is standard business and ERM terminology with no specialized frameworks, tools, or domain-specific language. This is clearly Level 1.


reasoning: The first clause states a backward-looking materiality conclusion ('have not experienced a cybersecurity threat or incident that resulted in a material adverse impact to our business or operations'), which is an SI materiality assessment per Rule 5. The speculation ('no guarantee') and cross-reference to Risk Factors are subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — the negative self-assertion about no material incidents is not externally verifiable, and the cross-reference adds no substance.

thinking:
Let me analyze this paragraph.

First sentence: "While we have not... experienced a cybersecurity threat or incident that resulted in a material adverse impact to our business or operations" — this is a backward-looking materiality assessment (negative assertion). Then "there can be no guarantee..." is speculation.

Second sentence is a cross-reference to Risk Factors.

Category: The first clause states a conclusion about materiality — "have not experienced... material adverse impact to our business or operations." Per Rule 5, this is a backward-looking materiality assessment → SI. The cross-reference is subordinate.

The negative assertion "have not experienced any material cybersecurity incidents" isn't externally verifiable — there are no domain-specific terms, firm-specific facts, or quantifiable metrics here. This lands at Level 1 specificity.


reasoning: This is a cross-reference directing the reader to Item 1A for cybersecurity risk information, with no substantive cybersecurity disclosure. Cross-references are N/O, always Level 1.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the Board's intended oversight role and delegation to a committee or appointed officer — classic BG content, though entirely future-tense/aspirational ('will oversee,' 'will review'). No domain terminology, no named roles or committees, and no verifiable facts — all language is generic and could apply to any company, keeping specificity at Level 1.

thinking:
Let me classify this paragraph.

Content: The Board will oversee cybersecurity risk management framework, and a committee or officer will review/approve policies, strategies, and risk management practices.

Category: This answers "How does the board oversee cybersecurity?" → Board Governance. It's about board oversight structure, delegation.

But note the future tense: "will oversee," "will review and approve." This is aspirational, not describing an existing program. Also, checking if this is a SPAC or no-operations company — Wenyuan Group Corp seems like a small company. The language is entirely future-tense and hypothetical.

The codebook distinguishes between aspirational governance language and actual programs, but this paragraph does articulate an intended oversight structure even if it's not yet implemented. Without confirmation that this is a SPAC or truly non-operational, I'll classify it as Board Governance with the caveat that the future tense indicates this is a planned rather than established program.

Now I'm checking the specificity of the language used — the references to "board," "dedicated committee," and "officer" are all generic terms without naming specific individuals or committees, and the cybersecurity language is standard boilerplate. There's no firm-specific detail or domain expertise evident, so this rates as Level 1 specificity.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing vendor onboarding assessments, risk-based evaluation, and contractual cybersecurity obligations imposed on providers. Specificity remains Level 1 because all language ('cybersecurity risk assessments,' 'vendor management process,' 'contractual obligations') is general business/ERM vocabulary that any non-security professional could write; no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: Describes how the company manages third-party service providers' cybersecurity risks - onboarding assessments, risk assessments, contractual obligations. This clearly answers "How are third-party cyber risks managed?" → Third-Party Risk.

Specificity: Let me scan for facts.
- No domain terminology that passes the ERM test - "cybersecurity risk assessments," "vendor management process," "contractual obligations" are all general business/ERM language
- No firm-specific facts - no named roles, committees, specific details
- No QV facts

This is generic vendor risk management language.

I'm assigning this a Level 1 classification.


reasoning: This paragraph contains pure speculation ('cannot be predicted') and a cross-reference to Item 1A Risk Factors, with no substantive cybersecurity disclosure. It answers none of the six substantive questions. No domain terminology, firm-specific facts, or verifiable claims.


reasoning: The paragraph describes how cybersecurity findings flow to a board-level committee, answering 'how does the board oversee cybersecurity?' The named 'Enterprise Risk and Compliance Committee (ERC Committee)' is a non-generic, firm-specific board committee, elevating specificity to Level 3.


reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' by describing the incident response team composition (including the CFO), escalation structure, and reporting lines to the audit committee. Person-removal test: removing the CFO and team references leaves only generic incident escalation language, confirming the substance is organizational. For specificity, CFO is not a cybersecurity-specific role (explicitly NOT firm-specific per codebook), 'Audit Committee' exists at every public company, 'incident response' is general business language (NOT domain terminology), and the incident response team lacks a distinguishing identifier — no facts elevate above Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes incident response escalation processes, a cybersecurity incident response team that includes the CFO, and reporting to the audit committee.

Category: This is about how the company is organized to handle cybersecurity incidents. The paragraph describes an incident response team composition and escalation/reporting structure. Let me think about whether this is BG, MR, or RMP.

The paragraph covers:
1. Escalation processes for incidents → RMP-ish
2. A designated incident response team including CFO → MR-ish

3. Reporting to audit committee → BG-ish

Primary question: "How is management organized to handle cybersecurity?" - it's about the team structure and escalation. But it also describes the incident response process itself.

Person-removal test: Remove CFO, team composition. What remains? "Cybersecurity incident response processes are designed to escalate cybersecurity incidents... depending on the circumstances. The Company's incident response process also requires reporting about certain cybersecurity incidents." That's still a process description but quite generic.

Actually, the core content is about organizational structure for incident response - who is on the team, how escalation works, reporting lines. This feels like it straddles MR and BG, with the escalation process being the RMP element. The team composition and reporting structure are what make this primarily about management organization rather than just process.

The governance chain aspect—reporting to the audit committee—could suggest BG, but the main focus is really on how management is structured to handle incidents: the designated team, the CFO's role, and the escalation path to senior leadership. That's fundamentally about management responsibility, not board governance.

I'm settling on MR. The paragraph centers on management's organizational role in incident response—the team designation, CFO involvement, and escalation to senior management. The CFO is a generic governance role per the codebook, and the named cybersecurity incident response team is the specific organizational element here.

Looking at the specificity markers: no domain terminology that qualifies, no firm-specific facts, and the incident response team lacks a distinguishing identifier. This lands at Level 1. The next thinking fragment notes that "incident response" isn't classified as domain terminology, which actually weakens the MR argument since it suggests the content lacks specialized cybersecurity language and firm-specific details.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing vendor risk assessments, remediation obligations, and contractual security/privacy provisions imposed on third parties. All language is general business/ERM vocabulary (risk assessment, security provisions, remediation) without cybersecurity domain terminology, firm-specific facts, or verifiable claims, keeping it at Level 1.

thinking:
Let me classify this paragraph.

Content: Describes a third-party information risk management program, requiring vendors to complete security risk assessments, remediation obligations, and contractual security/privacy provisions.

Category: This is clearly about how third-party cyber risks are managed → Third-Party Risk (TP). The central topic is oversight of external parties.

