fact: insider threat controls

fact: controls and tools to alert on suspicious or unusual insider activity (insider threat monitoring)

fact: controls to prevent data loss and external sharing (data loss prevention)

reasoning: The paragraph describes what the cybersecurity program does regarding insider threats — controls, monitoring tools, and data loss prevention — answering 'what does the program do?' → RMP. It uses domain-specific concepts (insider threat controls, DLP-style controls, insider activity alerting) that a generic ERM professional would not naturally employ, but contains no firm-specific or verifiable facts, placing it at Level 2.

thinking:
Let me analyze this paragraph.

Content: Describes insider threat controls - identifying, assessing, addressing internal risks, tools for suspicious activity, data loss prevention, external sharing controls.

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

Specificity: Let me scan for facts.
- "insider threat controls" - this is a security domain concept
- "data loss prevention" - wait, they say "prevent data loss and external sharing" which is describing DLP conceptually
- "controls and tools to alert on suspicious or unusual insider activity" - this describes monitoring but in generic terms

- "insider threat" is a security domain concept, a specific threat type that the codebook would classify as domain terminology. An ERM professional wouldn't naturally use this phrasing - they'd talk about internal risks or employee misconduct more broadly. The language here is distinctly cybersecurity-focused rather than general risk management.

- "data loss prevention" is explicitly listed in the domain terms as DLP. The paragraph describes this functionality without using the acronym, but it's still demonstrating specialized security knowledge by framing it as a control against data loss and external sharing.

So this paragraph does use domain-specific terminology and concepts - both "insider threat controls" and the DLP framing suggest the author has security expertise rather than speaking as a general ERM professional would.

I'm settling on Level 2 for this section. There are no firm-specific facts like named roles or committees, and nothing tied to their QV process specifically.


content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes how the Audit Committee reports cybersecurity risk information to the Board of Directors, and the Board's annual review of material cybersecurity risks — answering 'how does the board oversee cybersecurity?' All entities mentioned (Audit Committee, Board of Directors) are generic governance structures present at every public company, cadence is generic ('at least annually'), and no domain terminology, firm-specific facts, or verifiable claims are present.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: Describes the Audit Committee's role in reporting cybersecurity risks to the Board, and the Board's review of material cybersecurity risks/events annually.

Category: This answers "How does the board oversee cybersecurity?" — Board/committee oversight, reporting structure, briefing frequency. → Board Governance

Specificity: Let me scan for facts:
- "Audit Committee" — every public company has one, NOT firm-specific
- "Board of Directors" — generic, NOT firm-specific
- "at least annually" — generic cadence
- "processes to prevent, detect and mitigate cybersecurity incidents" — general language, ERM test: swap cybersecurity for any other risk and it works

- No domain terminology, no firm-specific facts, no QV facts

This is Level 1 boilerplate.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing delegation to the Audit Committee — classic BG. No domain terminology, no firm-specific facts (Board of Directors and Audit Committee exist at every public company), and no verifiable claims, so it remains Level 1.

thinking:
Classify this paragraph.

Category: Board Governance - describes how the board oversees cybersecurity, delegating to Audit Committee.

Specificity: "Board of Directors" and "Audit Committee" are generic (every public company has these). No domain terminology, no firm-specific facts, no QV facts. Level 1.


content_category: Management Role

fact: CTO

fact: CISO

reasoning: The paragraph describes the qualifications and experience of the internal working group, CTO, and CISO — answering 'how is management organized?' with focus on credentials and background. Person-removal test: removing roles and qualifications leaves nothing substantive. CTO and CISO are firm-specific cybersecurity leadership titles, but 'multiple decades' is a soft number and certifications are unnamed, so no QV-eligible facts push this beyond Level 3.

thinking:
Classify this paragraph.

This is about the qualifications and experience of members of an internal working group, CTO, and CISO. It answers "How is management organized to handle cybersecurity?" — specifically about qualifications and credentials.

Category: Management Role

Specificity: Let me check facts.
- "CTO" — firm-specific cybersecurity leadership role? CTO is listed under "NOT firm-specific" as a generic role... wait, let me re-check. The codebook says "CEO, CFO, COO, President, General Counsel — not cybersecurity-specific roles" but CTO is listed under firm-specific: "CISO, CTO, CIO, VP of IT/Security..." Yes, CTO is firm-specific.

- "CISO" is also firm-specific, and while they mention certifications and decades of experience, neither of those details are specific enough to qualify as quantified values.

So this lands at Level 3 (Firm-Specific) because of the CTO and CISO references.


content_category: Strategy Integration

fact: July 23, 2023 — specific date of cybersecurity incident

fact: $14.3 million of costs incurred in connection with the incident

type: quantified

category_confidence: medium

reasoning: The paragraph describes a real incident but its primary purpose is communicating the financial impact — $14.3M in costs and a materiality conclusion ('no material impact to our financial results'), making SI the best fit under Rule 4 (financial frame dominant) and Rule 5 (stating a materiality conclusion). Specificity is Level 4 due to the specific date (July 23, 2023) and the verifiable dollar amount ($14.3M).

thinking:
Let me analyze this paragraph.

Content: Describes a specific cybersecurity incident (July 23, 2023), costs ($14.3 million), forensic investigation, and materiality conclusion.

Category: This is primarily about what happened in a cybersecurity incident - timeline, costs, investigation, and impact. It's a mix of ID and SI. The paragraph describes the incident (date, what happened) but also gives financial impact ($14.3M costs) and a materiality conclusion. The financial/business impact framing is significant here - "$14.3 million of costs" and "no material impact to our financial results."

Looking at the balance here, the incident details and forensic investigation take up meaningful space, but the real focus seems to be on the financial assessment and materiality conclusion - that's what the paragraph is ultimately trying to communicate. So this leans toward SI. The paragraph's framing around "Cybersecurity Incident Impact" makes it clear the focus is on how this incident affects the business, with the materiality assessment being the key takeaway. Looking at the specificity markers: the July 23, 2023 date and $14.3 million cost are both quantitatively specific, while the forensic investigation detail adds context but isn't domain-specific on its own. This lands at Level 4 specificity.


content_category: Third-Party Risk

reasoning: The paragraph's central topic is assessing third-party vendors' data protection practices — answering 'how are third-party cyber risks managed?' → Third-Party Risk. All language is generic business terminology ('formal, documented process,' 'data protection practices,' 'sensitive information') that any ERM professional could write without cybersecurity domain knowledge; no domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: "We follow a formal, documented process to assess the data protection practices of certain third-party vendors that handle sensitive information on our behalf."

Category: This is about assessing third-party vendors' data protection practices. The central topic is vendor oversight → Third-Party Risk.

Specificity: Let me check for domain terms, firm-specific facts, or QV facts.
- "data protection practices" - general business language
- "third-party vendors" - general
- "sensitive information" - general
- "formal, documented process" - general

No domain terminology (fails ERM test - "assess data protection practices of vendors" could appear in any ERM context). No firm-specific facts. No QV facts.

This classifies as Level 1 specificity.


content_category: None/Other

reasoning: The paragraph is a generic commitment statement and risk acknowledgment with no substantive cybersecurity disclosure — no program activities, no roles, no oversight structure, no incident. The 'could negatively impact' language is speculation, not a materiality assessment, so it fails the SI test. All language (securing IT systems, cybersecurity threats, confidentiality/integrity) is general business vocabulary any non-security professional could write, with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Generic commitment to securing IT systems, recognition that cyber threats are ongoing, definition of cybersecurity threats. No specific measures, no program details, no roles, no incidents. Pure generic language.

Category: This doesn't answer any of the six substantive questions meaningfully. It's general risk acknowledgment language. "Could negatively impact our brand, business, results of operations and financial condition" is speculation ("could"), not a materiality assessment. No actual cybersecurity measures described. → None/Other

Specificity: No domain terminology (just generic "cybersecurity threats," "information technology systems"), no firm-specific facts, no QV facts.

This lands at Level 1 — the lowest tier of disclosure.


content_category: Risk Management Process

reasoning: The paragraph describes the company's cybersecurity program at a high level, answering 'what does the program do?' but only in the most generic terms. 'Confidentiality, integrity, and availability' is the CIA triad but expressed here as general business language rather than demonstrating domain expertise. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph acknowledges cybersecurity as important and lists generic threats but describes no actual cybersecurity measures, processes, oversight, or organizational details. The 'could materially adversely affect' language is speculation (every 10-K says this), not a materiality assessment, so it fails the SI test. No substantive disclosure → N/O. N/O always receives Specificity 1; while 'ransomware' and 'denial-of-service' are domain terms, the N/O override applies.

thinking:
Let me analyze this paragraph.

Content: Generic statement about cybersecurity importance, mentions threats (ransomware, denial-of-service), speculation about material adverse effects, statement about needing to spend on cybersecurity.

Category: The "could materially adversely affect" is speculation (every 10-K says this), not an assessment → NOT SI. No actual program described, no board oversight, no management roles. It's general risk language. But it does mention ransomware and denial-of-service as specific threat types...

Wait - does it describe any actual cybersecurity measure? "We believe cybersecurity is critical" - belief statement. "We face threats" - acknowledgment.

