reasoning: The paragraph contains both a backward-looking materiality assessment ('have not...materially affected') and a forward-looking assessment ('are reasonably likely to materially affect'), both of which are conclusions about cybersecurity's impact on business outcomes → SI per Rule 5. The cross-reference to Item 1A is subordinate. Specificity is Level 1 because the language is entirely SEC boilerplate with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Two materiality assessments (backward-looking negative, forward-looking positive) plus a cross-reference to Item 1A.

Category: The first sentence is a backward-looking materiality assessment ("have not... materially affected"). The second sentence is a forward-looking materiality assessment ("are reasonably likely to materially affect"). Both are SI per Rule 5. The third sentence is a cross-reference but subordinate to the assessments.

→ Strategy Integration

Specificity: Let me scan for facts.
- No domain terminology beyond general business language
- No firm-specific facts

- No QV facts
- "materially affected" / "reasonably likely to materially affect" — these are SEC boilerplate language
- The cross-reference to Item 1A is generic

This is boilerplate SI language. Level 1.


content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is a cross-reference pointing to Item 1A for materiality discussion rather than stating a materiality conclusion itself. Per the N/O vs SI rule, 'risks that may materially affect us, see Item 1A' → N/O. N/O always receives Specificity 1.

provider: anthropic

generationId: agent-sdk

stage: benchmark


content_category: Management Role

fact: CISO

fact: President of Technology

fact: Zero Trust Architecture

fact: over 30 years of industry experience (CISO)

type: quantified

fact: joined Visa in November 2015

fact: over 30 years of experience (President of Technology)

fact: joined Visa in November 2013

fact: VisaNet

fact: Fortune 500 companies

reasoning: The paragraph is entirely about management qualifications, career history, and role responsibilities for the CISO and President of Technology — person-removal leaves no substantive content, confirming MR. Multiple QV-eligible facts including specific join dates (November 2015, November 2013) and quantified experience ('over 30 years' as verifiable lower bounds) drive Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes CISO's experience and background, President of Technology's experience and responsibilities. This is about management's qualifications, career history, and role responsibilities.

Category: Management Role (MR) - person-removal test: remove all person-specific content and nearly nothing remains. The paragraph is entirely about who these people are, their qualifications, and their responsibilities.

Specificity: Let me scan for facts.
- CISO - firm-specific role (Level 3)

- Over 30 years of industry experience and joining Visa in November 2015 are both quantified dates and specific milestones (Level 4)
- Zero Trust Architecture is a domain-specific term (Level 2)
- President of Technology is another firm-specific role (Level 3)
- November 2013 marks another specific date (Level 4)
- VisaNet is a named system tied to the firm (Level 4)
- Fortune 500 companies reference is harder to verify directly about the CISO

The multiple specific dates and quantified experience metrics push this to Level 4.


fact: CIO

fact: Technology and Operations Committee

fact: Management Committee

reasoning: The paragraph describes how management is organized to handle cybersecurity: the CISO's reporting line to the CIO and Bank President, and the Technology and Operations Committee's role in overseeing cyber risks. Person-removal test: removing roles and reporting lines leaves little substantive content, confirming MR. Specificity is Level 3 due to named cybersecurity roles (CISO, CIO) and named non-generic committees (Technology and Operations Committee, Management Committee).


reasoning: This paragraph is a cross-reference directing readers to a risk factor in Item 1A for the materiality discussion. While it echoes the SEC's materiality language ('materially affected or are reasonably likely to materially affect'), it does not itself STATE a conclusion about materiality — it describes what another section covers and incorporates it by reference. Per the N/O vs. SI rule, cross-references pointing elsewhere are N/O. No substantive cybersecurity disclosure is present, so specificity is Level 1.

thinking: Cross-reference to Item 1A risk factor. It mentions materiality language but is pointing elsewhere, not making an assessment itself.


content_category: Board Governance

fact: CISO updates the Audit Committee

reasoning: The paragraph primarily answers how the board oversees cybersecurity: Audit Committee oversight, quarterly briefings from the CISO, information flow to the full Board, and annual education sessions — all classic BG content. The CISO reference is firm-specific (Level 3), but no QV-eligible facts are present (no specific numbers, dates, named external firms, or certifications). 'Audit Committee' is generic per the codebook, and cadences like 'quarterly' and 'annual' are not verifiable specifics.

thinking:
Let me analyze this paragraph.

Content: Describes how the Audit Committee oversees cybersecurity, CISO reports to the committee quarterly, information flows to the full Board, board education sessions.

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

Specificity: Let me scan for facts:
- "Audit and Risk Committee" — called "Audit Committee" which is generic per codebook (every public company has one) → NOT firm-specific. But wait, it's named "Audit and Risk Committee" — though the codebook says "Audit Committee" is not firm-specific.

- The CISO role is firm-specific, but the quarterly reporting cadence and unnamed third-party assessments are too generic. The incident response plan and annual education sessions are also standard practices without domain-specific terminology. Since the CISO is the only firm-specific element here, this qualifies as Level 3.


content_category: Strategy Integration

reasoning: The paragraph states a conclusion about whether cybersecurity has materially affected the company using SEC Item 106(b)(2) language ('materially affected or are reasonably likely to materially affect... business strategy, results of operations or financial condition'), making it a materiality assessment → SI. No domain terminology, firm-specific facts, or verifiable claims are present; the negative assertion about no material incidents is not externally verifiable, and the remaining language is generic boilerplate any company could use.

thinking:
Let me analyze this paragraph.

Content: States no material cybersecurity risks/incidents, materiality assessment, then generic forward-looking caveat.

Category: The paragraph states a conclusion about whether cybersecurity has materially affected the business → Strategy Integration (SI). The materiality assessment language "materially affected or are reasonably likely to materially affect" is the SEC's Item 106(b)(2) language.

Specificity: Let me check for facts:
- "Have not encountered any risks... that materially affected or are reasonably likely to materially affect" → This is a materiality assessment, but it's a negative self-assertion. Not QV.

- The language lacks any domain-specific terminology, company-specific details, or substantive claims that could be verified → Level 1 boilerplate.


fact: vulnerability assessments

reasoning: The paragraph primarily answers how the board oversees cybersecurity — Audit Committee and Board oversight, discussion cadence with management — making it Board Governance. 'Vulnerability assessments' is cybersecurity domain terminology (passes the ERM test), elevating to Level 2. COO is not a cybersecurity-specific title, Audit Committee is not firm-specific, and 'at least once a year' is a generic cadence, so nothing reaches Level 3.

thinking:
Let me classify this paragraph.

Content: Board/Audit Committee oversight of cybersecurity, discussions with COO and management about cybersecurity topics.