Specificity: Let me scan for facts:
- "third-party information risk management program" - this is a named internal program but is it distinguishing? It's fairly generic naming.
- "periodic security risk assessment" - generic
- "security and privacy provisions" - generic
- No domain terminology that passes the ERM test - "security risk assessment" is generic ERM language

- No named roles, no numbers, no named firms, and the program name itself lacks any distinguishing identifier

Everything here is general business language about vendor management. No cybersecurity domain terms, no firm-specific facts, no QV facts. This is Level 1 - Generic Boilerplate.


fact: Chief Information Officer leads the information technology team

fact: Cybersecurity governance committee

fact: Committee composed of CFO, Chief Legal Officer, CIO, Head of Internal Audit, and senior IT team members

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' by detailing the CIO's leadership role, team responsibilities, reporting lines, and the cybersecurity governance committee's composition and mandate. Person-removal test: removing all role/team details leaves only generic policy language, confirming MR. Specificity is Level 3 due to the named CIO role, the named cybersecurity governance committee, and the specific committee composition listing multiple named roles.

thinking:
Let me analyze this paragraph.

Category: This describes management's organizational structure for cybersecurity - the CIO leading the IT team, the cybersecurity governance committee composition, reporting lines. The person-removal test: remove CIO, CFO, CLO, Head of Internal Audit, team composition → what remains? "developing and maintaining cybersecurity policies and standards, monitoring ongoing compliance and program updates, ensuring information security is aligned with business objectives and strategies" — some generic program description remains, but the bulk is about WHO is responsible and HOW they're organized. The primary question answered is "How is management organized to handle cybersecurity?" → MR.

Now I'm checking the specificity. The CIO and the named cybersecurity governance committee are firm-specific, while the CFO, Chief Legal Officer, and Head of Internal Audit are standard roles. The committee composition itself—listing those specific titles together—is what makes it firm-specific. There are no quantitative facts, dates, or external references, so this is Level 3.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' describing board and audit committee oversight structure, making it BG. All language is generic — 'board of directors,' 'executive officers,' 'audit committee,' 'risk management process' — terms found at every public company with no domain terminology, firm-specific facts, or verifiable claims.


reasoning: The paragraph is split between describing consultants hired for the company's own risk assessment (RMP) and requirements imposed on third-party service providers (TP). The most substantive and detailed content is the final sentence imposing certification, security, and breach-reporting requirements ON service providers, tipping the balance toward Third-Party Risk. All language is generic business/contract terminology ('risk assessment processes,' 'appropriate security measures,' 'policies and procedures') that any ERM professional would use — no cybersecurity domain terms, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party service providers in two contexts: (1) consultants hired to help the company's own security program, and (2) requirements imposed on third-party providers.

Category analysis:
- First part: consultants helping design/implement/monitor/test the company's cybersecurity → RMP (third parties serving the company)
- Second part: requirements imposed on third-party service providers (certify ability, maintain security measures, report breaches) → TP

The paragraph is split. The first two sentences describe consultants serving the company's program (RMP). The last sentence describes requirements imposed ON vendors (TP).

Looking at the balance here, the third sentence is quite substantial with detailed requirements, but the first part about using consultants for risk assessment and policy implementation is also clearly RMP material. The paragraph genuinely splits between how the company uses third parties for its own program versus what it requires of its vendors, with the vendor requirements section being more detailed and specific. The requirements on service providers lean this toward TP territory, even though the opening mentions consultants helping with the company's own risk assessment. The language about certifying security capabilities and breach reporting is vendor oversight, which is the more substantive part. Looking at the specificity now—terms like "risk assessment processes," "cybersecurity policies," and "security measures" are all generic ERM language without domain-specific terminology that would elevate them beyond L1.

Even "breach" here is just contractual reporting language, not a specific threat classification. There are no firm-specific facts or QV facts present, so this is Level 1 boilerplate that any company could use.


fact: Vice President of Information Systems

reasoning: This is a governance-chain paragraph where the majority of text (sentences 2–5) describes how the Board and Audit Committee oversee cybersecurity, receive reports from management, and are briefed on incidents — answering 'how does the board oversee cybersecurity?' The opening sentence about the VP of Information Systems introduces the management link but serves the oversight-flow narrative. The VP of Information Systems is a VP-level title with an IT/security portfolio, qualifying as firm-specific (Level 3); no QV-eligible facts are present.

thinking:
Let me analyze this paragraph.

Content: This paragraph describes both management organization and board oversight. Let me apply the "what question" test.

The paragraph covers:
1. VP of Information Systems leads cyber risk management, reports to CFO (management structure)
2. Board has ultimate oversight, Audit Committee oversees policies (board governance)
3. VP of Information Systems reports to Audit Committee on cyber risks (board governance - information flow)
4. Board of Trustees receives periodic updates (board governance)
5. Board and Audit Committee receive prompt info on material incidents (board governance)

This is a governance-chain paragraph (Board → Committee → Officer → Program).

Most of the content focuses on how information flows up to the board and committee, with the oversight structure they maintain. The opening sentence mentions the VP reporting to the CFO, but the rest centers on board and committee oversight, so this falls under Board Governance. For specificity, the Vice President of Information Systems is a firm-specific title with an IT/security focus, but the CFO, Audit Committee, and Board of Trustees are all generic roles that don't add specificity. The response plan reference is also generic. This lands at Level 3 specificity.


reasoning: The paragraph opens with a materiality assessment ('we have not had any material incidences involving cybersecurity attacks'), which is a backward-looking conclusion about business impact → SI. The remaining text is speculation ('could have a material adverse effect') and a cross-reference to Risk Factors, neither of which overrides the materiality assessment. For specificity, the date 'December 28, 2024' anchors a negative self-assertion which is not externally verifiable per codebook rules, and all other language ('security and integrity of our networks,' 'cybersecurity policies and procedures') is generic business language that fails the ERM test — no domain terminology, no firm-specific facts, no QV-eligible claims.

thinking:
Let me analyze this paragraph.

Content: States no material cybersecurity incidents as of a date, acknowledges ongoing risks, mentions efforts to maintain security, references risk factors section.

Category: The paragraph starts with a materiality assessment ("we have not had any material incidences"), then has speculation ("could have a material adverse effect"), and a cross-reference to Risk Factors. The materiality assessment is the key substantive content. "Have not had any material incidences" is a negative assertion with materiality framing → SI.

Specificity: "As of December 28, 2024, we have not had any material cybersecurity incidents" — negative self-assertion.