The "could materially adversely affect" language is pure speculation, and "make it imperative that we expend resources" describes intent rather than any concrete action or program. There's no substantive disclosure of actual cybersecurity measures here—just risk acknowledgment. Even though ransomware and denial-of-service are domain-specific terms, this is still N/O with Specificity 1.


reasoning: The paragraph describes the general regulatory environment (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. None/Other always receives Generic Boilerplate.

thinking:
Analyzing this paragraph from Five Star Bancorp's 10-K Item 1C.

The paragraph discusses regulatory context - financial privacy laws, federal banking agency oversight, SEC disclosure rules, and a cross-reference to another section. It doesn't answer any of the six substantive cybersecurity questions. It's describing the regulatory environment, not what the company does.

Category: None/Other - this is regulatory context and cross-references, no substantive cybersecurity disclosure.

Specificity: Level 1 (Generic Boilerplate) - N/O always gets Level 1.


fact: CIO holds primary responsibility for cybersecurity program

fact: more than 20 years of experience in information and operational technology

reasoning: The paragraph primarily answers 'how is management organized?' by establishing the CIO as the responsible leader, noting qualifications, and describing the IT team under their direction. Person-removal test: removing the CIO and team references leaves only generic language ('evaluates risk postures,' 'safeguards critical cyber assets'), so the paragraph collapses → MR. 'More than 20 years of experience' is a lower-bound quantified fact (verifiable: is experience ≥ 20?), elevating to Level 4.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the CIO's role and responsibility, then what the IT team does under their leadership. Person-removal test: Remove "CIO, with more than 20 years of experience" and "Under the CIO's leadership, the IT team" — what remains? "continuously evaluates risk postures and safeguards critical cyber assets... resilience against both common and sophisticated cyber threats." This is fairly generic risk management language. But the paragraph's primary focus is on establishing who holds responsibility (CIO) and their qualifications (20 years experience). The organizational structure (CIO leads IT team) is the frame.

So this is definitely MR — the substance is really about identifying the responsible party and their credentials. The specificity breaks down as: "CIO" is a firm-specific leadership role, "more than 20 years of experience" is a quantified and verifiable claim, while "IT team" is just generic terminology. That puts it at Level 4 because of the concrete experience metric.


reasoning: This paragraph is a cross-reference directing readers to Item 1A risk factors for additional information on cybersecurity risks. It contains no substantive cybersecurity disclosure — it merely points elsewhere. N/O always receives Specificity 1.


fact: vulnerability management

reasoning: The paragraph describes the oversight flow from management to the Audit Committee, answering 'how does the board oversee cybersecurity?' — a governance-chain paragraph defaulting to BG. The CEO mention is brief attribution, and the Audit Committee is the recipient of updates. 'Vulnerability management' is a cybersecurity domain term that passes the ERM test, elevating to Level 2; CEO and Audit Committee are generic roles present at every public company and do not qualify as firm-specific.

thinking:
Let me classify this paragraph.

Content: CEO directs cybersecurity programs. Management updates Audit Committee on cybersecurity programs including risks, mitigation, vulnerability management, and ongoing projects.

Category: This describes oversight flow - management reports TO the board (Audit Committee). The governance-chain pattern (Board → Committee → Officer → Program) defaults to BG when describing oversight structure. The paragraph answers "how does the board oversee cybersecurity?" - through Audit Committee updates from management.

Wait - let me reconsider. The paragraph has two parts: (1) CEO directs cybersecurity programs, (2) Management updates Audit Committee.

The primary question is really about how the board oversees cybersecurity through Audit Committee updates, with the CEO mention serving as brief context. The bulk of the content focuses on the reporting and oversight structure, so this is BG.

Looking at specificity: CEO and Audit Committee are generic governance roles present in every company, while vulnerability management is a domain-specific cybersecurity practice. The risks, mitigation strategies, and projects mentioned are all generic. This points to Level 2.


fact: IASME Cyber Essentials framework

type: framework

fact: UK government Cyber Security NCSC

fact: NIST framework

reasoning: The paragraph answers 'What does the cybersecurity program do?' by describing an annual IT security assessment approach and the frameworks/standards guiding their policies and controls — squarely RMP. Multiple named cybersecurity frameworks (IASME Cyber Essentials, ISO 27001, NIST) and the NCSC reference are domain terminology elevating to Level 2, but the company only claims alignment ('based on the understanding of'), not certification, so no QV-eligible fact is present.

thinking:
Classify this paragraph.

Content: Describes their cybersecurity program activities - annual IT security assessment, framework adoption (IASME Cyber Essentials, ISO 27001, NIST), policies and controls. This answers "What does the cybersecurity program do?" → RMP.

Specificity:
- "IASME Cyber Essentials framework" - named framework, domain terminology (Level 2)
- "UK government Cyber Security NCSC" - named external entity... this is a government body, could be Level 4 as a named external entity? Actually, it's describing that the framework is approved by NCSC - it's context about the framework, not a verifiable claim about the company. It's more like domain terminology.

- "ISO 27001" and "NIST framework" are domain terms (Level 2). They reference understanding of these standards rather than claiming actual certification, and mention following assessments without providing specific numbers, dates, or named firms conducting them. No firm-specific facts like named roles or committees either.

Level 2 - Domain-Adapted.


reasoning: Three of four sentences describe the information flow from monitoring → management → Audit Committee → Board, answering 'how does the board oversee cybersecurity?' The monitoring sentence sets the stage for the governance chain. No domain terminology passes the ERM test ('continuously monitored', 'cybersecurity incidents/breach' are general business language), 'Audit Committee' and 'Board of Directors' are not firm-specific per the codebook, 'internal cybersecurity team' is equivalent to the excluded 'dedicated cybersecurity team', and 'quarterly' is a generic cadence — yielding Level 1.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics: monitoring, incident notification, Audit Committee notification, and Board briefings. Let me determine the primary question it answers.

- "networks and systems are continuously monitored by a combination of third-party service providers and an internal cybersecurity team" — RMP (what the program does)
- "Management is promptly notified of cybersecurity incidents" — could be MR or BG
- "Audit Committee is promptly notified by our management of any material cybersecurity breach" — BG (oversight flow)
- "Board of Directors is briefed at least quarterly on the state of our cybersecurity program" — BG (board oversight)

- The core structure here is really about governance and information flow—monitoring feeds into management notification, which then escalates to the Audit Committee and Board. Three of the four sentences focus on this oversight chain, so the primary question is "How does the board oversee cybersecurity?" — BG. Looking at specificity, most of the details are generic: "continuously monitored," unnamed third-party providers, a generic internal team, and standard governance bodies that every company has. The quarterly cadence is also vague.

- Now I'm checking whether the language itself contains domain-specific terminology. "Cybersecurity breach" and "cybersecurity incidents" are used here, but these aren't really specialized terms—they're general business language. The codebook doesn't flag them as domain terminology, and the paragraph doesn't actually employ specialized cybersecurity jargon. There are no firm-specific facts either—no named roles like a CISO, no named committees beyond the standard Audit Committee. No quantitative or value facts either.

This is Level 1 boilerplate. The entire governance structure described here is generic and could apply to any company.


fact: Vice President of Information Technology Services

reasoning: The paragraph primarily answers how the board oversees cybersecurity—describing audit committee oversight, information flow from senior leadership to the board, and the board's risk oversight responsibility. The VP of Information Technology Services is mentioned as leading the program but is subordinate to the governance-chain description. The VP-level IT title qualifies as firm-specific, but no domain terminology or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Category: The paragraph answers "How does the board oversee cybersecurity?" - it describes the audit committee's oversight, how information flows to the board, and the board's responsibility for overseeing cybersecurity risks. There's a mention of "vice president of information technology services" but the primary content is about oversight structure. → Board Governance

Specificity: Let me scan for facts:
- "vice president of information technology services" — VP-level title with IT portfolio → firm-specific
- "audit committee" — every public company has one, NOT firm-specific
- No domain terminology beyond generic risk/oversight language

- No QV facts present

This lands at Level 3 because of the VP of IT Services reference.


fact: Cyber Risk Committee comprised of CIO and other executive officers

fact: CIO role overseeing cybersecurity

fact: virtual Chief Information Security Officer (third-party)

fact: more than twenty years of experience as an information technology professional

fact: CIO since 2007

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — describing the Cyber Risk Committee composition, CIO's role and responsibilities, qualifications, and reporting relationships. Person-removal test leaves little substance. Specificity reaches Level 4 via 'more than twenty years of experience' (verifiable lower bound) and 'CIO since 2007' (specific year tied to a cybersecurity role).

thinking:
Let me analyze this paragraph.

Content: The paragraph describes governance and management structure for cybersecurity at this fund. It mentions no board/committees of its own, relies on Manager's senior management, has a Cyber Risk Committee (CIO + executive officers), CIO's role and experience, and a virtual CISO relationship.

Category: This is primarily about how management is organized to handle cybersecurity. It describes the CIO's role, the Cyber Risk Committee composition, reporting lines, and qualifications. Person-removal test: remove CIO, titles, experience, committee membership → very little remains. This is MR.