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

Specificity: Let me scan for facts.
- "Audit Committee" — not firm-specific (every public company has one)
- "Board of Directors" — not firm-specific
- "COO" — not a cybersecurity-specific role (it's a generic executive title)
- "vulnerability assessments" — this is domain terminology (yes, per the codebook)

- "threat environment" — this is more generic, borderline
- "at least once a year" — generic cadence

"Vulnerability assessments" passes the ERM test — it's cybersecurity domain terminology. So Level 2.


content_category: Risk Management Process

fact: Security awareness training

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing two program activities: security awareness training for employees and integration of cybersecurity into the ERM framework. 'Security awareness training' is a cybersecurity domain term (passes the ERM test — a generic ERM professional wouldn't naturally use this term), elevating to Level 2. The remaining language (key risk indicators, emerging risks, risk mitigation plan, enterprise risk management) is general ERM vocabulary that stays at Level 1. No firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes security awareness training and ERM integration of cybersecurity.

Category: "What does the cybersecurity program do?" → RMP. It describes activities (training, ERM integration, tracking risk indicators).

Specificity:
- "Security awareness training" — this is a domain term (cybersecurity-specific practice)
- "enterprise risk management framework" — general business term, not domain
- "key risk indicators," "emerging risks," "risk mitigation plan" — general ERM language

So Level 2 based on "security awareness training."


reasoning: The paragraph answers 'How does the board oversee cybersecurity?' — describing Board oversight, delegation to Audit Committee, and reporting structure. No domain terminology, no firm-specific facts (Board, Audit Committee, and 'management' are generic governance elements present at every public company), and no verifiable claims.


category_confidence: medium

reasoning: The paragraph describes developing cybersecurity processes and procedures with external help, answering 'what does the program do?' The third parties are hired to serve the company's own program (Rule 3 → RMP, not TP). All language is generic business terminology — 'outside counsel,' 'third-party service providers,' 'processes and procedures,' 'response plan' — none passes the ERM test, and no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Working with outside counsel and third-party service providers to develop expertise, processes, procedures for cybersecurity protection and response plan.

Category: This describes the company's cybersecurity program activities - developing processes and procedures. The third parties mentioned are hired to serve the company (Rule 3 → RMP, not TP). This answers "What does the cybersecurity program do?"

Specificity: No domain terminology (just generic "cybersecurity protection," "response plan," "processes and procedures"). No firm-specific facts. No QV facts. "Outside counsel" and "third-party service providers" are unnamed.

This lands at Level 1 due to the lack of specificity and detail.


content_category: Third-Party Risk

fact: service organization controls reports (SOC reports)

fact: Risk Management, Legal and/or Information Security Departments review higher risk contracts

reasoning: The paragraph's central topic is oversight of third-party service providers' cybersecurity — assessing vendor risks, reviewing contracts, conducting due diligence on data security requirements — squarely answering 'how are third-party cyber risks managed?' The mention of 'service organization controls reports' is domain terminology (SOC reports), and the specific departmental composition ('Risk Management, Legal and/or Information Security Departments') reviewing contracts is a firm-specific team composition detail, elevating to Level 3.

thinking:
Let me analyze this paragraph.

Content: This is about managing third-party cybersecurity risks - vendor oversight, contractual requirements, due diligence on service providers. Central topic is third-party risk management.

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

Specificity facts:
- "Risk Management, Legal and/or Information Security Departments" - specific team composition by department → firm-specific
- "service organization controls reports" - this is SOC reports → domain term
- "third party service provider management program" - generic program name, not distinguishing

- The specific departmental composition mentioning Risk Management, Legal, and Information Security departments indicates Level 3 specificity, while the reference to SOC reports as domain terminology points to Level 2.


fact: layered security model

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

specificity_confidence: medium

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing a comprehensive information security program with a layered security model as part of ERM — clearly RMP. The 'layered security model' (essentially defense in depth) and explicit invocation of the CIA triad (confidentiality, integrity, availability) are cybersecurity domain concepts that an ERM professional would not naturally use, elevating to Level 2. However, no firm-specific facts or verifiable claims are present.

thinking:
Let me classify this paragraph.

Content: Describes the company's information security program at a high level - layered security model, protecting data, ensuring CIA triad, part of ERM.

Category: "What does the cybersecurity program do?" → RMP. It describes the program's general approach.

Specificity: Let me scan for facts.
- "layered security model" - this is close to "defense in depth" but not exactly domain terminology. Actually "layered security" is essentially the same concept. Let me think... would an ERM professional use "layered security model"? Possibly not - it's a security architecture concept. But it's borderline.

- The CIA triad is foundational to information security, and while an ERM professional might say "protect data," they'd be less likely to invoke this specific framework - I'll count it as domain terminology.
- "industry leading hardware, software, and services" and "enterprise risk management program" are both generic language.
- "Layered security model" is essentially defense in depth, which qualifies as domain terminology.

So this scores at Level 2.


fact: penetration testing

fact: managed detection and response services

fact: intrusion prevention and detection applications

reasoning: The paragraph is split: sentences 1–2 describe third parties hired to serve the company's own security (RMP per Rule 3), while sentences 3–5 describe the vendor risk management program's oversight of third parties and assessment of critical third parties' cyber risk protocols (TP). Because the TP content occupies the majority of the text and the paragraph's organizing arc moves toward vendor oversight, TP wins. Specificity is Level 2 due to cybersecurity domain terminology (penetration testing, MDR, IDS/IPS) that passes the ERM test, but no firm-specific roles, named external entities, or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph discusses both third-party engagements serving the company's security program AND vendor risk management. Let me parse it:

1. First two sentences: Third parties hired to test/enhance the company's own security (penetration testing, MDR, IDS/IPS) → RMP
2. "Our vendor risk management program includes regular reviews..." → TP
3. "the Bank seeks to identify, monitor and prioritize substantial risks from cybersecurity threats associated with our use of critical third parties" → TP
4. Last sentence about assessing third party's cyber risk management → TP

5. So the structure is: the first two sentences describe security service providers, then sentence 3 pivots to the vendor risk management program that oversees those same third parties, with sentences 4-5 elaborating on how they monitor and assess vendor cyber risk.

The paragraph is genuinely split between describing their use of third parties for security (RMP) and their oversight of those vendors (TP). Since the vendor management and risk assessment content takes up more space and represents the main focus, this leans toward TP. I'm counting the sentences to determine the dominant classification—the first two focus on third parties hired to support security operations, which falls under RMP, while the remaining three center on how the bank manages vendor risk itself, making TP the stronger fit overall.