Now checking the codebook rules: negative assertions aren't externally verifiable, and the date doesn't change that. The language around policies and security measures is entirely generic with no domain-specific terminology or firm-specific facts. This is a Level 1 disclosure.


reasoning: The paragraph states a backward-looking conclusion about whether cybersecurity has materially affected business outcomes ('not aware of any cybersecurity threats or incidents to date that have materially affected its strategy, results of operations, or financial condition'), making it a materiality assessment → SI. No domain terminology, firm-specific facts, or verifiable claims are present; the negative self-assertion is not externally verifiable → Level 1.

thinking:
Classify this paragraph.

"The Company is not aware of any cybersecurity threats or incidents to date that have materially affected its strategy, results of operations, or financial condition."

This is a materiality assessment - backward-looking negative assertion. Per Rule 5, "Have not materially affected our business strategy, results of operations, or financial condition" → SI.

Specificity: This is boilerplate materiality language. No domain terms, no firm-specific facts. The negative assertion "not experienced any material cybersecurity incidents" is NOT externally verifiable.

So this lands at Level 1.


reasoning: The paragraph states two materiality conclusions — a backward-looking assessment ('have not identified material risks...that have materially affected us') and a forward-looking assessment ('reasonably likely to materially affect us') — both triggering SI under Rule 5. The cross-references to Risk Factors are subordinate to the assessments. No domain terminology, firm-specific facts, or verifiable claims are present; the language is standard SEC boilerplate.

thinking:
Let me analyze this paragraph.

Content: This paragraph makes two materiality assessments - backward-looking ("have not identified material risks...that have materially affected us") and forward-looking ("are reasonably likely to materially affect us"). Then it has cross-references to Risk Factors.

Category: Strategy Integration - it's stating conclusions about materiality (both backward and forward-looking assessments per Rule 5).

Specificity: Let me scan for facts.
- "have not identified material risks...that have materially affected us" - backward-looking materiality assessment → SI content but not a specific fact for specificity

- The forward-looking assessment and cross-references to risk factor titles are just boilerplate language without any firm-specific details or domain terminology. This is standard disclosure language with no substantive facts. Level 1.


reasoning: The opening sentence states a materiality conclusion — both backward-looking ('have not materially affected') and forward-looking ('are not reasonably likely to materially affect') — which is the SEC's Item 106(b)(2) required language, making this SI. The remainder is generic speculation ('may be insufficient,' 'could') and a cross-reference to Item 1A. No domain terminology, firm-specific facts, or verifiable claims appear anywhere in the paragraph, so specificity stays at Level 1.

thinking:
Analyzing this paragraph.

First sentence: "To date, we do not believe that any risks from any cybersecurity threats, including as a result of any previous cybersecurity incidents, have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition." — This is a materiality assessment (both backward and forward-looking). → SI

Rest: speculation ("could," "may") and cross-reference to Item 1A.

Category: SI — the first sentence states a conclusion about materiality.

Specificity: The materiality assessment is generic boilerplate. No domain terms, no firm-specific facts, no QV facts.

The remaining language—the cross-references and speculative language—is also generic and doesn't add specificity, so this rates as Level 1.


fact: Enterprise Risk Management Committee (ERMC)

fact: TISC (referenced as a named internal committee)

reasoning: The paragraph primarily describes a management-level committee (ERMC) — its responsibilities, composition, leadership (Director of ERM and CRO), and reporting lines — answering 'how is management organized to handle cybersecurity?' Per Rule 1, management-level committees described in terms of structure and membership → MR. The one-sentence reporting line to the Audit and Risk Committee is subordinate to the ERMC's own organizational description. Specificity reaches Level 3 via two named non-generic committees (ERMC, TISC); no QV-eligible facts are present (no specific numbers, dates, named external entities, or certifications).

thinking:
Let me analyze this paragraph.

Content: Describes the ERMC committee - its responsibilities, composition, reporting to Audit and Risk Committee, and leadership.

Category: This is about the ERMC, which is a management-level committee. It describes its structure, membership, responsibilities, and reporting line to the board's Audit and Risk Committee. The primary question answered is about how management is organized - the ERMC's role, composition, and leadership. But there's also a governance chain element (ERMC reports to Audit and Risk Committee).

The ERMC is a management-level committee. Per Rule 1, management-level committees → MR if about structure/membership.

So the focus here is really on the ERMC's organizational structure and its role in enterprise risk management, including cybersecurity oversight. While it reports upward to the Audit and Risk Committee, the paragraph is fundamentally describing how this management committee is composed and what it does.

Looking at the specificity markers, the ERMC and TISC are both named committees specific to this firm, so those count as firm-specific disclosures. The Director of Enterprise Risk Management title is also firm-specific since it's a particular role within their structure. The Chief Risk Officer reference is more generic, and the Audit and Risk Committee, while a board-level body, is essentially a standard committee structure that wouldn't necessarily be marked as firm-specific on its own.


reasoning: The paragraph primarily answers 'how are third-party cyber risks managed?' — the company uses various third parties and relies on the Adviser's personnel to oversee cybersecurity risks from those entities. No domain terminology is present; 'identifying and overseeing risks' is generic ERM language, and the listed functional areas (risk management, legal, IT, compliance) are standard business departments, not firm-specific compositions. 'The Adviser' is a generic reference (like 'third-party experts'), not a named entity.

thinking:
Let me analyze this paragraph.

Content: The company depends on third parties and relies on the Adviser's personnel for identifying/overseeing cybersecurity risks from those third parties.

Category: This is about how third-party cyber risks are managed. But let me think more carefully. The paragraph says they rely on the Adviser's personnel to oversee risks from third-party use. This is about third-party risk management as the central topic.

Wait - is this more about management organization (relying on the Adviser's personnel) or third-party risk? The paragraph has two parts: (1) we use third parties, (2) we rely on the Adviser's people to oversee risks from those third parties. The central topic is how they manage third-party cyber risks - through the Adviser's personnel.

Since this is an externally managed BDC, the Adviser is their external manager handling cybersecurity oversight of third parties. The core question is how third-party cyber risks get managed, which points to third-party risk as the primary category. I can see specific details about the team composition - risk management, legal, information technology, and compliance personnel - that give concrete substance to their oversight approach.

But looking closer, these are just generic functional areas, not a named or firm-specific team structure. The Adviser itself isn't named specifically either, just referenced generically. There's no domain expertise terminology here, no quantifiable facts, and nothing that survives the specificity filter as truly firm-specific. This reads more like standard enterprise risk management language rather than something distinctive to this company.