Now I'm evaluating the specificity of the details provided. The Cyber Risk Committee is a named, firm-specific committee rather than a generic governance structure, and the CIO's tenure since 2007 plus more than twenty years of experience are concrete, verifiable facts tied to a cybersecurity-relevant role. The virtual CISO arrangement is also firm-specific, though the third-party provider itself remains unnamed.


reasoning: The first sentence states a backward-looking and forward-looking materiality conclusion ('have not materially affected... are not reasonably likely to materially affect'), which is the SEC's Item 106(b)(2) language → SI. The remainder is generic speculation ('cannot eliminate all risks') and a cross-reference to Item 1A, neither of which changes the category. No domain terminology, firm-specific facts, or verifiable claims are present — all language is boilerplate materiality assessment phrasing found in countless filings.

thinking: Materiality assessment paragraph.


fact: ransomware

reasoning: The opening sentence states a backward-looking materiality conclusion ('no cybersecurity incidents have materially impacted the Company, including the Company's business strategy, results of operations, or financial conditions'), which is a materiality assessment → SI per Rule 5. The remainder is speculative risk language ('could be material') that does not override the assessment. 'Ransomware' is a specific threat type (domain terminology) elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Starts with "To date, no cybersecurity incidents have materially impacted the Company" - this is a materiality assessment (SI). Then discusses risks, third-party reliance, and limitations of controls - this is speculative/generic risk language.

The first sentence is a backward-looking materiality assessment → SI. The rest is speculation ("could be material", "may not be high"). Per Rule 5, the first sentence IS an assessment stating a conclusion about materiality.

Category: Strategy Integration - the paragraph opens with a materiality conclusion, and while much of the rest is speculative risk language, the primary question answered is "how does cybersecurity affect the business?"

Now scanning for specific details. The paragraph mentions "ransomware" as a concrete threat type, which gives it some domain specificity, but most other language is generic—"encrypt systems," "third-party software," "risk-based approach," "security controls," and "critical information systems infrastructure assets" are all standard boilerplate. The negative self-assertion about no incidents isn't verifiable. Based on the ransomware reference alone, this lands at Level 2 specificity.


fact: penetration testing

fact: vulnerability scanning

reasoning: The paragraph describes cybersecurity program activities — workforce training, penetration testing, vulnerability scanning, and remediation — answering 'what does the program do?' Third-party providers serve the company's own program (Rule 3 → RMP). Domain terms 'penetration testing' and 'vulnerability scanning' elevate to Level 2, but no firm-specific or verifiable facts are present (third-party providers are unnamed, no specific numbers or dates).

thinking:
Let me classify this paragraph.

Content: Describes training, penetration testing, vulnerability scanning, and remediation processes.

Category: "What does the cybersecurity program do?" → RMP. Third parties are mentioned but serve the company's program (Rule 3 → RMP).

Specificity: Domain terms include "penetration testing" and "vulnerability scanning." No firm-specific facts (no named roles above VP, no named committees). No QV facts (no specific numbers, dates, named firms). → Level 2.


fact: Information Technology Committee

fact: Chief Information Security Officer (CISO)

fact: penetration test results

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the governance chain: Board → Information Technology Committee → CISO, including briefing scope and frequency. While it details what the IT Committee reviews (controls, procedures), the purpose is describing the oversight structure, making it BG. Specificity reaches Level 3 via the named Information Technology Committee and CISO role; 'penetration test results' is a domain term but the firm-specific facts set the floor. No QV-eligible facts (no specific numbers, dates, named external entities, or certifications).

thinking:
Let me analyze this paragraph.

Category: This describes board oversight structure - the Board's role, the Information Technology Committee's review responsibilities, and how information flows from CISO to the committee and board. The governance-chain (Board → IT Committee → CISO) is the primary structure. Even though there's detail about what the IT Committee reviews (controls, procedures), the purpose is describing the oversight structure. → Board Governance

Specificity: Let me scan for facts:
- "Information Technology Committee" — named non-generic committee → firm-specific
- "CISO" — cybersecurity leadership role → firm-specific

- "penetration testing" and "penetration test results" are domain terms, not quantifiable facts
- "at least quarterly" is a generic cadence, not a specific date or number
- "cyberattacks, unauthorized access" are standard threat categories

No quantifiable facts present. The specificity comes from the named committee and CISO role.

Level 3 — Firm-Specific due to the Information Technology Committee and CISO.


reasoning: The paragraph describes third-party cybersecurity partners and consultants as part of the company's risk management strategy; per Rule 3, third parties hired to serve the company's own program → RMP. However, the language is entirely generic — 'cybersecurity risk management strategy,' 'industry recognized cybersecurity providers,' 'cyber risk advisory' — all fail the ERM test and contain no domain terminology, no firm-specific facts (providers are unnamed), and no verifiable claims, leaving this at Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes third-party cybersecurity partners/consultants as part of the company's risk management. These are third parties hired to serve the company (assessors, consultants) → RMP per Rule 3.

Wait - but this is Breeze Holdings Acquisition Corp, which is a SPAC. Let me check the N/O rule for SPACs: "SPACs and no-operations companies with no cybersecurity program receive N/O regardless of incidental mentions of board oversight or risk acknowledgment."

However, this paragraph does describe something - partnering with cybersecurity providers.

The language here is extremely vague and generic. Even though they mention having cybersecurity partners and providers as part of their strategy, it reads more like boilerplate than an actual program. Given the SPAC rule about no real program, this probably qualifies for N/O despite the mention of external partners. The paragraph describes third-party cybersecurity partners as part of the company's risk management strategy, which qualifies as RMP under Rule 3. However, the language is extremely generic—no domain terminology, no specific firm details, just vague references to "industry recognized cybersecurity providers" and "cyber risk advisory"—so this lands at Specificity Level 1.


reasoning: The paragraph contains no substantive cybersecurity disclosure — it merely states that management and the board intend to meet periodically to assess an unspecified 'fluid situation,' with no cybersecurity-specific content, measures, or oversight details. No domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

This is from WORLDS INC, a very small company. The paragraph says management and board intend to meet periodically to assess adequacy of current status and determine if additional steps are needed. This is vague, generic language with no substantive cybersecurity disclosure.

Category: This could be BG (board oversight) but it's extremely generic - no actual cybersecurity content. It mentions "management and the board of directors" meeting periodically, but doesn't describe any cybersecurity program, measures, or oversight structure. It's more of a generic forward-looking statement. Given the N/O threshold rule - no substantive cybersecurity disclosure here.

The language is too vague to qualify as board governance—it's just a commitment to meet and assess things without any cybersecurity specifics. The lack of domain terminology or concrete details puts this at Specificity Level 1, making it N/O.


fact: Technology Committee of the Board

fact: Information Security Policy (named governing policy)

reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — describing the Board's responsibility for the information security program and the Technology Committee's role in approving policies, overseeing mitigation plans, and engaging in risk assessments. The Technology Committee is a named non-generic board-level committee (not every company has one), elevating specificity to Level 3, but no quantified-verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity program, Technology Committee approves policies, oversees mitigation plans, monitors implementation, engages in risk assessments.

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

Specificity:
- "Technology Committee" - named non-generic committee → firm-specific (Level 3)
- "Information Security Policy" - named internal program with distinguishing identifier → firm-specific
- The rest is general governance language

No QV facts. Level 3.


fact: System and Organization Controls reports (SOC reports)

reasoning: The paragraph's central topic is oversight of third-party service providers' cybersecurity—evaluating vendors prior to engagement and requesting SOC reports—directly answering 'how are third-party cyber risks managed?' The mention of 'System and Organization Controls reports' (SOC reports) is domain terminology that passes the ERM test, elevating to Level 2, but there are no firm-specific or verifiable facts to push higher.

thinking:
Let me classify this paragraph.

Content: About third-party risk management - evaluating third parties, requesting SOC reports from vendors.

Category: Third-Party Risk (TP) - the central topic is oversight of external parties' cybersecurity. Requirements imposed ON vendors and assessment of vendor cybersecurity posture.

Specificity: "System and Organization Controls reports" = SOC reports = domain terminology (Level 2). This is a specific cybersecurity/audit term that passes the ERM test.

No firm-specific facts, no QV facts.


reasoning: The paragraph opens with a backward-looking materiality assessment ('have not experienced a cybersecurity threat or incident that materially affected our business strategy, results of operations, or financial condition'), which is an SI conclusion per Rule 5, even though the remainder is speculation and a cross-reference to Item 1A. No domain terminology, firm-specific facts, or verifiable claims are present—the negative assertion about no material incidents is a self-reported claim about absence (not externally verifiable), and the filing date is generic reporting context—so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: States no material cybersecurity incidents have occurred (backward-looking materiality assessment), then speculates about future incidents, then cross-references Item 1A risk factors.

Category: The first clause is a materiality assessment - "have not experienced a cybersecurity threat or incident that materially affected our business strategy, results of operations, or financial condition" → SI per Rule 5. The second part is speculation ("there can be no guarantee") and a cross-reference to Item 1A. The materiality assessment is the substantive content here → SI.

Specificity: "Have not experienced...

The negative assertion about not experiencing material cybersecurity incidents isn't externally verifiable—it's a self-assessment. The date reference is just standard reporting boilerplate, and while the cross-reference points to a specific risk factor title, that's not a cybersecurity fact itself. There are no domain-specific terms, firm-specific details, or quantifiable facts here → Level 1.


fact: Cybersecurity Committee

fact: ten years of cybersecurity experience

fact: thirty-five years of experience in various technology domains

reasoning: The paragraph answers 'how is management organized?' — it identifies who is responsible (executives, IT management, Cybersecurity Committee) and details a senior IT executive's qualifications and experience. Person-removal test: removing roles and qualifications leaves only generic statements about policies and processes, confirming MR. Specificity reaches Level 4 due to specific verifiable numbers: 'ten years of cybersecurity experience' and 'thirty-five years of experience.'

thinking:
Let me analyze this paragraph.