For specificity, I'm noting the presence of domain terminology like penetration testing, MDR services, and IDS/IPS applications, but no named external vendors, specific metrics, or firm-specific details beyond a generic company reference, which points to Level 2.


reasoning: The paragraph's central topic is managing cybersecurity risks from third-party service providers — it describes reliance on third-party networks and a program to manage those risks, answering 'how are third-party cyber risks managed?' No domain terminology, firm-specific facts, or verifiable claims are present; language like 'third-party risk management program' and 'manage cybersecurity risks' is generic business language.


reasoning: The paragraph contains a backward-looking materiality assessment ('prior cybersecurity incidents have not had a material adverse effect on the Partnership's business, financial condition, results of operations, or cash flows'), which is a conclusion about whether cybersecurity has affected business outcomes → SI per Rule 5. The 'could have a material adverse effect' language is speculation and the Item 1A cross-reference is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — the language is entirely generic boilerplate that could appear in any filing.

thinking:
Let me analyze this paragraph.

Content: States cybersecurity threats "could have a material adverse effect" (speculation), then states "prior cybersecurity incidents have not had a material adverse effect" (backward-looking materiality assessment → SI), then cross-references Item 1A.

The key sentence: "prior cybersecurity incidents have not had a material adverse effect on the Partnership's business, financial condition, results of operations, or cash flows" — this is a backward-looking materiality assessment → SI.

The "could have a material adverse effect" is speculation (not SI by itself), but the backward-looking assessment IS SI per Rule 5.

The cross-reference to Item 1A is just a supporting reference. Looking at the specificity here: the language about not having material adverse effects is generic boilerplate without any firm-specific facts, domain terminology, or quantifiable details — it's a negative assertion about materiality that lacks the concrete information needed to qualify as SI.


reasoning: This is a cross-reference pointing to Item 1A for materiality discussion. Per the codebook, 'risks that may materially affect us, see Item 1A' → N/O (pointing elsewhere), not SI. No substantive cybersecurity disclosure is made. N/O always receives Specificity 1.


reasoning: The paragraph describes employee training and awareness activities, answering 'what does the cybersecurity program do?' → RMP. Despite mentioning 'cybersecurity training,' the description uses only generic language ('mandatory ongoing training,' 'culture of awareness,' 'identifying and reporting security issues') that any ERM professional could write — no domain-specific practices like phishing simulations or security awareness training platforms are named, and no firm-specific or verifiable facts are present.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by stating the Fund has processes to assess, identify, and manage risks and that the Adviser has implemented a cybersecurity program — this is RMP, though very generic. All language ('processes to assess, identify, and manage material risks,' 'cybersecurity program,' 'communications and information systems') is standard ERM phrasing with no domain terminology, no firm-specific cybersecurity facts, and no verifiable claims, keeping it at Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes that the Fund has processes for cybersecurity risk management, depends on the Adviser and third-party service providers, and the Adviser has implemented a cybersecurity program.

Category: "What does the cybersecurity program do?" — but it's very generic. It says "processes to assess, identify, and manage material risks" and that the Adviser "has implemented a cybersecurity program." This is RMP - describing what the program does, albeit generically.

Specificity: Let me check for facts:

- "processes to assess, identify, and manage material risks from cybersecurity threats" — generic ERM language → Level 1
- "Adviser" — this is a generic reference to their investment adviser, not a cybersecurity-specific role
- "cybersecurity program" — generic program name
- No domain terminology, no firm-specific facts, no QV facts

This is Level 1 - Generic Boilerplate. All language is generic business/risk management language.


fact: CISO

fact: Executive Steering Committee (includes CEO, CFO, EVP Engineering, Senior Director IT, General Counsel)

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity — the CISO coordinating with a named Executive Steering Committee, multidisciplinary teams deployed across the company, and reporting lines. Person-removal test: removing the CISO, committee membership, and reporting structure leaves only generic program language ('protect information systems,' 'monitor prevention, detection, mitigation'). The final sentence about reporting to the Audit Committee/Board introduces a BG element, but the bulk of the text is about management's organizational structure. Specificity reaches Level 3 via the CISO role and the named Executive Steering Committee with its specific composition; no QV-eligible facts (no numbers, dates, certifications, or named external entities) are present.

thinking:
Let me analyze this paragraph.

Category: This paragraph describes how the CISO works with an Executive Steering Committee to implement a cybersecurity risk management program. It mentions multidisciplinary teams, governance, and monitoring. The last sentence mentions reporting to the Audit Committee/Board.

The primary question: "How is management organized to handle cybersecurity?" vs "What does the cybersecurity program do?"

Person-removal test: Remove CISO, Executive Steering Committee members, titles, reporting lines. What remains? "implement a cybersecurity risk management program intended to protect information systems from cybersecurity threats and to promptly respond to Cybersecurity Events in accordance with incident response and recovery plans.

So the core of this is really about the organizational structure—the CISO coordinating with the Executive Steering Committee, how that committee is composed, the deployment of multidisciplinary teams for governance, and the reporting chain up to the Audit Committee and Board. The program description itself is fairly generic, but the paragraph's main focus is on who's responsible for what and how they're connected.

This lands in MR territory—it's fundamentally about management and reporting structure. The specificity comes from naming the CISO role and the Executive Steering Committee as firm-specific entities, though some elements like the CEO involvement are still being identified.


fact: CISO reports to the full Board

reasoning: The paragraph primarily answers how the board oversees cybersecurity — describing the Board's direct oversight of risk management, its review of policies including cybersecurity, and the information flow from CISO to Board. The CISO mention is a firm-specific cybersecurity leadership role elevating to Level 3, but no QV-eligible facts (no specific numbers, dates, named external firms, or certifications) are present.

thinking:
Let me classify this paragraph.

Content Category: This paragraph answers "How does the board oversee cybersecurity?" - Board oversight, committee structure, risk management oversight function, CISO reporting to the Board. This is clearly Board Governance.

Specificity: Let me scan for facts.
- "CISO" - firm-specific cybersecurity role (Level 3)
- "at least annually" - generic cadence, not QV
- "prevent, detect, and respond" - generic language
- The paragraph describes board oversight activities in general terms

The CISO is a firm-specific fact (Level 3). No QV-eligible facts (no specific numbers, dates, named external entities, or certifications).

The language around cybersecurity incidents and data protection is fairly standard terminology without specific domain references like NIST or penetration testing, so this stays at Level 3 based on the CISO mention alone.


fact: vulnerability scanning

fact: PCI DSS compliance requirements

type: framework

fact: cyber insurance underwriting process

reasoning: The paragraph describes third-party cybersecurity assessments the company participates in (vulnerability scanning, penetration testing, network assessments) — these are activities serving the company's own security program, making this RMP per Rule 3. Multiple domain terms (vulnerability scanning, penetration testing, PCI DSS) elevate to Level 2, but cadences are generic ('quarterly,' 'annual') and PCI DSS is referenced as a requirement they're subject to rather than a verified certification claim, so it stays at Domain-Adapted.

thinking:
Classify this paragraph.