So this falls into Level 1 boilerplate. Let me think about the category though—is this third-party risk, management responsibility, or risk management process? The core question is how cyber risks from third parties are being managed, which points to third-party risk. The text explicitly mentions "risks from cybersecurity threats associated with our use of such entities," where those entities are the third parties. That confirms it's TP, not something else. And the specificity is definitely Level 1—no domain terminology, no firm-specific details, no quantifiable facts.


fact: CISSP certification

fact: CISM certification

fact: CISA certification

fact: previous cybersecurity leadership positions at various Fortune 500 companies and U.S. Defense contractors

reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' — describing the team's responsibilities (monitoring, supervision of internal and external personnel) and their qualifications (certifications, experience, prior roles). Person-removal test: removing qualifications and experience leaves generic responsibility language, confirming MR. Specificity is Level 4 because CISSP, CISM, and CISA are named, externally verifiable certifications (checkable via (ISC)², ISACA registries).

thinking:
Let me analyze this paragraph.

Content: Describes management team's role in cybersecurity - monitoring, responsibility, supervision, and their qualifications (CISSP, CISM, CISA, decades of experience, previous positions).

Category: This is about how management is organized to handle cybersecurity. Person-removal test: remove titles, qualifications, experience → "monitors the prevention, detection, mitigation and remediation of cybersecurity threats... has primary responsibility for our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our retained external cybersecurity consultants." This describes roles and responsibilities but also some program structure.

The paragraph leans heavily on management credentials and background rather than concrete program details. The certifications—CISSP, CISM, CISA—are verifiable qualifications, but the experience descriptions like "decades" and references to "Fortune 500 companies" lack specificity. This makes it primarily about who's in charge and why they're qualified, with only generic references to the actual cybersecurity team structure.


reasoning: The paragraph's central topic is managing cybersecurity risks of third-party service providers—reviewing their practices, imposing contractual obligations, conducting assessments and inspections—squarely answering 'how are third-party cyber risks managed?' All language (vendor management, security assessments, contractual obligations, questionnaires, annual re-assessments) passes the ERM test: a non-security risk manager could write identical sentences about any vendor risk domain. No domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: This is about vendor management processes for cybersecurity risks with third-party providers. It describes requirements imposed on vendors - reviewing their practices, contractual obligations, security assessments, on-site inspections, questionnaires, annual re-assessments.

Category: This is clearly Third-Party Risk (TP) - the central topic is oversight of external parties' cybersecurity.

Specificity: Let me scan for facts.
- "vendor management processes" - generic
- "reviewing cybersecurity practices" - generic
- "contractually imposing obligations" - generic

- "security assessments" - generic (ERM test: would appear in non-cyber vendor risk context)
- "conducting on-site inspections" - generic
- "written questionnaires" - generic
- "annual re-assessments" - generic cadence

All of this language could be used by any ERM professional about non-cyber vendor risk. No domain terminology, no firm-specific facts, no verifiable claims. Level 1.


reasoning: This is an introductory statement about the company's approach to cybersecurity risk management, answering 'what does the program do?' at the most general level. It contains no domain terminology, no firm-specific facts, and no verifiable claims — purely generic business language that could apply to any company.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing a program with policies, controls, and assessments — clearly RMP. However, every term used ('assess, identify, and manage risks,' 'policies and controls,' 'regularly reviewed,' 'internal and external assessments') is standard ERM language that would appear in any risk management context, with no cybersecurity domain terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: "To assess, identify, and manage the risks of cybersecurity threats to our information system, we maintain a cybersecurity program, including policies and controls, which are regularly reviewed through internal and external assessments."

Category: This answers "What does the cybersecurity program do?" → RMP

Specificity: Let me check for domain terms, firm-specific facts, and QV facts.

- "assess, identify, and manage the risks" → generic ERM language (Level 1)
- "cybersecurity program" → generic

- "policies and controls" → generic
- "regularly reviewed" → generic
- "internal and external assessments" → generic

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


reasoning: The paragraph opens with a materiality assessment — both backward-looking ('have not materially affected') and forward-looking ('reasonably likely to materially affect') — which is a conclusion about cybersecurity's impact on business outcomes, satisfying the SI materiality rule. The remainder is a caveat and cross-reference to Risk Factors, which is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present; the language is standard boilerplate found in many 10-K filings.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. A materiality assessment: "we have not identified any cybersecurity threats that have materially affected or that we believe are reasonably likely to materially affect our business strategy, results of operations, or financial condition"
2. A caveat about limitations and a cross-reference to Risk Factors

The first sentence contains a clear materiality conclusion (both backward-looking and forward-looking), making it SI per Rule 5.

The second part is a cross-reference, which would be N/O on its own, but the materiality assessment dominates.

The language here is entirely generic boilerplate with no specific details, domain-specific terminology, or company-particular facts—just standard materiality disclaimers. That puts it at Level 1 for specificity.


fact: real time threat detection

fact: dedicated monitoring platform

fact: communications with risk management, legal, information technology, and/or compliance personnel of the Investment Advisor

specificity_confidence: medium

reasoning: Person-removal test: removing CCO and management references, substantive program content remains — third-party IT provider, dedicated monitoring platform with real-time threat detection, and incident management processes — so this is RMP rather than MR. Specificity reaches Level 3 via the specific team composition listing departments (risk management, legal, IT, compliance) involved in cybersecurity communications, plus domain terms like 'real time threat detection' and 'dedicated monitoring platform' that pass the ERM test.

thinking:
Let me analyze this paragraph.

Content: Describes management's role in cybersecurity, mentions CCO, third-party IT provider, monitoring platform with real-time threat detection, and how management is informed about incidents.

Category: The paragraph starts with management's responsibility, mentions the Investment Advisor's third-party IT provider and resources, and describes how management monitors cybersecurity. The primary question answered is "What does the cybersecurity program do?" — it describes the program structure including third-party IT provider, monitoring platform, threat detection. Let me apply the person-removal test: remove CCO, management titles.

When I strip out the specific roles and titles, the core content remains substantive — it's describing actual program components like the third-party IT provider, the monitoring platform with real-time threat detection, and the incident response process. But I'm also seeing governance elements woven in: how management gets informed through notifications and communications with various departments. This paragraph is doing double duty — it's both explaining what the cybersecurity program consists of and how management oversees it. The management responsibility framing in the opening sentence doesn't disappear when I remove titles; it's fundamental to the structure. This looks like it belongs in RMP. The listing of specific departments—risk management, legal, information technology, and compliance—identifies a firm-specific team composition, which matches the codebook's standard for Level 3. Combined with the domain-specific terminology like "real time threat detection" and "remediation," this qualifies as a substantive cybersecurity program description at Level 3.


reasoning: The paragraph states a backward-looking and forward-looking materiality conclusion ('have not materially affected or are reasonably likely to materially affect'), making it SI under the materiality assessment rule. The second sentence is a cross-reference subordinate to the assessment. No domain terminology, firm-specific facts, or verifiable claims are present — the negative assertion about no material incidents is not externally verifiable.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — it describes requirements imposed on vendors (risk assessments, controls, compliance monitoring), making it TP. All language is general business vocabulary (risk assessments, cybersecurity controls, compliance monitoring) that any ERM professional would use; no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: About third-party/vendor cybersecurity oversight - conducting risk assessments of vendors, requiring them to implement controls, monitoring compliance.