Content: Describes management's role in cybersecurity - executives, IT management, Cybersecurity Committee responsibilities, and a senior IT executive's qualifications.

Category: This is about how management is organized to handle cybersecurity. The primary question answered is "How is management organized to handle cybersecurity?" The paragraph describes who is responsible (executives, IT management, Cybersecurity Committee), what they oversee, and the qualifications of the senior IT executive. Person-removal test: remove titles, qualifications, committee membership → very little substantive program description remains. → MR

The specificity here pushes this to Level 4 - there are concrete numbers like specific years of experience for key personnel, and the Cybersecurity Committee is named rather than generic, indicating firm-specific governance structures.


content_category: Incident Disclosure

fact: malware (non-self-propagating type deployed by attacker)

fact: Forensic investigation completed on December 13, 2023

fact: Last confirmed unauthorized activity on November 20, 2023

reasoning: The paragraph describes actual incident events — unauthorized access, malware deployment, data exfiltration, forensic investigation findings, and scope of impact — squarely answering 'what happened?' Two specific dates (December 13, 2023 and November 20, 2023) tied to incident milestones are independently verifiable facts, driving specificity to Level 4.

thinking:
Incident Disclosure - describes what happened in an actual cybersecurity incident.

Specific facts: December 13, 2023 (specific date), November 20, 2023 (specific date), malware (domain term), "unauthorized third-party accessed certain of our systems" (incident detail), "exfiltrated certain data" (incident detail).

Level 4 - specific dates.


fact: ransomware attack

fact: May 2020 - specific date of the ransomware attack

reasoning: The paragraph primarily describes an actual cybersecurity incident — a ransomware attack in May 2020 involving data exfiltration from a self-hosted environment — and its ongoing legal aftermath, answering 'what happened?' Per Rule 4, the incident frame dominates over the legal/financial consequences. Specificity reaches Level 4 because 'May 2020' is a specific date tied to a verifiable cybersecurity event, and 'ransomware' is domain terminology.

thinking:
Let me analyze this paragraph.

Content: Discusses a specific ransomware attack in May 2020, mentions ongoing legal proceedings, and cross-references financial statements for more details about the incident's impact.

Category: This describes an actual cybersecurity incident (ransomware attack, May 2020, data exfiltration) and its aftermath (legal proceedings). The primary question answered is "What happened in a cybersecurity incident?" → Incident Disclosure.

Though there's some strategy/financial impact language (legal proceedings, adverse judgments), the incident frame dominates per Rule 4.

Specificity:
- "ransomware attack" → domain_term (Level 2)

- "May 2020" → specific_date (Level 4)

The incident is specific and dated, so this lands at Level 4.


reasoning: This paragraph describes general IT dependency without any substantive cybersecurity disclosure — no measures, processes, or assessments are described. It uses only generic business language ('systems, networks and technology', 'contractors, consultants, vendors') that any company could state, yielding Level 1.


fact: System and Organization Control reports (SOC reports)

fact: ISIRP (Information Security Incident Response Plan) — named internal program with distinguishing identifier

specificity_confidence: medium

reasoning: The paragraph's central topic is managing third-party cybersecurity risks — due diligence, contractual covenants, vendor monitoring, and SOC report reviews — making TP the clear category. SOC reports provide domain terminology (Level 2), and 'ISIRP' is a named internal program with a distinguishing acronym elevating to Level 3, though no externally verifiable quantified facts are present.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party cybersecurity risk management - due diligence, data protection covenants, vendor management program, SOC reports, risk-based reassessment.

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

Specificity:
- "ISIRP" - named internal program with distinguishing identifier → firm-specific
- "System and Organization Control reports" (SOC reports) → domain terminology

- Most other terms like data protection covenants, vendor management program, and annual reassessment cadence are generic industry language, but ISIRP stands out as the most specific identifier, making this Level 3 firm-specific overall.


reasoning: This paragraph is pure speculation about what 'could' happen — it states no materiality conclusion, describes no actual program activities, and contains no cybersecurity domain terminology. It fails the SI test ('could materially impact' is speculation every 10-K includes, not an assessment), and there are no substantive cybersecurity measures described, so it falls to N/O.


fact: Head of Resources Management role overseeing cybersecurity

fact: CCO (Chief Compliance Officer) involved in cybersecurity management

fact: More than 30 years of overall experience (Head of Resources Management)

fact: More than 20 years directly assessing and managing cyber information technology

fact: CCO has more than 30 years of overall experience

fact: CPA certification held by CCO

fact: More than 15 years managing information technology systems and databases

fact: 15-plus years supporting Adviser's and Administrator's resource management department

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' by detailing the Head of Resources Management and CCO roles, their qualifications, and years of experience. The person-removal test leaves almost nothing substantive. Multiple specific experience durations (30+, 20+, 15+ years) and the CPA certification are independently verifiable, driving Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes management personnel involved in cybersecurity - Head of Resources Management and CCO, their experience levels, qualifications, and also mentions Board receiving updates.

Category: The primary content is about who manages cybersecurity and their qualifications. Person-removal test: remove titles, experience, qualifications - very little remains. This is MR.

But there's a sentence about the Board at the end. The bulk is about management roles and qualifications → MR.

Specificity:
- "Head of Resources Management" - this is a named role, firm-specific

- "CCO" - Chief Compliance Officer, though not cybersecurity-specific, is being described in this context as managing cyber
- Multiple quantified experience metrics across the team: over 30 years overall, 20+ years in cyber IT specifically, 15+ years in IT systems management, plus a CPA certification - all verifiable facts → Level 4.


fact: CISO

fact: joined Workday in 2010

fact: served as CISO since April 2018

fact: more than 15 years of experience in cybersecurity and information technology risk management

reasoning: The paragraph primarily answers 'how is management organized?' by detailing the CISO's responsibilities, tenure, and qualifications. Person-removal leaves only a generic sentence. Specificity is Level 4 due to multiple verifiable facts: specific dates (joined 2010, CISO since April 2018) and a quantified lower-bound experience claim (more than 15 years).

thinking:
Let me analyze this paragraph.

Category: This is about the CISO's role, qualifications, and experience. Person-removal test: remove CISO, joined 2010, April 2018, 15 years experience, degree — what remains? "leads all aspects of our global cybersecurity program, including the identification, evaluation, and prioritization of security risks, as well as the company's response to material security incidents." That's fairly generic program description but not very substantive on its own. The bulk of the paragraph is about the person. → MR

Now I'm checking the specificity of each claim: the CISO title is firm-specific, the 2010 and April 2018 dates are quantifiable, the 15+ years of experience is a lower bound that's verifiable, and the degree in information systems management lacks external verification without the institution name. That puts this at Level 4.


fact: Steering Committee (named non-generic committee that receives updates FROM management, indicating board-level oversight body)

reasoning: The paragraph describes how the Steering Committee oversees cybersecurity — monitoring program quality, receiving updates from management, and reviewing policies. The phrase 'receives regular updates from management' indicates the committee sits above management, fitting the board-oversight pattern (BG). The content is governance/oversight activity (monitoring, reviewing, receiving reports), not program operations. The named 'Steering Committee' is a non-generic committee (not Audit Committee), qualifying as firm-specific (Level 3), but the remaining language — prevention/detection/mitigation, third-party assessments, incident response plan — is general business vocabulary that doesn't pass the ERM test for domain terminology.

thinking:
Let me analyze this paragraph.

Content category: The paragraph is about the "Steering Committee" monitoring the cybersecurity program. The question is whether this is BG, MR, or RMP.

The "Steering Committee" - is this a board-level or management-level committee? It's not called "Board Steering Committee" or "Audit Committee." It says it "receives regular updates from management" - this suggests it's separate from management, possibly board-level. But "Steering Committee" without more context is ambiguous.

Actually, re-reading: "receives regular updates from management on cybersecurity initiatives" - this suggests the Steering Committee is above management, which could make it board-level. But "Steering Committee" is often a management-level committee too.

The paragraph focuses on what the committee does—monitoring program quality, receiving updates, and reviewing policies—which are oversight activities. Since "Steering Committee" without a "Board" qualifier typically indicates a management-level body, and the content describes activities rather than structure, this leans toward MR based on the rule that management committees performing oversight activities fall into that category.

But applying the person-removal test clarifies things: stripping out the committee references leaves mostly descriptions of what gets monitored and reviewed, not standalone program descriptions. The program details are secondary to the oversight function itself, which confirms this is about the committee's oversight role rather than the program itself.

Given that a Steering Committee is typically management-level and the content focuses on its oversight activities—monitoring quality, receiving updates, reviewing policies—MR fits better than RMP. Though there's some ambiguity since the committee receives updates from management, which could suggest it's board-level, making BG a possibility. I'll lean toward MR but note the uncertainty.

For specificity, "Steering Committee" is a named non-generic committee specific to this firm, so that's Level 3. The other elements—incident response plan, prevention/detection/mitigation language, third-party assessments, and cybersecurity framework—are all generic terminology, so they don't push the specificity higher.


fact: August 2021 cybersecurity incident

fact: January 2023 cybersecurity incident

reasoning: The paragraph references two actual incidents but its dominant frame is business/financial impact — lawsuits, costs, insurance coverage limits, and material adverse effect on financial condition and operations — making the primary question 'how does cybersecurity affect the business?' (SI). Per Rule 4, mixed incident-and-impact paragraphs where the financial frame dominates → SI. Specificity reaches Level 4 because 'August 2021' and 'January 2023' are specific dates tied to real cybersecurity events that are independently verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the impact of two actual cybersecurity incidents (August 2021 and January 2023), their resulting lawsuits, financial costs, and references additional details elsewhere.