Content: describes cybersecurity assessments the company receives/participates in - vulnerability scanning, network assessments, penetration testing. These are third-party assessments serving the company's own security program → RMP (Rule 3).

Specific facts:
- "vulnerability scanning" → domain_term
- "PCI DSS" → framework (domain term)
- "penetration testing" → domain_term
- "vulnerability scans" → domain_term
- "quarterly vulnerability scanning" → cadence is generic but the practice is domain
- "cyber insurance underwriting process" → this touches SI but is subordinate

- "PCI DSS compliance requirements" - they're stating they're subject to PCI DSS and must comply with it, which is verifiable through a QSA. This is a claim about being subject to the standard, not just alignment.

But wait, the codebook treats "aligned with NIST CSF" as Level 2 aspiration. Yet "PCI DSS compliance requirements" is different - they're saying they HAVE compliance requirements, implying they're either PCI DSS compliant or working toward it. That's more concrete than just referencing a framework.

Though actually, "compliance requirements" just means they're subject to PCI DSS regulations - it doesn't explicitly claim they're certified or compliant. It's more about acknowledging regulatory applicability, which probably still lands at Level 2 as a framework reference.

The cyber insurance mention is just passing context. Looking at the specific cadences - "quarterly" vulnerability scanning, "annual" network assessments, "annual" penetration testing - these are generic timeframes without firm-specific dates, so they don't qualify as QV. I'm settling on RMP, Level 2, with the domain terms being vulnerability scanning, PCI DSS, penetration testing, and network assessments.


reasoning: This paragraph is pure speculation about hypothetical security breaches using 'could have a material adverse effect' language — not a materiality assessment. No substantive cybersecurity measures are described ('various procedures and controls' is entirely generic), meeting the N/O threshold under Rule 6. No domain terminology, firm-specific facts, or verifiable claims are present.

thinking: This is a speculative risk factor paragraph discussing potential security breaches and their hypothetical impacts. It uses "could," "if," and "there can be no assurance" language throughout. No actual cybersecurity measures are described in specific terms. The materiality language is speculative ("could have a material adverse effect") not an assessment.


reasoning: This is a generic risk statement about IT system failures with no substantive cybersecurity disclosure — it reads as a section header or risk factor title. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph states a backward-looking and forward-looking materiality conclusion ('have not materially affected and are not reasonably likely to materially affect... business strategy, results of operations or financial condition') and mentions cybersecurity insurance — both squarely answer 'how does cybersecurity affect the business or finances?' No domain terminology, firm-specific facts, or verifiable claims are present; insurance and materiality language are general business concepts found in any filing.

thinking:
Materiality assessment + insurance mention → SI. Let me check specificity.

"cybersecurity insurance" - general business concept, not domain terminology
"have not materially affected and are not reasonably likely to materially affect" - materiality conclusion → SI

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


reasoning: The paragraph states a backward-looking materiality conclusion ('have not encountered cybersecurity challenges that have materially impaired our operations or financial standing') and discusses cyber liability insurance — both answering how cybersecurity affects the business. The cross-reference to Item 1A and insurance caveats are subordinate. No domain terminology, firm-specific facts, or verifiable claims are present; 'cyber liability insurance' and the negative materiality assertion are general business language, keeping this at Level 1.

thinking:
Let me analyze this paragraph.

Content: States no material cybersecurity incidents, cross-references Item 1A, mentions cyber liability insurance, and discusses limitations of insurance.

Category: The paragraph states a conclusion about materiality ("have not encountered cybersecurity challenges that have materially impaired our operations or financial standing") → SI per Rule 5. It also mentions cyber liability insurance, which is SI. The cross-reference is subordinate. This is SI.

Specificity: Let me scan for facts.
- "cyber liability insurance policy" - this is a firm-specific organizational claim? No, it's a generic business concept. Actually, insurance is general business language.

- The negative assertion about not materially impairing operations lacks any verifiable detail or domain-specific language, and there are no firm-specific facts or quantifiable metrics present.

This is Level 1 - Generic Boilerplate. All language is general business language.


reasoning: The paragraph states a backward-looking materiality conclusion ('did not experience any cybersecurity threats or incidents that have materially affected or are reasonably likely to materially affect') — this is an assessment of cybersecurity's impact on business outcomes, making it SI. The years mentioned (2024, 2023, 2022) are generic reporting periods, and the negative self-assertion about absence of material incidents is not externally verifiable, leaving no facts that elevate above Level 1.

thinking:
Classify this paragraph.

Content: States that during 2024, 2023, 2022, no material cybersecurity incidents. This is a materiality assessment - backward-looking conclusion about whether cybersecurity has affected business outcomes → SI.

Specificity: "During 2024, 2023, and 2022" - these are reporting period years, not specific dates tied to cybersecurity events. The statement is a negative self-assertion ("did not experience any material incidents") which is not externally verifiable. No domain terms, no firm-specific facts.

This lands at Level 1 - it's a generic claim without concrete details or external verification.


reasoning: The paragraph primarily answers 'how are third-party cyber risks managed?' by describing a vendor management program for third-party service providers with access to confidential information. Specificity remains Level 1: 'Vendor Management program' is a generic program name without a distinguishing identifier, 'internal and external audit functions' are unnamed, and the language (risk management, audit verification) is general business terminology that would appear in any ERM context without cybersecurity domain expertise.


reasoning: This paragraph describes what the cybersecurity program does — incident detection, containment, response, and remediation procedures — answering 'What does the cybersecurity program do?' → RMP. The language uses only general terms: 'incident detection, containment, response and remediation' and 'security incident response plan' are standard ERM vocabulary that any enterprise risk professional would use. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: This paragraph is pure speculation about potential risks ('may be subject to') without describing any actual cybersecurity measures, processes, or assessments. It uses only general business language ('threat landscape,' 'hacking,' 'unauthorized access') that any company could state. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph's central topic is how the company manages cybersecurity risks from third-party service providers, directly answering 'how are third-party cyber risks managed?' → TP. All language is generic business/ERM vocabulary ('third party risk management program,' 'information technology systems and networks,' 'third party service providers') with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Talks about relying on IT systems, some managed by third parties, and implementing a third-party risk management program.

Category: The central topic is managing third-party cyber risks. "How are third-party cyber risks managed?" → Third-Party Risk. But let me check - it's quite generic. The paragraph says they have a "third party risk management program" to manage cybersecurity risks of third-party service providers. The central topic is vendor oversight → TP.

Actually, wait. Let me re-read. The first two sentences are context (we use IT, some managed by third parties).

The third sentence is where they describe implementing a third-party risk management program to oversee cybersecurity risks from their service providers. That's the core topic here → TP.

Now checking the specificity. The language is entirely generic—"information technology systems," "third party service providers," "third party risk management program"—nothing that would distinguish this company or demonstrate domain expertise. An ERM professional would use exactly these same terms. No firm-specific details, no technical terminology, no quantifiable facts. This reads as boilerplate.