Category: Third-Party Risk (TP) - central topic is vendor cybersecurity oversight.

Specificity: Let me check the facts.
- "Third-Party Risk Management program" - this is a named program but is it distinguishing? It's fairly generic naming.
- "periodic risk assessments of vendors" - generic
- "requiring vendors to implement appropriate cybersecurity controls" - generic
- "monitoring vendor compliance" - generic

- "Third-Party Risk Management program" doesn't qualify as firm-specific since it's a generic program name without distinguishing identifiers that any company could use. The language around risk assessments, cybersecurity controls, and compliance monitoring is all standard business terminology with no domain-specific jargon. This is Level 1.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing periodic risk assessments and their scope, making it RMP. All language is generic ERM terminology — 'risk assessments,' 'identification of reasonably foreseeable internal and external risks,' 'likelihood and potential damage,' 'policies, procedures, systems, and safeguards' — none of which passes the ERM test for domain terminology, and there are no firm-specific or verifiable facts.

thinking:
Let me classify this paragraph.

Content: Describes risk assessment processes - periodic assessments, identification of risks, likelihood/damage evaluation, sufficiency of existing safeguards.

Category: "What does the cybersecurity program do?" → RMP

Specificity: Let me scan for facts.
- "periodic risk assessments" - generic ERM language
- "identification of reasonably foreseeable internal and external risks" - generic
- "likelihood and potential damage" - generic risk management
- "policies, procedures, systems, and safeguards" - generic

Everything here is standard risk management language. No domain terminology, no firm-specific facts, no verifiable claims.

The language is so generic it could apply to any organization's risk management approach regardless of industry or focus area. Level 1.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing processes for managing third-party service provider risks and updating vendor contracts with security/confidentiality/recourse requirements, making it TP. Despite mentioning contract amendments related to security and confidentiality, the language remains entirely general business/legal terminology (no domain terms like SOC 2, encryption, etc.) and contains no firm-specific facts or verifiable claims — 'Cleco' is just a company self-reference, not a firm-specific cybersecurity detail.

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


fact: Chief Privacy Officer (designated from Chief Risk Officer)

fact: Chief Information Security Officer

fact: Risk Oversight Committee (Board-level)

fact: Information Security Program

fact: Security Incident Response Policy and Plan

fact: over 13 years previously serving as the Company's Chief Financial Officer

fact: over 20 years of work experience in cybersecurity at financial institutions

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity — describing the CPO and CISO roles, their responsibilities, coordination, reporting lines, and qualifications. Person-removal test leaves little substance. Specificity reaches Level 4 due to quantified years of experience ('over 13 years' and 'over 20 years') which are verifiable lower-bound claims.

thinking:
Let me analyze this paragraph.

Content: Describes management roles (CRO/CPO and CISO), their responsibilities, coordination, reporting to Board's Risk Oversight Committee, and qualifications.

Category: The primary question is "How is management organized to handle cybersecurity?" - roles, responsibilities, reporting lines, qualifications. Person-removal test: remove all person-specific content and very little remains. This is MR.

Wait - there's reporting to the Board's Risk Oversight Committee. But the bulk is about management organization. BG vs MR: the reporting to the board is one sentence among many about management roles. Primary content is management organizational structure.

The specificity here is strong - I'm seeing named roles like Chief Privacy Officer and CISO, specific committees and programs, plus quantified experience metrics like the 13 years as CFO and 20+ years in cybersecurity. These concrete details and measurable qualifications push this to Level 4.


reasoning: This is a standard forward-looking statements disclaimer with no substantive cybersecurity disclosure. It contains only boilerplate legal language applicable to any SEC filing.


reasoning: The first sentence states a materiality conclusion ('has not identified any cybersecurity incidents which have materially affected, or are reasonably likely to materially affect') using SEC Item 106(b)(2) language, making this SI. The admission of no specific policies and generic 'keeping up to date' language contain no domain terminology, no firm-specific facts, and no verifiable claims — the negative materiality assertion is a self-reported claim about absence, not externally verifiable — so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: Three sentences. First states no material incidents (materiality assessment). Second says no specific cybersecurity policies implemented. Third says they're aware of risks and taking proactive steps.

Category: The first sentence is a materiality assessment → SI. The second sentence says they have NO policies. The third is generic. The primary thrust is the materiality conclusion in sentence 1, plus an admission of no program. This is SI per the materiality rule.

Wait - the second sentence says "has not implemented any specific policies with respect to monitoring and managing cybersecurity threats." This is essentially a SPAC-like admission of no program.

But they're an operating company making a materiality assessment, not a SPAC. The first sentence directly answers whether cybersecurity affects the business with a materiality conclusion → SI. The rest is supplementary. SI wins.

Looking at specificity: the materiality language mirrors SEC boilerplate about business strategy and financial condition, the policies admission is just a negative assertion, and there's no domain expertise, firm-specific details, or quantifiable facts. The negative materiality claim itself isn't externally verifiable per the codebook—it's a self-assertion without external validation.

This lands at Level 1 - generic boilerplate.


reasoning: The paragraph is split between two topics: engaging third-party consultants for the company's own risk program (RMP per Rule 3) and establishing processes to oversee third-party cybersecurity risks (TP). The second clause directly answers 'how are third-party cyber risks managed?' and represents the more distinctive disclosure, edging the classification toward TP. All language is generic business/ERM vocabulary ('risk assessment,' 'risk management,' 'processes and procedures,' 'oversee and identify') with no domain terminology, firm-specific facts, or verifiable claims, yielding Level 1.

thinking:
Classify this paragraph.

The paragraph mentions engaging third-party consultants for risk assessment/management AND having processes to oversee cybersecurity risks associated with third parties.

Two topics: (1) third-party consultants helping with the company's own risk program → RMP, (2) processes to oversee third-party cybersecurity risks → TP.

The paragraph is split. The first clause is about consultants serving the company (RMP per Rule 3). The second clause is about overseeing third-party risks (TP). It's roughly equal but let me assess.

The first part describes hiring consultants for the company's own risk assessment, which falls under RMP, while the second part specifically addresses establishing processes to monitor third-party cyber risks, which is TP. Since the second clause is more distinctive and directly targets third-party risk oversight, I'd lean toward classifying this as TP overall. as a whole touches on both but the second clause is the more distinctive disclosure. However, "what question does this primarily answer?" - it's genuinely split.

I'll go with RMP slightly since the first clause is about the company's own risk program using consultants, and the second clause describes processes that are part of the company's risk management. Actually, the second clause specifically answers "how are third-party cyber risks managed?"