Category: This is about the business/financial impact of cybersecurity incidents - lawsuits, costs, insurance, material adverse effects. Per Rule 4, "Business/financial impact of an incident → SI" and "Mixed with financial frame dominant → SI." The paragraph's primary question is "How does cybersecurity affect the business or finances?" The incidents are referenced but the frame is about financial/business impact (lawsuits, costs, insurance, material adverse effect).

The financial impact frame is definitely dominant here - the specific incidents serve as evidence for the broader business consequences. Both dates are tied to verifiable real events, which pushes this toward higher specificity. This lands at Level 4.


fact: monitoring and rating services (vendor security rating)

fact: posture and intelligence reviews of vendors

reasoning: The paragraph's central topic is how third-party/vendor cyber risks are managed — requirements imposed on vendors, security evaluations of critical vendors, and embedding cyber controls in SLAs — making it TP. Domain terminology like 'open-source intelligence risk assessments,' 'monitoring and rating services,' and 'posture and intelligence reviews' demonstrate cybersecurity expertise beyond generic ERM language, but no firm-specific or verifiable facts are present.

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

Facts:
- "monitoring and rating services" - generic
- "open-source intelligence risk assessments" - this is domain terminology (OSINT)
- "posture and intelligence reviews" - domain-ish
- "cybersecurity teams" - not firm-specific (generic)
- "service level agreements" with cyber controls embedded - this is about requirements imposed on vendors

This is TP - the central topic is oversight of external parties' cybersecurity.

For specificity: "open-source intelligence risk assessments" (OSINT) is domain terminology. "Posture reviews" could be domain.

The "monitoring and rating services" phrase is likely referring to vendor security rating platforms like BitSight or SecurityScorecard, which brings it into domain-specific language. This pushes the overall content to Level 2 - domain-adapted, using terminology like OSINT risk assessments and security rating services alongside the third-party oversight framework.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the Board's recognition of cybersecurity importance and delegation to the Audit Committee for risk oversight. All entities mentioned (Board of Directors, Audit Committee) exist at every public company, no domain terminology is used, and no firm-specific or verifiable facts are present — entirely generic governance language.

thinking:
Let me classify this paragraph.

Content: Board oversight of cybersecurity risk, delegation to Audit Committee.

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

Specificity: Let me scan for facts.
- "Board of Directors" - not firm-specific (every company has one)
- "Audit Committee" - not firm-specific (every public company has one)
- No domain terminology - "information security," "cybersecurity," "data security threats" are general
- No QV facts
- No firm-specific facts

- This is generic board oversight language, so it's Level 1.


fact: management committee on cybersecurity

reasoning: The paragraph is structured around who oversees cybersecurity and how responsibilities are divided — the Senior Director and Head of IT's role, their relationship to the management committee on cybersecurity, and what they monitor. Person-removal test: removing the role and committee leaves only generic activity descriptions ('oversee policies and processes,' 'monitors prevention, detection, mitigation'), confirming MR. 'Senior Director and Head of Information Technology' is a director-level IT title without a security qualifier (not firm-specific per codebook), but 'management committee on cybersecurity' is a named non-generic committee elevating to Level 3.

thinking:
Let me analyze this paragraph.

Content: Describes management's role in cybersecurity - Senior Director and Head of IT oversees policies/processes, monitors prevention/detection/mitigation/remediation, leads implementation of cybersecurity risk management program, works with security team, provides updates to management committee on cybersecurity.

Category: This is about how management is organized to handle cybersecurity. The person-removal test: remove "Senior Director and Head of Information Technology" and "management committee on cybersecurity" - what remains? "oversee cybersecurity policies and processes", "monitors prevention, detection, mitigation, and remediation", "leading the implementation of the cybersecurity risk management program", "working directly with our security team", "provides appropriate information and updates." The program description is fairly generic.

The core of this is really about the person's responsibilities and their relationship with the committee rather than generic processes. "Senior Director and Head of Information Technology" lacks a security-specific qualifier, so that's not firm-specific, but "management committee on cybersecurity" is a named committee that's firm-specific. I'm also noticing the domain terminology around prevention, detection, mitigation, and remediation.


reasoning: The paragraph describes a management person's role and qualifications — person-removal test leaves nothing substantive, confirming MR. '25 years of experience' is a specific number verifiable against a resume, elevating to Level 4. Note: 'Head of Information Technology' is a general IT title (NOT firm-specific per codebook), but the quantified experience claim independently drives specificity.

thinking:
Let me classify this paragraph.

Content: "Our Head of Information Technology for Latin America, who oversees Cybersecurity, has 25 years of experience in strategic IT leadership and global project management."

Category: This is about a management person's role and qualifications. Person-removal test: remove "Head of Information Technology for Latin America" and "25 years of experience in strategic IT leadership and global project management" → nothing remains. This is MR.

Specificity:
- "Head of Information Technology for Latin America" — this is an IT title. Per the codebook, "Head of IT" is NOT firm-specific.

The regional qualifier "for Latin America" and the cybersecurity oversight detail the organizational structure, but the base title "Head of IT" is still a general IT role, not a cybersecurity-specific position. The "who oversees Cybersecurity" describes responsibilities rather than a dedicated cybersecurity title.

- "25 years of experience" — this is a specific, verifiable number that can be checked against a resume.

So Level 4.


fact: Internal Vulnerability Reports

fact: Cybersecurity Risk Assessment

fact: IT Risk Assessment, Annual IT Program Status Report, Vendor Management Risk Assessment, Quarterly Internal Vulnerability Reports, Cyber Events briefings — named specific reports the Committee receives

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing a board-level committee's oversight responsibilities, the reports it receives, and its decision-making role — classic Board Governance. The Risk Management Committee of the Board is a named non-generic committee (firm-specific, Level 3), and the paragraph includes domain terms like 'Vulnerability Reports' and 'Cybersecurity Risk Assessment,' but no QV-eligible facts such as specific numbers, dates, or named external entities.

thinking:
Let me classify this paragraph.

Content: Describes the Risk Management Committee of the Board overseeing cybersecurity risks, receiving various reports, and making decisions.

Category: This answers "How does the board oversee cybersecurity?" — Board Governance. The Risk Management Committee is a board-level committee.

Specificity: Let me scan for facts:
- "Risk Management Committee of the Board of Directors" — this is a board-level committee, but is it firm-specific? It's not "Audit Committee" which every company has. A "Risk Management Committee" is somewhat common but not universal. I'd say it's firm-specific as a named non-generic committee.

- The reports mentioned—IT Risk Assessment, Cybersecurity Risk Assessment, Annual IT Program Status Report, Vendor Management Risk Assessment, Quarterly Internal Vulnerability Reports—are specific named reports, with "vulnerability" and "vulnerability management" being domain-specific cybersecurity terminology. "Cyber Events briefings" also fits within domain language.

- The "Risk Management Committee of the Board" is a named, firm-specific governance structure that not all companies maintain at the board level, which signals Level 3 classification.

- There are no QV facts present—no specific numbers, dates, named external entities, or certifications—so this confirms Level 3.


reasoning: The paragraph states two materiality conclusions — a backward-looking assessment ('not aware of any cyber incidents that have been material') and a forward-looking assessment ('do not believe risks are reasonably likely to materially affect') — making it SI per the materiality assessment rule. The cross-reference to Item 1A is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present; the negative assertions about no material incidents are not externally verifiable, and all language is standard boilerplate.

thinking:
Let me analyze this paragraph.

Content: This paragraph makes materiality assessments (backward-looking and forward-looking) and includes a cross-reference to Item 1A.

Category: The paragraph states conclusions about materiality - "not aware of any cyber incidents that have been material" (backward-looking) and "do not believe risks are reasonably likely to materially affect" (forward-looking). Per Rule 5, these are materiality assessments → Strategy Integration. The cross-reference to Item 1A is subordinate.

Specificity: Let me scan for facts:
- "not aware of any cyber incidents that have been material" — negative self-assertion, not verifiable

- "not reasonably likely to materially affect" — assessment language, boilerplate
- Cross-reference to Item 1A — not a specific fact
- No domain terminology, no firm-specific facts, no QV facts

This is boilerplate materiality language. Level 1.


reasoning: This paragraph is a generic company introduction mentioning commitment to a 'reliable and secure trading environment' without any substantive cybersecurity disclosure — no program details, governance structure, or specific measures. It answers none of the six substantive questions, so N/O at Level 1.


fact: Specific department composition for cybersecurity communications: legal, operations, information technology, and/or compliance personnel

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — it identifies who is responsible (COO, CCO), describes their general expertise areas, and explains how management stays informed. Person-removal test collapses most substance. COO and CCO are generic executive roles (not cybersecurity-specific titles), but the explicit listing of departments involved (legal, operations, IT, compliance) constitutes a firm-specific team composition detail, elevating to Level 3.

thinking:
Let me analyze this paragraph.