Level 1.


reasoning: The paragraph describes what the cybersecurity program does (incident response and recovery plans, periodic testing), answering 'What does the cybersecurity program do?' → RMP. All language is generic business terminology — 'incident response and recovery plans,' 'tested and evaluated on a periodic basis,' 'comprehensive' — none of which passes the ERM test. No domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: Describes incident response and recovery plans, testing them periodically. This answers "What does the cybersecurity program do?" → RMP.

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

- "incident response and recovery plans" — incident response plan is listed as NOT domain terminology (Level 1)
- "comprehensive" — generic
- "tested and evaluated on a periodic basis" — generic

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


fact: InfoSec Director

fact: eRISC committee

fact: CTO

reasoning: The paragraph describes how information about cybersecurity risks flows from the InfoSec Director through the eRISC committee and senior management up to the Board, answering 'how does the board oversee cybersecurity?' — a governance-chain paragraph defaulting to BG. Specificity is Level 3 due to the firm-specific InfoSec Director role (Director-level with security qualifier), the named eRISC committee, and the CTO title, but no quantified-verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes how the InfoSec Director reports to the eRISC committee and maintains communication with CEO, CFO, CTO, GC for escalation to the Board. Purpose is describing oversight/reporting structure flowing up to the Board.

Category: This is a governance-chain paragraph (Officer → Committee → Board). The purpose is describing how information flows to the board about cybersecurity. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. The paragraph answers "How does the board oversee cybersecurity?" — specifically the information flow mechanism. → **Board Governance**

The InfoSec Director and eRISC committee are firm-specific terms, and the CTO qualifies as a cybersecurity-specific title per the codebook, while CEO, CFO, and GC are generic leadership roles. This puts the paragraph at Level 3 — Firm-Specific.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — describing the Advisory Committee's oversight responsibility, reporting to the full Board of Managers, periodic briefings, and ad hoc conversations with management. The 'Advisory Committee of the Board of Managers' is a named non-generic committee unique to this partnership's governance structure, elevating to Level 3. The remaining language (cybersecurity risks, data privacy incidents, information security initiatives) is generic oversight vocabulary that fails the ERM test.

thinking:
Board oversight, briefing content, reporting structure. BG.

Specific facts: "Advisory Committee of the Board of Managers" - this is a named committee specific to this partnership structure. Firm-specific.

No QV facts. No domain terms beyond generic risk management language. "Cybersecurity risks," "data privacy incidents," "information security initiatives" - these are general. "Risk management in cybersecurity" is generic.

Actually, "Advisory Committee of the Board of Managers" is a named non-generic committee → firm-specific (Level 3).


fact: Chief Information Security Officer (CISO)

reasoning: The paragraph describes the CISO's role leading the security team and their areas of responsibility (risk assessments, security controls, incident response coordination). Person-removal test: removing the CISO and team leadership leaves generic responsibility areas ('cybersecurity risk assessments, implementation of security controls, coordination of incident response efforts') — these are role descriptions rather than a substantive program description with specific activities or tools, so it collapses toward MR. CISO is a firm-specific cybersecurity leadership title, elevating to Level 3.

thinking:
Classify this paragraph.

The paragraph describes the security team led by the CISO and what they oversee. Let me apply the person-removal test: remove "led by our CISO" → "Our security team... oversees our cybersecurity risk assessments, the implementation of security controls, and the coordination of our incident response efforts."

That still describes program activities. But the primary framing is about the CISO's role and what they oversee - it's describing how management is organized. Actually, the paragraph is quite short and centers on the CISO leading the team and their responsibilities. The person-removal test: remove CISO and team leadership → "cybersecurity risk assessments, implementation of security controls, coordination of incident response efforts" — these are generic descriptions of what the role covers, not detailed program activities.

This is borderline, but the focus is really on the CISO's leadership position and their oversight responsibilities. Once I strip away the person, I'm left with just generic responsibility areas rather than substantive program details, so this classifies as MR. The CISO itself is firm-specific enough to warrant Level 3 specificity. There are no quantifiable facts, dates, or external references to consider.


reasoning: This describes using external consultants to assist with the company's own cybersecurity controls (serving the company's program → RMP, not TP). The language is entirely generic — 'external consultants,' 'third-party experts,' 'assess, test, or otherwise assist' — no domain terminology, no firm-specific facts, no verifiable claims.


reasoning: The paragraph describes the company engaging external firms to assess its own cybersecurity posture, which per Rule 3 (third parties hired to serve the company → RMP) makes this about what the program does. Specificity remains Level 1: the third-party firms are unnamed ('a third-party technology firm', 'an independent cyber security firm'), dates are soft ('During 2024', 'In early 2025'), 'cyber risk assessment' fails the ERM test (swap 'cyber' for any other risk domain and the sentence still works), and no domain terminology, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: Describes engaging third-party firms to assess the company's own cybersecurity, and upgrades made. This is about what the program does - risk assessments conducted by external firms serving the company's program.

Category: RMP - third parties hired to serve the company's own security assessment → RMP per Rule 3.

Specificity: Let me scan for facts.
- "During 2024" - a year, but generic reporting context
- "third-party technology firm" - unnamed
- "annual cyber risk assessment" - "cyber risk assessment" - is this domain terminology? Risk assessment fails the ERM test per the codebook.

"Cyber risk assessment" is just "risk assessment" with "cyber" prepended. The dates are too vague—"During 2024" is just a year, and "In early 2025" lacks specificity. The firms themselves are unnamed, and the descriptions like "assessment of the Company's information technology system" are generic. I'm not finding any domain terminology that passes the ERM test, no firm-specific facts, and no QV facts that would strengthen this disclosure.

This appears to be Level 1 material.


fact: served in the role since 2015

fact: intrusion detection

fact: threat modeling

fact: RCOC (quarterly committee briefings)

reasoning: The paragraph primarily answers 'how is management organized?' — it describes the CISO's tenure, qualifications, team, and reporting cadence. Person-removal test: removing the CISO, experience, and team leaves only generic risk language, confirming MR. Specificity reaches Level 4 because 'since 2015' is a specific, verifiable date tied to a cybersecurity leadership fact.

thinking:
Let me analyze this paragraph.

Content: About the CISO's role, qualifications, team, and reporting to RCOC.

Category: The paragraph describes the CISO's experience, team composition, and reporting. The person-removal test: remove CISO, qualifications, team info → "assessing, identifying and managing cybersecurity threats on a day-to-day basis" and briefing RCOC. The primary content is about the CISO's role, qualifications, and team. This is MR.

Wait - the last sentence about RCOC briefings could be BG. But the paragraph is primarily about management's organization - who the CISO is, their experience, their team. The RCOC briefing is subordinate. MR.