Let me just go with TP since the second clause directly answers the TP question and is the more substantive/specific disclosure.

Wait, actually both clauses are quite brief and generic. Let me reconsider. The paragraph has two equal parts. The first is RMP (consultants for own program), the second is TP (processes for third-party risks). When genuinely split, "the category whose content occupies the most text wins." They're roughly equal in length.

I'll go with Third-Party Risk since the second clause specifically answers the TP question, and even the first clause mentions third-party consultants in a risk context. Though Rule 3 does classify consultants hired to serve the company as RMP, the paragraph's real substance is about overseeing third-party risks. The language here is all generic—just standard business terminology around risk assessment and cybersecurity, nothing domain-specific or firm-particular. That puts it at Level 1 specificity.


fact: Technology Committee (named non-generic board-level committee)

reasoning: The paragraph describes the board's oversight structure for cybersecurity, including delegation to the Technology Committee and its reporting responsibilities — squarely answering the BG question. The Technology Committee is a named non-generic board committee that distinguishes this company's governance structure, elevating specificity to Firm-Specific.

thinking:
BG, describing board oversight structure with delegation to Technology Committee.

Facts: Technology Committee is a named non-generic committee → firm-specific (Level 3).


reasoning: The paragraph describes general regulatory context (financial privacy laws, SEC disclosure rules) and ends with a cross-reference to another section. It does not answer any of the six substantive cybersecurity questions — it neither describes the company's cybersecurity program, governance, management, incidents, third-party oversight, nor makes a materiality assessment. No domain terminology, firm-specific facts, or verifiable claims elevate specificity above Level 1.

thinking: Regulatory context and cross-references, no substantive cybersecurity disclosure.


fact: scanning our environment for vulnerabilities (vulnerability scanning)

fact: penetration testing

reasoning: The paragraph answers 'What does the cybersecurity program do?' by describing risk assessments, vulnerability scanning, penetration testing, and third-party assessments of the company's own security — all program activities (RMP). Third parties here serve the company's program, not vendor oversight. Penetration testing and vulnerability scanning are cybersecurity domain terms that pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Describes what the cybersecurity program does - risk assessments, vulnerability scanning, penetration testing, third-party assessments. This answers "What does the cybersecurity program do?" → RMP.

Third parties mentioned serve the company's own program → RMP not TP.

Specificity: Domain terms include "vulnerability scanning" (well, "scanning our environment for vulnerabilities"), "penetration testing" → Level 2. No firm-specific facts, no QV facts.


reasoning: The paragraph states a conclusion about materiality ('did not identify risks...that have materially affected, or are reasonably likely to materially affect, our business strategy, results of operations, or financial condition'), which is the SEC's Item 106(b)(2) assessment language → SI. No domain terminology, firm-specific facts, or verifiable claims are present; 'fiscal year 2023' is reporting-period context, the cross-reference to Item 1A is subordinate to the materiality conclusion, and the speculation ('cannot eliminate all risks') is generic boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph contains:
1. A materiality assessment: "did not identify risks from cybersecurity threats...that have materially affected, or are reasonably likely to materially affect, our business strategy, results of operations, or financial condition" → SI (backward-looking + forward-looking assessment)
2. A caveat about not eliminating all risks → speculation
3. A cross-reference to Item 1A

The primary content is the materiality conclusion → Strategy Integration.

Specificity: The materiality language is boilerplate. "Fiscal year 2023" is a reporting period context, not a cybersecurity fact.

The cross-reference to Item 1A points to risk disclosures but provides no actual incident details, domain-specific information, or company-particular facts. This is Level 1 content.


reasoning: The final sentence states a backward-looking materiality conclusion ('have not materially affected the company, including our business strategy, results of operations, or financial condition'), which is SI per Rule 5. The cross-reference to Item 1A and generic 'could materially impact' speculation are subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — the negative materiality assertion is a self-reported claim about absence, not externally verifiable.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. A cross-reference to Item 1A risk factors
2. A materiality assessment statement

The materiality assessment "have not materially affected the company, including our business strategy, results of operations, or financial condition" is a backward-looking SI assessment per Rule 5.

The first sentence is generic speculation ("could materially impact") and the cross-reference is N/O-like. But the final sentence IS a materiality conclusion → SI.

Specificity: Let me scan for facts.

The language here is pure boilerplate—negative assertions about cybersecurity risks that lack any verifiable support, generic cross-references, and standard headings rather than domain-specific terminology. There are no firm-specific facts or quantifiable details, just formulaic SI language. Level 1.


reasoning: The paragraph describes the general regulatory environment (financial privacy laws, SEC disclosure rules) and cross-references another section of the filing — it does not answer any of the six substantive cybersecurity questions about what the company actually does. N/O always receives Generic Boilerplate.

thinking:
This paragraph discusses regulatory context and cross-references another section. Let me classify it.

Content: Describes general regulatory environment (financial privacy laws, federal banking oversight, SEC rules), then cross-references another section. No substantive cybersecurity disclosure about what the company does.

Category: None/Other - this is regulatory context and cross-references, not answering any of the six substantive questions.

Specificity: N/O always gets Level 1.


reasoning: The first sentence is a cross-reference (N/O), but the second sentence states a backward-looking materiality conclusion ('has not experienced a cybersecurity threat that has materially affected the company'), which is an SI assessment per Rule 5. No domain terminology, firm-specific facts, or verifiable claims are present; the negative materiality assertion is a self-reported claim about absence, not externally verifiable.

thinking:
Let me analyze this paragraph.

Two sentences:
1. Cross-reference to Item 1A risk factors
2. "The Company has not experienced a cybersecurity threat that has materially affected the company." - This is a backward-looking materiality assessment.

Category: The cross-reference alone would be N/O, but the second sentence is a materiality conclusion ("has not...materially affected") → SI per Rule 5.

Specificity: "Has not experienced a cybersecurity threat that has materially affected the company" - negative self-assertion about materiality. No domain terms, no firm-specific facts, no QV facts. The negative assertion is not externally verifiable.

This lands at Level 1 on the disclosure quality scale.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the Board's awareness and oversight responsibilities regarding cybersecurity risks. No domain terminology, firm-specific facts, or verifiable claims are present — it uses only generic business language that could appear in any filing.


reasoning: The paragraph describes program activities (incident response plan, employee training, compliance programs), answering 'what does the cybersecurity program do?' → RMP. The language uses only generic terms — 'incident response plan,' 'cybersecurity training,' 'compliance programs' — all of which would appear naturally in any ERM document. No domain terminology, firm-specific facts, or verifiable claims are present.


fact: CISO

fact: threat intelligence briefings

fact: CISO reports to the Chief Executive Officer

fact: DTRC (named management-level committee)

fact: CyTOC (named cybersecurity operations entity)

fact: FedEx Executive Committee oversees business risk with cybersecurity as regular topic

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity: the CISO's reporting line to the CEO, the Executive Committee's oversight role, and the escalation/communication chain (DTRC, CyTOC, Executive Committee, Board). While threat intelligence briefings and incident response plan are mentioned, they serve to illustrate management communication paths rather than describe program activities in depth. Person-removal test: removing CISO, CEO, Executive Committee, DTRC, CyTOC leaves only fragments about briefings and communication processes — the paragraph collapses, confirming MR. Specificity is Level 3 due to firm-specific named entities (CISO, DTRC, CyTOC) but no externally verifiable quantified facts.

thinking:
Let me analyze this paragraph.