Category: This is about management's role - who is responsible (COO, CCO), their expertise areas, and how they stay informed. The person-removal test: remove COO, CCO, management references, expertise claims → "monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents, including through the receipt of notifications from service providers and reliance on communications with legal, operations, information technology, and/or compliance personnel." Some process description remains but it's thin - it's about how management stays informed, not what the program does. The primary question answered is "How is management organized to handle cybersecurity?" → MR.

Now I'm checking the specificity of these elements. The COO and CCO are generic executive titles, not firm-specific. The expertise areas listed—information systems technology, regulatory compliance, corporate governance—are standard competencies. The departments mentioned (legal, operations, IT, compliance) form a specific team composition, which the codebook distinguishes from vague phrases like "cross-functional team," so this counts as specific.

There's no domain-specific terminology beyond generic risk language like "prevention, detection, mitigation, and remediation." No frameworks or security tools are referenced. Based on the specific departmental composition, this lands at Level 3.


fact: Chief Technology Officer

fact: Executive Vice President – Operations

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' by describing reporting lines (CTO → EVP-Operations), incident escalation paths (to legal department), and a qualifications assessment of the team. Person-removal test confirms MR: removing roles, reporting lines, and qualifications leaves no substantive content. CTO is a firm-specific cybersecurity leadership role; EVP-Operations is a named role in the reporting chain. No QV-eligible facts (no specific numbers, dates, certifications, or named external entities).

thinking:
Let me analyze this paragraph.

Content: Describes CTO reporting to EVP-Operations, incident reporting to legal, and qualifications assessment of the technology team.

Category: This is about management organization - reporting lines, roles, responsibilities, qualifications assessment. Person-removal test: remove CTO, EVP-Operations, legal department, technology services team → almost nothing remains. → MR

Specificity:
- CTO (Chief Technology Officer) → firm-specific cybersecurity leadership role at VP+ level
- EVP – Operations → not a cybersecurity-specific title

- "legal department" → not firm-specific
- No domain terminology, no QV facts

So the CTO gets a Level 3 designation for being a firm-specific executive role, while the other elements don't meet the specificity threshold.


reasoning: The paragraph answers 'How does the board oversee cybersecurity?' by describing delegation from the Board to the Audit Committee and periodic management reporting — a classic BG paragraph. All elements (Board of Directors, Audit Committee, management, periodic reports) are generic governance structures found at every public company, with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: This answers "How does the board oversee cybersecurity?" — Board delegates to Audit Committee, Committee receives reports from management. This is BG.

Specificity: Let me scan for facts.
- "Board of Directors" — not firm-specific (every company has one)
- "Audit Committee" — not firm-specific (every public company has one)
- "management" — generic
- "periodic reports" — generic cadence
- "cybersecurity incidents" — not domain terminology per se, just general

No domain terminology that passes the ERM test.

The paragraph contains no firm-specific facts or QV facts, so this is Level 1.


reasoning: This is a cross-reference to Item 1A Risk Factors with speculative 'could materially and adversely affect' language — it points elsewhere rather than making a substantive cybersecurity disclosure. No domain terminology, firm-specific facts, or verifiable claims.


reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' by describing the division of responsibilities between internal management and an external IT specialist, and enumerating management's areas of responsibility (resource allocation, incident response planning, strategic integration, periodic evaluation). Person-removal test: removing 'management team' and 'internal leadership' leaves generic activity descriptions, but the paragraph's primary purpose is establishing the organizational division of labor rather than describing program mechanics. No domain terminology passes the ERM test ('incident response planning,' 'business continuity,' and 'risk management framework' are all general business language), no firm-specific facts (no named roles at VP+ level, no named committees, 'external IT specialist' is unnamed), and no QV-eligible facts.

thinking:
Let me analyze this paragraph.

Content Category: This answers "How is management organized to handle cybersecurity?" - it describes management's role and responsibilities. But let me apply the person-removal test. Remove person-specific content (names, titles, qualifications, etc.) - there are no specific titles, names, or qualifications here. The paragraph talks about "management team" generically. What remains? Descriptions of responsibilities: overseeing cybersecurity risk, maintaining responsibility for risk management framework, resource allocation, incident response planning, strategic integration, evaluating effectiveness, ensuring alignment with business continuity.

Actually, this is about management's role and responsibilities but uses very generic language.

The paragraph doesn't specify individual titles like CISO or CTO, so it's describing the management function itself rather than particular people. When I strip away the generic references to "management team" and "internal leadership," what's left are the actual activities and responsibilities - evaluating programs, maintaining frameworks, allocating resources, coordinating with external IT specialists. The core content is about how management's role is structured to handle cybersecurity, particularly the division of labor where external IT handles day-to-day technical work while internal management oversees the overall framework and strategic alignment. This is clearly MR - it's answering the organizational question about management's responsibilities and how they coordinate with external resources. The paragraph doesn't use domain-specific terminology—"incident response planning" and "business continuity" are general business language, not cybersecurity expertise. There are no firm-specific facts or named roles, so this is clearly Level 1 generic boilerplate. The framing centers on management's organizational responsibilities and how they coordinate with external IT, which points to MR rather than RMP.


reasoning: This paragraph is primarily risk-factor language describing potential threats and consequences ('could have a material adverse effect on our business'), ending with a cross-reference to Item 1A Risk Factors. While it mentions 'ransomware' and 'phishing attacks' as threat types and briefly notes the company monitors its networks, the overwhelming frame is speculative risk disclosure (what COULD happen), not a substantive description of the cybersecurity program. Per the codebook, 'could have a material adverse effect' is speculation every 10-K includes, and cross-references pointing elsewhere are N/O. None/Other always receives Specificity 1.

thinking:
Let me analyze this paragraph.

Content: Generic risk language about IT dependence, data storage, cyber threats, and potential impacts. Mentions ransomware and phishing as threats. Ends with "could have a material adverse effect" (speculation) and a cross-reference to Item 1A.

Category: This doesn't really answer any of the six substantive questions. It's general risk language about cybersecurity threats and potential consequences. "Could have a material adverse effect" is speculation, not an assessment. The cross-reference to Item 1A points elsewhere. There's mention of monitoring/developing IT networks, but it's very generic. Let me check - "We continuously monitor and develop our information technology networks and infrastructure to help prevent, detect, address and mitigate the risk of unauthorized access, misuse, computer viruses, and other events that could have a security impact." This is generic risk language.

The paragraph frames itself as a risk disclosure rather than a program description—it's focused on what could go wrong rather than what the company actually does to address it. While there's a sentence about monitoring and developing IT infrastructure, it's buried in a larger risk-factor context and lacks specificity about actual cybersecurity measures or governance. This reads more like N/O territory since the dominant narrative is about potential consequences rather than substantive program details. The specific threat types like ransomware and phishing push toward RMP, but the monitoring language is too vague to carry real weight—it's just boilerplate about developing infrastructure. The paragraph is fundamentally structured around risk speculation and consequences rather than describing an actual program, so this lands as N/O with Specificity 1.


fact: Risk Committee of the Board of Directors provides oversight for cybersecurity

reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the Board's primary risk oversight responsibility and delegating cybersecurity oversight to the Risk Committee of the Board. While management is mentioned first, it serves as framing for the board oversight structure. The Risk Committee of the Board of Directors is a named non-generic board-level committee (distinct from the generic Audit Committee), making it firm-specific at Level 3.


reasoning: The paragraph states no incidents have occurred (without materiality framing), admits the absence of a formalized cybersecurity framework, then offers generic speculation about potential impacts ('could potentially lead to...'). No substantive cybersecurity measures, oversight, or program are described — this resembles the no-program pattern where the company effectively has nothing to disclose. The speculative language ('could potentially lead to unauthorized access...disrupt our business operations...regulatory fines') is the generic risk language every 10-K contains, which the codebook explicitly excludes from SI. Without materiality framing on the negative incident claim and with no actual cybersecurity disclosure, this is N/O. Specificity is Level 1 by rule for N/O.

thinking:
Let me analyze this paragraph.

Content: States no incidents to date, acknowledges lack of formalized framework leaves them vulnerable, then speculates about potential impacts.

Category: The first sentence is a negative assertion about incidents. The rest is speculation ("could potentially lead to...").

The "have not experienced any cybersecurity incidents to date" - is this a materiality assessment? It says "cybersecurity incidents" not "material cybersecurity incidents." It's closer to a factual claim about incident history rather than a materiality conclusion. But per the codebook, "We have not experienced any material cybersecurity incidents" → SI. This one doesn't use "material" though.

The speculative language about potential impacts is generic risk boilerplate and doesn't count as substantive disclosure. La Rosa Holdings is essentially a small real estate company in early-stage cybersecurity development with no formalized program, which means the paragraph fails to address the substantive questions about what their program actually does, board oversight, or management responsibilities. The negative incident claim is incomplete since it doesn't specify materiality. The paragraph lacks substantive disclosure—no actual cybersecurity measures, processes, or governance structures are described. The admission of vulnerability without a formalized framework is honest but doesn't constitute a meaningful program description. Given the materiality standard requires evidence of potential material adverse effects rather than generic speculation, I'm settling on N/O classification.


reasoning: The first sentence states a materiality conclusion ('not aware of any material risks... that have materially affected or are reasonably likely to materially affect') — this is both a backward-looking and forward-looking assessment, making it SI per the materiality rule. The remainder is generic speculation ('could adversely affect') and a cross-reference to Item 1A, both subordinate to the assessment. No domain terminology, firm-specific facts, or verifiable claims are present — only general business/risk language ('cyber-attacks,' 'security breaches,' 'privacy laws' all pass the ERM test as generic).

thinking:
Let me analyze this paragraph.