The specificity here is strong: the CISO is a named role with a specific tenure since 2015, the expertise areas are concrete domain terms like penetration testing and threat modeling, and the RCOC is an identified committee with quarterly meetings. This pushes it to Level 4 on the quality scale.


reasoning: The paragraph centrally answers 'how are third-party cyber risks managed?' with pre-engagement assessments and contractual requirements imposed on vendors → TP. No domain terminology (just generic 'cybersecurity practices,' 'standards and protocols'), no firm-specific facts, no verifiable claims — everything here could appear in any company's filing unchanged → Level 1.


fact: CISO chairs the Cybersecurity Steering Committee

fact: Cybersecurity Steering Committee

fact: One director is the President of a major cybersecurity services provider

reasoning: The paragraph primarily answers how the board oversees cybersecurity: board education, reports on risks/threats/incidents, and Audit Committee members' expertise. While the CISO and Cybersecurity Steering Committee are mentioned, they serve as the source of information flowing TO the board — the governance-chain frame is dominant. Specificity is Level 3 due to the named CISO role and the Cybersecurity Steering Committee (a non-generic committee), but no QV-eligible facts are present (no named external firm, no specific numbers or dates, no verifiable certifications).

thinking:
Let me analyze this paragraph.

Content: Describes the CISO chairing the Cybersecurity Steering Committee, meetings providing updates, updates to the Board, board education, and Audit Committee members' expertise.

Category: This is primarily about board oversight - how information flows to the board, board education, board member expertise. The CISO and Cybersecurity Steering Committee are mentioned but in context of providing updates TO the board. The governance chain (Committee → Board) is the frame. BG.

Specificity:
- CISO → firm-specific (named role)

- Cybersecurity Steering Committee → firm-specific (named non-generic committee)
- "President of a major cybersecurity services provider" → this is a firm-specific detail about board expertise, but no named entity, so not QV
- Audit Committee → NOT firm-specific (every company has one)

No QV facts - no specific numbers, dates, named external entities, or certifications. This lands at Level 3 - Firm-Specific.


reasoning: The paragraph states both a backward-looking materiality conclusion ('have not identified risks...that have materially affected us') and a forward-looking assessment ('reasonably likely to materially affect us'), making it SI under the materiality assessment rule. The cross-reference to Item 1A is subordinate. No domain terminology, firm-specific facts, or verifiable claims are present — pure boilerplate materiality language found in many 10-K filings.

thinking:
Materiality assessment paragraph.

First sentence: "We have not identified risks from cybersecurity threats that have materially affected us" — backward-looking materiality assessment → SI. "although certain risks, if realized, are reasonably likely to materially affect us" — forward-looking assessment using SEC language → SI.

Second sentence: cross-reference to Item 1A — N/O element, but subordinate.

Category: Strategy Integration. The paragraph states a conclusion about materiality (both backward and forward-looking).

Specificity: No domain terms, no firm-specific facts, no QV facts. Generic boilerplate materiality language.

This is Level 1 — the most generic tier with no company-specific details or substantive risk analysis.


category_confidence: low

reasoning: The paragraph is primarily risk acknowledgment and speculation ('could have a material adverse effect' — explicitly not SI per codebook), but it does contain a thin process description ('proactively seek to detect and investigate unauthorized attempts and attacks... through changes or updates to internal processes and tools'), which per Rule 6 pushes it past the N/O threshold into RMP. However, confidence is low because the paragraph is dominated by risk framing, a cross-reference to Item 1A, and regulatory concern rather than substantive program description. All language is generic business/ERM vocabulary — 'detect and investigate,' 'internal processes and tools,' 'unauthorized attempts' — none passes the ERM test as cybersecurity domain terminology, yielding Level 1.

thinking:
Let me analyze this paragraph.

Content category: This paragraph mixes several things - risk acknowledgment, a negative incident assertion, some generic process description, and a cross-reference. Let me apply the "what question" test.

The paragraph starts with speculation ("could have a material adverse effect") - not SI per the rules. Then "To date, we have not had a cybersecurity incident" - this is a negative assertion but without materiality framing specifically. Then generic process language about detecting/investigating threats. Then regulatory concerns. Then a cross-reference.

The negative assertion "we have not had a cybersecurity incident" - is this SI? The codebook says "We have not experienced any material cybersecurity incidents" → SI (negative assertion with materiality framing).

But this one lacks the word "material" - it's just a bare claim about incident history. The speculation language upfront is explicitly excluded from SI, and the process description that follows is too vague to qualify as ERM. The key issue is whether a negative assertion without explicit materiality language still counts as SI, or if the absence of that framing pushes it outside the definition. The process description about detecting and investigating threats is a real measure, so it shouldn't be classified as purely generic risk language. But the paragraph's weight is still heavily on risk acknowledgment and speculation—the "could have a material adverse effect" language and the cross-reference to Item 1A push this toward N/O territory. The detection/investigation mention is brief and thin enough that I'm leaning toward classifying this as N/O, since the dominant frame is risk rather than substantive program description. I'm settling on RMP since the process description—detecting and investigating unauthorized attempts, updating internal processes and tools—is the most substantive part, even if it's generic. The language lacks any domain-specific terminology or firm-specific details, just standard ERM concepts like "cybersecurity incident" and "IT assets," so this is Level 1 boilerplate.


reasoning: The first sentence states a materiality conclusion (backward-looking 'have not materially affected' and forward-looking 'are not reasonably likely to materially affect'), and the second addresses cybersecurity insurance—both squarely answer 'how does cybersecurity affect the business or finances?' No domain terminology, firm-specific facts, or verifiable claims are present; the negative materiality assertion is a self-reported claim about absence (not verifiable), and the insurance mention uses general business language.

thinking:
Let me analyze this paragraph.

Content: Two sentences. First states a materiality assessment (backward-looking and forward-looking). Second mentions lack of cybersecurity insurance.

Category: The first sentence is a materiality assessment → SI. The second sentence about insurance is also SI (cybersecurity insurance is listed under SI). Both sentences answer "How does cybersecurity affect the business or finances?" → Strategy Integration.

Specificity: Let me scan for facts.
- "materially affected... business strategy, results of operations, or financial condition" — boilerplate materiality language
- "cybersecurity commercial insurance policy" — is this domain terminology? Insurance is a business concept.

"Cybersecurity insurance" is just insurance applied to cyber, not domain terminology. The language about not experiencing material incidents reads like a negative self-assertion rather than something verifiable. There are no domain-specific terms, firm-specific facts, or quantifiable details here. This is Level 1.


fact: October 3, 2024 — specific date of identified unauthorized activity

reasoning: The paragraph references a real incident (Oct 3, 2024) but its primary purpose is stating a materiality conclusion: 'has not experienced a cybersecurity incident that has resulted in a material impact to the Company's financial condition, results of operations, cash flows, or business strategy' — a backward-looking materiality assessment making this SI per Rule 5. The incident details are brief context for the assessment, with cross-references directing readers elsewhere for full incident discussion. The specific date October 3, 2024 tied to the cybersecurity incident is a QV-eligible fact, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics: mentions a cybersecurity incident (October 3, 2024), a materiality assessment, and cross-references. Let me determine the primary question it answers.