Content: Discusses CISO participation in threat intelligence briefings, CISO reporting to CEO, FedEx Executive Committee overseeing business risk with cybersecurity as a topic, and the incident response plan's communication processes to various management levels and the Board.

Category: This touches multiple areas. Let me apply the "what question" test:
- Threat intelligence briefings → RMP activity
- CISO reports to CEO → MR (reporting line)
- Executive Committee oversees business risk → could be BG or MR
- Incident response plan communication processes → RMP

The paragraph describes reporting lines (CISO → CEO), management oversight structure (Executive Committee), and incident response communication processes. It's a mix of MR and RMP.

When I strip away the organizational titles and roles, what's left is mostly about communication escalation paths and incident response procedures. The substance of the paragraph centers on how cybersecurity incidents flow through management layers and the Board, with threat intelligence briefings as a supporting activity. The core content is really about organizational structure and communication protocols rather than specific risk management practices. I'm identifying the firm-specific elements that qualify for Level 3 classification: the CISO role, DTRC and CyTOC as named internal committees, while generic terms like the incident response plan and CEO don't add specificity. There are no QV-eligible facts here—no numbers, dates, or external certifications—so this stays at Level 3.


reasoning: The paragraph's central topic is reliance on third-party service providers and the cyber risks they introduce, answering 'how are third-party cyber risks managed?' — though the answer is thin (only 'continuously monitors'). Specificity is Level 1 because the language is entirely general business vocabulary ('cyber attack,' 'information systems,' 'continuously monitors') with no domain terminology passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Let me classify this paragraph.

Content: Discusses reliance on third-party service providers, exposure to cyber attacks on those providers, and monitoring of service provider risks.

Category: This answers "How are third-party cyber risks managed?" - Third-Party Risk. The central topic is third-party/vendor cyber risk.

Wait - let me re-read. It talks about dependence on third parties, the risk of cyber attacks on them, and says "BHE continuously monitors the risks associated with its service providers." This is about third-party risk but is it substantive enough?

The paragraph describes: reliance on third-party providers, exposure to their cyber attacks, potential impact, and continuous monitoring.

Now I'm checking the specificity. The language here is quite generic - "third-party service providers," "cyber attack," and "continuously monitors" are all standard boilerplate terms without domain-specific terminology, firm-specific details, or verifiable facts. This reads like Level 1 generic boilerplate.


reasoning: The paragraph describes how material cybersecurity matters flow from senior management to the Audit Committee, answering 'how does the board oversee cybersecurity?' — this is an oversight structure description, defaulting to BG. No domain terminology, no firm-specific facts (Audit Committee is generic, 'senior management' is generic), and no verifiable claims — Level 1.


reasoning: The paragraph's central topic is how the company manages cybersecurity risks from third parties—vendor diligence, contractual protections, and monitoring—directly answering 'How are third-party cyber risks managed?' → TP. 'Security rating services' is a cybersecurity-specific concept (e.g., BitSight, SecurityScorecard) that an ERM professional would not naturally reference, elevating to Level 2, but nothing is firm-specific or verifiable.

thinking:
Let me classify this paragraph.

Content: About managing third-party cyber risks - vendor diligence, contractual protections, third-party risk monitoring.

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

Specificity: Let me scan for facts.
- "third-party risk monitoring security rating services" - this is a domain term? Let me think... Security rating services (like BitSight, SecurityScorecard) are cybersecurity-specific. An ERM professional wouldn't naturally talk about "security rating services." This passes the ERM test → Domain-Adapted.

- The other phrases like performing diligence, obtaining contractual protections, and overseeing threats are all generic risk management language. But "security rating services" is the specific cybersecurity domain concept that tips this toward Level 2.


reasoning: This paragraph is a cross-reference to Item 1A Risk Factors with speculative language ('may be materially affected') — it points elsewhere rather than stating a materiality conclusion, and contains no substantive cybersecurity disclosure of its own. N/O always receives Specificity 1.

thinking:
Classify this paragraph.

The paragraph is a cross-reference to Item 1A Risk Factors and contains speculative language ("may be materially affected").

Category: This is pointing to another section and using speculative "may be" language. Per Rule 5, "Could have a material adverse effect" → speculation, NOT SI. And cross-references pointing elsewhere → N/O.

Specificity: N/O always gets Level 1.


fact: CSIRPs (Cyber Security Incident Response Plans) — named internal program with distinguishing acronym

fact: detection, analysis, containment, eradication, recovery — incident response lifecycle phases specific to cybersecurity methodology

reasoning: The paragraph primarily answers 'What does the cybersecurity program do?' by describing incident response plan processes (detection through recovery and post-incident review); the Audit Committee notification is subordinate to the program description, keeping this RMP rather than BG. Specificity reaches Level 3 because 'CSIRPs' is a named internal program with a distinguishing identifier (analogous to the codebook example 'Cyber Incident Response Plan (CIRP)'), and the IR lifecycle terms (containment, eradication) are domain-adapted vocabulary from NIST SP 800-61 methodology.

thinking:
Let me classify this paragraph.

Content: Describes Cleco's CSIRPs (Cyber Security Incident Response Plans) - detection, analysis, containment, eradication, recovery, post-incident review, and notice to stakeholders including Audit Committee.

Category: This primarily answers "What does the cybersecurity program do?" - it describes incident response planning processes. The mention of Audit Committee notification is subordinate to the program description. → RMP

Specificity:
- "CSIRPs" - this is a named internal program with a distinguishing identifier → firm-specific (Level 3)
- "detection, analysis, containment, eradication, recovery" - these are incident response lifecycle phases, fairly standard but let me check...