Content: States materiality assessment (not aware of material risks, not reasonably likely to materially affect), then generic risk speculation, then cross-reference to Item 1A.

Category: The first sentence is a materiality assessment → SI. The rest is speculation and cross-reference. The primary purpose is stating a conclusion about materiality.

Specificity: Let me check for facts. The materiality statement is a negative self-assertion - not verifiable. No domain terms beyond generic risk language. No firm-specific facts. No QV facts. This is boilerplate SI language.

Wait - "cybersecurity risks," "cyber-attacks," "security breaches" - are these domain terms? "Cyber-attacks" is fairly generic.

Applying the ERM test now: terms like "privacy laws," "theft, fraud, extortion," "cyber-attacks," and "security breaches" are all standard business vocabulary without any mention of specific security practices or tools. This lands at Level 1.


fact: threat intelligence

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' — it identifies executive leadership team members (CFO, SVP & General Counsel) who supervise cybersecurity efforts and describes the information channels they use. Person-removal test: the remaining text describes information sources (briefings, threat intel, alerts) but these are subordinate to the management supervision framing rather than a standalone program description. 'Threat intelligence' is a domain-specific term elevating to Level 2, but named roles (CFO, General Counsel) are generic C-suite titles not qualifying as firm-specific cybersecurity leadership.

thinking:
Let me analyze this paragraph.

Category: This describes management's role in supervising cybersecurity efforts. The subject is "members of our executive leadership team" and it describes what they supervise and how they get information. Let me apply the person-removal test: remove CFO, SVP, General Counsel, executive leadership team. What remains? "efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which include briefings from internal security personnel, threat intelligence and other information obtained from governmental, public, or private sources, including external consultants engaged by us, alerts and reports produced by security tools deployed in the IT environment."

That's still substantive, but the core question is really about how management is organized to handle cybersecurity. The paragraph centers on the executive leadership team's supervisory role and the information sources they rely on—briefings, threat intelligence, and security tool alerts. Removing the titles leaves a description of activities and information flows, which makes this borderline between MR and RMP, but the primary framing is clearly about management's organizational structure and how they perform their oversight function.

I'm settling on MR since the focus is on management's role rather than a full program description. Now checking specificity: CFO and SVP General Counsel are generic C-suite titles, not firm-specific. "Threat intelligence" is domain terminology, so that pushes toward Level 2. The rest—security tools, internal personnel, external consultants—are all generic references without naming or firm-specific details.


reasoning: The paragraph states a backward-looking materiality conclusion ('none of these incidents...had a material adverse effect on our business strategy, operations, or financial conditions'), which is an assessment of how cybersecurity affects the business → SI. The cross-reference to Item 1A is 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.

Content: States past cyber incidents weren't material, then cross-references Item 1A.

Category: The first sentence is a materiality assessment - backward-looking conclusion about whether cybersecurity has affected business outcomes. Per Rule 5, "Have not materially affected our business strategy, results of operations, or financial condition" → SI. The cross-reference is subordinate.

→ Strategy Integration

Specificity: Let me scan for facts.
- "cyber incidents in the past" - no specific dates or details
- "material adverse effect on our business strategy, operations, or financial conditions" - boilerplate materiality language

- No domain terms, no firm-specific facts, no QV facts
- "Have not experienced any material cybersecurity incidents" type language - negative self-assertion, NOT externally verifiable

This is generic boilerplate with no verifiable substance behind it.

→ Generic Boilerplate (Level 1)


reasoning: The paragraph states a materiality conclusion ('have not materially affected or are reasonably likely to materially affect... business strategy, results of operations, or financial condition'), which is the SEC's Item 106(b)(2) language — making this SI. The second clause ('could have a material adverse effect') is speculation and does not change the category. No domain terminology, firm-specific facts, or verifiable claims are present — pure boilerplate materiality language found in nearly every 10-K.

thinking:
This paragraph contains two parts: (1) a materiality assessment stating risks have not materially affected the company, and (2) speculation about future potential impact.

Category: The first clause is a clear materiality assessment (backward-looking + forward-looking SEC language). The second clause is speculation. The primary content is the materiality conclusion → Strategy Integration.

Specificity: Let me scan for facts.
- "have not materially affected or are reasonably likely to materially affect" — this is the SEC boilerplate materiality language. No domain terms, no firm-specific facts, no verifiable claims.

- "previous cybersecurity incidents" and "could have a material adverse effect in the future" — both are generic references without specifics. This is standard SI boilerplate, Level 1.


reasoning: The first sentence states a materiality conclusion — both backward-looking ('have materially affected') and forward-looking ('reasonably likely to materially affect') — which is the SEC's Item 106(b)(2) assessment language, making this SI. The brief second sentence about third-party due diligence is subordinate. No domain terminology (due diligence/monitoring are generic ERM language), no firm-specific facts, and 'during 2024' is merely reporting-period context, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Two sentences:
1. "We are not aware of any cybersecurity risks, including as a result of any cybersecurity incidents during 2024, that 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 (backward-looking + forward-looking). → SI

2. "Third parties with access to sensitive data or systems are subject to due diligence and ongoing monitoring." — This is about third-party risk management. → TP

The first sentence is the bulk of the paragraph and states a materiality conclusion.

The second sentence is brief and generic. Looking at the specificity here: "materially affected or are reasonably likely to materially affect" uses standard materiality language without detail, "during 2024" is just the reporting period, and "due diligence and ongoing monitoring" is boilerplate ERM terminology. There are no domain-specific terms, no firm-specific facts, and nothing that qualifies as quantified or verified information. This lands at Level 1.


reasoning: The paragraph states a backward-looking conclusion about whether cybersecurity has materially affected operations or financial performance ('not aware of any cybersecurity incidents that have materially impaired'), which is a materiality assessment → SI. No domain terminology, firm-specific facts, or verifiable claims are present; the negative self-assertion about absence of material incidents is not externally verifiable → Level 1.

thinking:
Classify this paragraph.

"We are not aware of any cybersecurity incidents that have materially impaired our operations or financial reporting responsibilities or performance historically."

This is a materiality assessment - a backward-looking conclusion about whether cybersecurity has affected the business. Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI (negative assertion with materiality framing).

Specificity: No domain terms, no firm-specific facts, no QV facts. The negative assertion about no material incidents is not externally verifiable. Level 1.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — discussing vendor reliance and developing a vendor risk management program, making TP the clear category. All language is generic business/ERM terminology ('third-party risks,' 'vendor risk management program,' 'cybersecurity defense programs') with no domain-specific terms, firm-unique facts, or verifiable claims.

thinking:
Let me classify this paragraph.

Content: About managing third-party cyber risks, developing a vendor risk management program.

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

Specificity: Let me scan for facts.
- "vendor risk management program" — generic program name, not firm-specific
- "third-party risks," "vendors," "cybersecurity incident" — general business language
- No domain terminology that passes the ERM test
- No firm-specific facts
- No QV facts

- The language here is entirely generic—just standard vendor risk management concepts without any specialized terminology or company-specific details. This lands at Level 1.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' — describing vendor selection, oversight, and contractual requirements imposed on service providers, making TP the clear category. No domain terminology (e.g., SOC 2, encryption), no firm-specific facts, and no verifiable claims; the language ('agree by contract to manage their cybersecurity risks in specified ways') is generic enough for any company's ERM filing, remaining at Level 1.

thinking:
Let me analyze this paragraph.

Content: About third-party service providers, suppliers, manufacturers, requiring them by contract to manage cybersecurity risks.

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

Specificity: Let me scan for facts.
- "third-party service providers, including our suppliers and manufacturers or those who have access to patient and employee data or our systems" — generic description
- "agree by contract to manage their cybersecurity risks in specified ways" — generic contractual requirements

No domain terminology (no specific security terms like SOC 2, encryption, etc.), no firm-specific facts, no QV facts.

The language here is boilerplate vendor management language that lacks any distinguishing detail or technical specificity. Level 1.


fact: October 28, 2023 — specific date of incident announcement

fact: mid-December 2023 — approximate recovery date

fact: $1.5 million of expenses related to the cybersecurity incident

fact: first quarter of fiscal 2024 — specific fiscal period for impact

reasoning: The paragraph is framed as 'Effects and Impacts of Cybersecurity Risks' and primarily answers how cybersecurity affected the business: shipping disruptions, $1.5M in costs, recovery timeline, and a concluding materiality assessment — making SI the dominant frame per Rule 4 (financial analysis with incident reference). Multiple QV facts including a specific date (October 28, 2023), a dollar amount ($1.5M), and a recovery timeline (mid-December 2023) drive Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes a real cybersecurity incident (October 28, 2023), its impacts on operations, recovery timeline, costs ($1.5M), and then a materiality assessment statement, plus cross-references to Item 1A.

Category: This is mixed. It describes an actual incident (ID) AND its business/financial impact (SI). The paragraph covers: what happened (incident impacting operations), timeline (October 28 2023, mid-December 2023), financial impact ($1.5M expenses), materiality assessment, and cross-references.

Per Rule 4: Mixed with financial frame dominant → SI. Let me reconsider.