Content: It describes an actual incident (October 3, 2024 unauthorized activity), states a materiality conclusion ("has not experienced a cybersecurity incident that has resulted in a material impact"), and cross-references other sections.

The materiality assessment is a key statement: "the Company has determined that it has not experienced a cybersecurity incident that has resulted in a material impact to the Company's financial condition, results of operations, cash flows, or business strategy" → This is a backward-looking materiality assessment → SI.

But there's also the incident disclosure itself—the October 3 unauthorized activity is explicitly mentioned and characterized as a cybersecurity incident. So the paragraph is doing two things: disclosing what happened and then assessing whether it matters materially. The framing seems to be about how this incident fits into the company's overall business impact, with the materiality conclusion being the dominant takeaway. The cross-references suggest more detailed incident information is covered elsewhere, so this section is really about the business implications rather than the incident details themselves.

Given that the materiality assessment is the primary conclusion and the incident serves as supporting context, I'd categorize this as Strategy Integration. For specificity, the October 3, 2024 date is tied to an actual cybersecurity event, which qualifies as quantifiable value. The materiality statement itself is a negative self-assertion and doesn't meet the specificity threshold. That puts this at Level 4.


reasoning: Per Rule 3, third parties hired to serve the company's own security (assessors, consultants) → RMP. The paragraph describes engaging external experts to evaluate and test the company's own risk management systems, not imposing requirements on vendors. For specificity, the vocabulary is entirely general business language — 'cybersecurity consultants,' 'risk management systems,' 'industry best practices,' 'regular audits,' 'threat assessments,' and 'security enhancements' all pass the ERM test (a non-security risk professional would naturally use these terms). No domain terminology, no firm-specific facts, no verifiable claims.

thinking:
Let me classify this paragraph.

Content: Describes engaging external experts/consultants to evaluate and test risk management systems, including audits, threat assessments, and consultation on security enhancements.

Category: This is about third parties hired to serve the company's own security program. Per Rule 3, "Third parties hired to serve the company (assessors, consultants, pen testers) → RMP." The central topic is using external experts as part of their own program, not imposing requirements on vendors. → RMP

Specificity: Let me scan for facts.
- "cybersecurity consultants" - unnamed, not firm-specific
- "regular audits, threat assessments, and consultation on security enhancements" - "threat assessments" could be domain terminology...

Now I'm testing whether the language is specific to cybersecurity or generic enough for an ERM professional. Most of these terms—"cybersecurity consultants," "risk management systems," "industry best practices," "audits," "security enhancements"—are fairly general business language. "Threat assessments" is borderline; while it has a cybersecurity flavor, an ERM professional could reasonably use it too, so it probably doesn't push this into domain-specific territory.

This is Level 1 language overall.


reasoning: This paragraph describes the general cyber threat landscape without disclosing anything about the company's own cybersecurity program, governance, or incidents — it answers none of the six substantive questions. The language is entirely generic business/risk commentary with no domain terminology, firm-specific facts, or verifiable claims.


reasoning: The paragraph describes a governance chain (Board ← Audit Committee ← CEO) with the purpose of explaining how material threats reach the Board and who operates under whose oversight — answering 'how does the board oversee cybersecurity?' per the BG default for governance-chain paragraphs. Specificity is Level 1 because 'Audit Committee' and 'CEO' are generic governance roles present at every public company, 'third-party consultants' are unnamed, and 'assessment and management of cybersecurity threats' is standard ERM language with no domain terminology.

thinking:
Let me analyze this paragraph.

Content: Describes management's responsibility to manage cyber threats and report to the Board. The CEO is responsible under Audit Committee oversight, uses third-party consultants.

Category: This is a governance-chain paragraph. It mentions Board, Audit Committee, CEO, and third-party consultants. The primary question answered is about oversight structure - how the board oversees (Audit Committee oversight) and who is responsible (CEO).

The paragraph starts with "management's responsibility" and describes the CEO's role under Audit Committee oversight. It's describing the oversight chain. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure.

I'm noticing the tension here between the Board's oversight role through the Audit Committee and the CEO's primary responsibility. The core question is whether this is fundamentally about how the board oversees cybersecurity or about management's operational responsibility. Reading it again, the structure flows from Board → Audit Committee → CEO, which points to BG as the default category for this oversight chain.

Looking at the specificity markers: Audit Committee and CEO are generic governance roles, not firm-specific or cybersecurity-specialized, and the third-party consultants mentioned are unnamed. There's no domain-specific terminology here either, so this reinforces the BG classification.


reasoning: The paragraph primarily answers 'how are third-party cyber risks managed?' — it describes assessing and managing cybersecurity threats from third-party service providers, making TP the central topic. However, the language is entirely generic business vocabulary ('assesses and manages,' 'communicated to management for review, response, and mitigation') with no domain terminology, firm-specific facts, or verifiable claims, yielding Level 1.

thinking:
Classify this paragraph.

The paragraph discusses managing cybersecurity threats from third-party service providers - this is about third-party risk management. But let me check: is the central topic vendor oversight?

"assesses and manages cybersecurity threats associated with its third-party service providers' information technology systems" - this is about managing third-party cyber risks.

Second sentence: "Identified cybersecurity threats are communicated to management for review, response, and mitigation" - this is about internal process for handling identified threats.

The first sentence is clearly about third-party risk. The second sentence is generic process. The central topic is third-party risk management.

Now I'm checking the specificity level. The language here is entirely generic - "third-party service providers," "information technology systems," "cybersecurity threats," "management" - all standard business terminology with no domain-specific jargon or firm-specific details. This reads like something an ERM professional could say about any risk domain, which puts it at Level 1. The category is Third-Party Risk since the paragraph answers how third-party cyber risks are managed, though the description is extremely generic.


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

reasoning: The paragraph describes the company's program design and assessment methodology using NIST CSF, answering 'what does the cybersecurity program do?' → RMP. NIST CSF is domain terminology elevating to Level 2, but the paragraph explicitly disclaims certification ('does not mean that we meet any particular technical standards'), so it remains an alignment reference rather than a verifiable claim. No firm-specific or QV-eligible facts are present.