These are general IR terms, though containment and eradication are cybersecurity-specific terminology that wouldn't naturally appear in generic ERM → domain terms (Level 2). "Post-incident review" is somewhat generic, and "Audit Committee" isn't firm-specific per the codebook. The key here is that CSIRPs itself - a named internal program with the distinguishing acronym - qualifies as firm-specific per the codebook's example of "Cyber Incident Response Plan (CIRP)" → Level 3. Now I'm checking whether the incident response lifecycle terms meet the threshold for specificity.


reasoning: The paragraph describes engaging external experts (assessors, consultants, auditors) to evaluate the company's own security and using detection tools — these serve the company's program, so RMP per Rule 3. Despite mentioning 'threat assessments' and 'proactive detection tools,' all language passes the ERM test (a non-security risk professional could write this); no specific frameworks, tool categories (e.g., SIEM, EDR), or named entities are mentioned, keeping it at Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes engaging external experts to evaluate the company's own security, plus using detection tools. The external parties are hired to serve the company's program (assessors, consultants, auditors) → RMP per Rule 3. The paragraph answers "What does the cybersecurity program do?"

Category: RMP

Specificity: Let me scan for facts.
- "cybersecurity assessors, third-party legal consultants, and auditors" — unnamed entities, not firm-specific
- "audits, threat assessments, and consultations on security enhancements" — "threat assessments" could be domain-ish but "audits" and "consultations" are generic.

Now I'm testing whether these terms would stand out to a general ERM professional. "Threat assessments" appears in non-cyber contexts too, "proactive detection tools" is too vague to be domain-specific, and "aligned with industry standards" is boilerplate language. None of these really clear the bar for domain-specific terminology.


reasoning: This paragraph describes general reliance on information systems and acknowledges cybersecurity risks exist, but does not answer any of the six substantive questions — it describes no program, no governance, no management structure, no incident, no third-party oversight process, and no materiality assessment. It is generic risk context language that could appear in any company's filing. No domain terminology, firm-specific facts, or verifiable claims are present.


fact: CISO as cybersecurity leadership role

reasoning: The paragraph answers 'how is management organized?' by describing the CISO's responsibilities and qualifications/experience. Person-removal test: removing the CISO, their role allocation, and career background leaves no substantive content. Specificity is Level 3 due to the CISO title (firm-specific cybersecurity leadership role), but no verifiable facts are present — 'extensive experience' is vague with no specific number of years, and no named certifications or prior employers.

thinking:
Let me analyze this paragraph.

Category: This is about management's organizational role - who the CISO is, their responsibilities, and their qualifications/experience. Person-removal test: remove CISO, titles, qualifications, experience → almost nothing remains. → MR

Specificity:
- "CISO" → firm-specific (named_role)
- "healthcare data" → not really domain terminology, more industry context
- No QV facts - "extensive experience" is vague, no specific numbers, no certifications named

Level 3 - Firm-Specific due to CISO.


reasoning: The paragraph states a backward-looking materiality conclusion — no cybersecurity incident during the year resulted in material impact on strategy, financial condition, or results of operations — making it SI under the materiality assessment rule. Specificity is Level 1: 'December 31, 2024' is reporting-period context (not a cybersecurity-specific date), the negative materiality assertion is not externally verifiable, and there are no domain terms, firm-specific facts, or QV-eligible claims.

thinking:
Let me analyze this paragraph.

Content: The paragraph discusses past cybersecurity attacks, states no material impact during 2024, and cross-references Item 1A for more information.

Category: The key sentence is "no cybersecurity incident during the year ended December 31, 2024, resulted in an interruption of our operations, known losses of critical data, nor a material impact on the firm's strategy, financial condition or results of operations." This is a backward-looking materiality assessment - stating a conclusion about whether cybersecurity has affected business outcomes. → Strategy Integration.

The cross-reference to Item 1A is subordinate.

Now I'm looking at the specificity of the claims. The materiality assertion about no incidents is a negative self-assessment that can't be externally verified, and the reporting date is just temporal context rather than a cybersecurity fact. There's no specialized terminology or firm-specific details beyond generic business language.


fact: Security Steering Committee

fact: CTO

fact: CSIRT (Computer Security Incident Response Team)

fact: PSIRT (Product Security Incident Response Team)

reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' by describing the CISO, Security Steering Committee, and senior executives' roles in reviewing policies and how the CISO receives incident information from CSIRT/PSIRT. Person-removal test: removing all roles and teams leaves generic process language ('review and manage policies... prompt communication describing severity...'), so the substance is the management structure. Specificity is Level 3 due to firm-specific named roles (CISO, CTO) and named teams (Security Steering Committee, CSIRT, PSIRT), but no externally verifiable quantified facts push it to Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes how management is organized - CISO, Security Steering Committee, CEO, CTO roles in reviewing/managing cybersecurity. But it also describes processes (how CISO monitors incidents via CSIRT/PSIRT communications, key risk indicators).

Person-removal test: Remove CISO, Security Steering Committee, CEO, CTO, CSIRT, PSIRT. What remains? "review and manage our cybersecurity policies and processes... processes by which [someone] is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents, include prompt communication... describing the severity and impact of the incident and status throughout the incident handling lifecycle and routine monitoring of key risk indicators."

Now I'm checking the specificity of each element. The CISO and Security Steering Committee are named firm-specific roles, while CSIRT and PSIRT are named teams with specific cybersecurity functions. The CTO and CEO are generic C-suite positions, not cybersecurity-specific. There are no numbers, dates, external entities, or certifications that would make this QV-eligible. This is clearly Level 3 - Firm-Specific.


fact: Cybersecurity Program Manager

reasoning: The paragraph's central topic is managing cybersecurity risks from third-party service providers — vendor evaluation, due diligence, and a vendor management policy — directly answering 'how are third-party cyber risks managed?' The Cybersecurity Program Manager is a firm-specific cybersecurity leadership title, elevating to Level 3. The remaining content (vendor risk assessment, due diligence process) uses general business language without domain-specific terminology or verifiable facts.

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

Facts:
- "Cybersecurity Program Manager" - named role (firm-specific)
- Vendor management policy approved by Board annually
- Description of vendor evaluation process

This is about how third-party cyber risks are managed - TP.

Specificity: "Cybersecurity Program Manager" is a firm-specific cybersecurity role title. No QV facts. Level 3.


reasoning: The paragraph contains only generic speculation about cybersecurity threats ('could have a material impact,' 'potential to negatively impact') and a cross-reference pointing to Item 1A for materiality discussion. No materiality conclusion is stated here, and no substantive cybersecurity measures are described, making this N/O. All language is general business risk vocabulary with no domain terms or specific facts.

thinking:
Let me analyze this paragraph.

Content: Generic risk language about cybersecurity threats, potential impacts, and a cross-reference to Item 1A.

Category: This is mostly speculation ("could," "potential," "may") and a cross-reference. No materiality assessment/conclusion is being stated. "Could have a material impact" is speculation. The cross-reference "For more information on how cybersecurity risk may materially affect..." points elsewhere → N/O.

Specificity: No domain terms, no firm-specific facts, no verifiable claims. Generic business language.

This lands at Level 1 — it's speculative language with no concrete details or firm-specific information.


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