The paragraph opens with the incident itself but quickly pivots to the business consequences—shipping disruptions, recovery timeline, the $1.5M expense, ongoing investments, and whether it's material. The header "Effects and Impacts of Cybersecurity Risks" signals a business/financial frame. While the incident is mentioned, the real substance is answering how this affected operations and the bottom line. That makes SI the dominant category here—the paragraph is fundamentally about the business impact, not just describing what happened.

Looking at the specificity markers: October 28, 2023 is a precise date, $1.5 million is an exact figure, mid-December 2023 pins down the recovery window, and the materiality assessment language all point to Level 4. The concrete numbers and dates give this the quantitative specificity needed for that rating.


reasoning: The paragraph's primary content is a materiality assessment — 'we have not had any known instances of material cybersecurity incidents' — which is a backward-looking conclusion about whether cybersecurity has affected the business (SI). The remaining text is speculation ('there can be no assurance') and a cross-reference to Item 1A, both subordinate. For specificity, the 'December 31, 2024' date anchors a negative self-assertion which is not externally verifiable per codebook rules, and no domain terminology, firm-specific facts, or other QV-eligible facts are present.

thinking:
Let me analyze this paragraph.

Content: States no material cybersecurity incidents as of Dec 31, 2024, acknowledges risks, and cross-references Item 1A.

Category: The first sentence is a negative assertion about material incidents - "we have not had any known instances of material cybersecurity incidents" - this is a materiality assessment (SI). The second sentence is speculation ("could have..."). The third is a cross-reference to Item 1A.

The primary content is the materiality conclusion → SI.

Specificity:
- "As of December 31, 2024, we have not had any known instances of material cybersecurity incidents" → negative self-assertion. Per the codebook, negative assertions are NOT externally verifiable ("you cannot independently confirm the absence of something"). The date doesn't make it verifiable either.

- The mention of third-party provider incidents is vague and lacks domain-specific language, and the cross-reference plus speculation don't add concrete details. No domain terminology, firm-specific facts, or quantifiable evidence present. This rates as Level 1.


reasoning: The paragraph's central topic is how the company manages third-party risk, answering 'how are third-party cyber risks managed?' → TP. The language is entirely generic ERM vocabulary ('identification, measurement, management, monitoring and reporting') with no cybersecurity domain terminology, no firm-specific distinguishing details ('Third Party Program' is a generic program name without a distinguishing identifier), and no verifiable facts → Level 1.

thinking:
Classify this paragraph.

Content: About third-party risk management program - what it does. Central topic is third-party risk management.

Category: This is about how third-party cyber risks are managed → Third-Party Risk. But wait - let me check Rule 3. The paragraph describes the company's own third-party program and what it does generally. It's about vendor oversight as the central topic → TP.

Actually, re-reading: "Our Third Party Program provides guidance for managing third party risk and is designed to assist us with the identification, measurement, management, monitoring and reporting of third party risk." This is about overseeing third parties → TP.

The program name itself is generic without any distinguishing identifier like an acronym, and the language relies entirely on standard business terminology around identification, measurement, and monitoring. There's nothing firm-specific or domain-specialized here, so this lands at Level 1 specificity.


reasoning: The paragraph states a conclusion about whether cybersecurity has materially affected business outcomes — a backward-looking materiality assessment ('have not had a material impact') combined with a forward-looking assessment ('not anticipated to significantly affect'), making it SI. No domain terminology, firm-specific facts, or verifiable claims are present — just standard boilerplate materiality language.


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

reasoning: The paragraph describes designing and assessing the cybersecurity program based on NIST CSF, answering 'what does the program do?' → RMP. NIST CSF is domain terminology elevating to Level 2, but the paragraph explicitly disclaims meeting any certification standards and uses NIST CSF only as a guide ('aligned with'), so it stays at Domain-Adapted rather than Quantified-Verifiable.

thinking:
Let me classify this paragraph.

Content: Describes using NIST CSF as a guide for their cybersecurity program - this answers "What does the cybersecurity program do?" → RMP

Specificity: NIST CSF is a named framework/domain term → Level 2. The paragraph explicitly says "This does not imply that we meet any particular technical standards" - so no certification claim. "Aligned with NIST CSF" → Domain-Adapted.


fact: Chief Information Security Officer (CISO)

reasoning: The paragraph is genuinely split between program description and board oversight. Applying the 'most text' tiebreaker, the first two sentences describe the cybersecurity framework (identify, assess, mitigate risks; policies and safeguards), which outweighs the Audit Committee oversight sentence, so RMP wins narrowly. The framework language is entirely generic ERM vocabulary ('identify, assess and mitigate,' 'policies and safeguards') failing the domain-expertise test, and 'Audit Committee' is not firm-specific, but the CISO title elevates specificity to Level 3.

thinking:
Let me analyze this paragraph.

Content category: This paragraph covers multiple topics - risk management framework, CISO mention, and board/audit committee oversight. Let me apply the "what question" test.

The paragraph describes: (1) a framework for identifying/assessing/mitigating risks, (2) policies and safeguards, (3) CISO manages the program, (4) Audit Committee oversight.

It's a governance-chain paragraph (Board → Committee → CISO → Program). The text is roughly split between describing the program framework and the oversight structure. The first half describes the framework (RMP), then CISO (MR), then Audit Committee (BG).

Now I'm looking at how the text actually breaks down - there's substantial space devoted to the framework itself, but the governance chain structure is clear. The paragraph opens with general framing about the cybersecurity approach, then moves into the specific framework components before shifting to who oversees it. Let me count the actual sentence distribution to determine the primary focus.

The Audit Committee sentence carries the most detail about specific responsibilities - reviewing procedures, assessing risk management, evaluating resource commitment. That level of specificity suggests governance oversight is the main point. The framework description is fairly generic, and the CISO mention is just a brief management detail. Given the governance-chain pattern and how much weight the oversight responsibilities carry, this leans toward BG. Looking at the word counts more carefully, the framework description takes up roughly 60 words compared to about 40 for the Audit Committee and 12 for the CISO mention. Even though the framework language is generic boilerplate, RMP wins on text volume. For specificity, the CISO reference pushes this to Level 3, since that's a firm-specific role, while the Audit Committee is generic across all companies.


reasoning: The paragraph answers 'What does the cybersecurity program do?' by describing incident management team activities, escalation processes, and response exercises — all program activities, not roles or governance. Despite length, every term fails the ERM test: 'incident response,' 'cross-functional team,' 'escalation,' simulated exercises, and 'identifying, protecting from, detecting, responding to, and recovering from' are all general process language any ERM professional could write. No domain terminology, no firm-specific facts, no verifiable claims.

thinking:
Let me analyze this paragraph.

Content Category: This describes what the cybersecurity program does - incident management team, incident response processes, escalation procedures, testing exercises. The primary question answered is "What does the cybersecurity program do?" → RMP

Person-removal test: No specific persons mentioned, so this is clearly about activities/processes.

Specificity: Let me scan for facts.

- "dedicated incident management team" - generic organizational claim
- "executive incident team" - not a named committee with a distinguishing identifier, fairly generic

- "cross-functional teams" - generic
- "incident response program" - generic
- "at least one incident response test exercise on an annual basis" - generic cadence
- "simulated incident scenario" - this is essentially a tabletop exercise without cybersecurity qualifier

Now I'm checking the domain terminology. The language around "incident response" and "incident management" isn't listed as specialized terminology, and while the paragraph references the NIST CSF functions—identifying, protecting, detecting, responding, and recovering—it doesn't explicitly call them out as such. The content is about cybersecurity incidents but uses fairly standard operational language.

Looking at the rest of the filing, everything else falls into generic business terminology: incident response plans, cross-functional teams, tabletop exercises, escalation procedures. These are all on the non-domain list. The implicit NIST CSF reference without naming it explicitly doesn't push this into Level 2 territory. I think this stays at Level 1—the language is fundamentally generic business speak.


fact: Executive Vice President of Technology

fact: over 16 years of experience managing information technology and cybersecurity matters

reasoning: The paragraph is genuinely split between MR (EVP role, reporting line, experience) and SI (materiality assessments). The materiality conclusions — both backward-looking ('have not…materially affected us') and forward-looking ('reasonably likely to materially affect us') — represent the paragraph's core regulatory disclosure per Rule 5, tipping the balance to SI. Specificity reaches Level 4 because 'over 16 years of experience' is a lower-bound quantified fact independently checkable against a resume.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. EVP of Technology role, reporting line, experience - MR
2. ERM integration - RMP
3. Materiality assessment - SI
4. Cross-reference to Item 1A - N/O

The materiality assessment is significant: "we have not identified risks...that have materially affected us" (backward-looking) AND "are reasonably likely to materially affect us" (forward-looking SEC language). This is a clear SI materiality conclusion.

The EVP of Technology description is MR content. The ERM mention is brief.

Looking at the text allocation, the paragraph is genuinely split between MR and SI—the EVP role description and the materiality assessment both carry substantial weight, with the materiality language being the SEC-required conclusion. from management responsibility to the materiality conclusion—that's the real substance of the disclosure. So SI is the right call.

Now looking at specificity: the Executive Vice President of Technology title is firm-specific, and the "over 16 years of experience" is a quantified lower bound, which pushes this to Level 4. The reporting line to the CEO is organizational context but less distinctive. The materiality statements themselves are SEC boilerplate and not independently verifiable, so they don't add specificity. The quantified experience metric is what drives the classification here.