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 disclaims certification ("does not mean we meet any particular technical standards"). No firm-specific facts, no QV facts.


content_category: Incident Disclosure

reasoning: The paragraph describes the operational impact and recovery from an actual cybersecurity incident — system shutdowns, manufacturing disruption, delayed order fulfillment, and full IT restoration — answering 'what happened?' No domain terminology, named external entities, specific dates, verifiable numbers, or firm-specific cybersecurity facts are present; the descriptions use general business/operational language (manufacturing, retail, wholesale, IT systems) without cybersecurity-specific vocabulary.

thinking: Incident disclosure - describes what happened after a cybersecurity incident.


reasoning: The paragraph answers 'how is management organized to handle cybersecurity?' by listing responsibilities assigned to the CFO and Head of IT; the person-removal test collapses it to a floating list of duties, confirming MR. Both 'CFO' and 'Head of IT' are explicitly on the NOT firm-specific list, and the described responsibilities (hiring, budgets, reviewing assessments, preparing for incidents) use only general business/ERM language with no domain terminology, yielding Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes CFO and Head of IT responsibilities - hiring, integrating cyber risk, communicating priorities, approving budgets, preparing for incidents, approving processes, reviewing assessments.

Category: This is about management's organizational role - who is responsible and what their responsibilities are. Person-removal test: remove "Our Chief Financial Officer and Head of IT" - what remains is a list of responsibilities without anyone to attach them to. The paragraph collapses. → MR

Specificity:
- "Chief Financial Officer" - CFO is listed as NOT firm-specific (generic governance role)

- "Head of IT" is also generic, not firm-specific
- The responsibilities listed use standard business language with no domain-specific terminology, no QV facts, and no firm-specific details

This falls under Level 1.


fact: cybersecurity awareness training

reasoning: The paragraph answers 'what does the cybersecurity program do?' by listing program components (risk assessments, offsite backups, external service providers, training), making it RMP. 'Cybersecurity awareness training' is a domain-specific security practice (listed in the codebook as 'security awareness training'), elevating to Level 2. The remaining items (risk assessments, offsite backup, external service providers) are general business/IT terms that fail the ERM test. No firm-specific or verifiable facts are present.

thinking:
Let me classify this paragraph.

Content: Describes what the cybersecurity program includes - risk assessments, offsite backup, external service providers, cybersecurity awareness training.

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

Specificity: Let me check for facts.
- "risk assessments" → general ERM language, Level 1
- "offsite backup storage" → general IT, Level 1
- "external service providers" → unnamed, generic
- "cybersecurity awareness training" → this is a domain term? Let me check. The codebook lists "Security awareness training" as domain terminology. "Cybersecurity awareness training" is essentially the same thing. → Level 2

- The "cybersecurity awareness training" reference to domain terminology pushes this to Level 2 overall.


fact: Relies on risk management, legal, information technology, and compliance personnel of the Adviser

reasoning: The paragraph's central topic is how the company oversees cybersecurity risks from third parties (suppliers, vendors, service providers), answering 'how are third-party cyber risks managed?' The specific enumeration of the Adviser's functional areas (risk management, legal, IT, compliance) constitutes a firm-specific team composition, but there is no cybersecurity domain terminology or verifiable facts. The CCO is a generic compliance role, not a cybersecurity-specific title.

thinking:
Let me analyze this paragraph.

Content: Discusses how the company manages cybersecurity risks from third parties (suppliers, vendors, service providers). It mentions relying on the Adviser's personnel and the CCO's oversight role regarding these entities.

Category: The central topic is oversight of third-party cybersecurity risks. "How are third-party cyber risks managed?" → Third-Party Risk. The paragraph describes how the company oversees cybersecurity risks from external entities.

Wait - let me reconsider. The paragraph mentions third parties but the content is about WHO oversees these risks (the Adviser's personnel, the CCO).

Actually, re-reading: "identifying and overseeing risks from cybersecurity threats associated with its use of such entities" - this is about how third-party cyber risks are managed. The central topic is third-party risk oversight. Even though it mentions roles, the purpose is answering "how are third-party cyber risks managed?" The paragraph is fundamentally about the company's approach to managing third-party cybersecurity risks, not just the organizational structure. Rule 3 applies here: the focus is on vendor oversight as the central topic → TP.

Specificity: "Chief Compliance Officer ('CCO')" - CCO is listed as NOT firm-specific (generic role), so this doesn't add specificity points.

"The Adviser" is a named entity reference specific to the investment company structure, but it's not a named external firm. "Risk management, legal, information technology, and compliance personnel" names specific departments, which the codebook indicates counts as firm-specific. But these are the Adviser's own personnel, not an external vendor's team composition, so I need to consider whether this still qualifies as firm-specific in the context of third-party risk management.

Actually, looking at this more carefully—the codebook example of "Legal, Compliance, and Finance" being firm-specific suggests that naming specific functional areas does count. So this team composition would be Level 3. CCO isn't a cybersecurity-specific title, so that's not firm-specific on its own. And there's no real domain terminology here—just general references to cybersecurity threats and preparedness. So the classification comes down to the specific team composition by department.


reasoning: This paragraph answers 'what does the cybersecurity program do?' by describing risk assessments as a key element, making it RMP. The language is entirely generic — 'risk assessments,' 'identify material risks,' 'critical systems' — all terms a non-security ERM professional would naturally use. No domain terminology, firm-specific facts, or verifiable claims are present.


reasoning: The paragraph answers 'what does the cybersecurity program do?' but only at the most generic level — 'processes intended to protect confidentiality, integrity and availability' is standard business language. No domain terminology, firm-specific facts, or verifiable claims are present. 'Confidentiality, integrity and availability' is the CIA triad concept but expressed here as general business language rather than technical jargon, and the rest is boilerplate risk language any company could use.


reasoning: The paragraph describes requirements imposed on third-party service providers (security measures, legal compliance, breach reporting), directly answering 'how are third-party cyber risks managed?' No domain terminology, firm-specific facts, or verifiable claims are present — the language is entirely generic ('appropriate security measures,' 'reasonable security measures,' 'applicable laws') and could appear in any company's filing unchanged.

thinking:
Classify this paragraph.

Content: Requirements imposed on third-party service providers regarding security measures, compliance with laws, and breach reporting.

Category: This answers "How are third-party cyber risks managed?" — requirements imposed ON vendors → Third-Party Risk.

Specificity: Let me scan for facts.
- "third-party service provider" — generic
- "appropriate security measures" — generic
- "consistent with all applicable laws" — generic
- "reasonable security measures" — generic
- "promptly report any suspected breach" — generic

No domain terminology (no specific security practices, tools, frameworks). No firm-specific facts. No QV facts.

The language here is boilerplate—the kind of vendor requirements any organization would include in their contracts. This is Level 1 specificity.


reasoning: The paragraph states a materiality conclusion ('have not materially affected... are not reasonably likely to materially affect... business strategy, results of operations, or financial condition'), which is 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 assertion about no incidents is a self-reported absence claim, not externally verifiable — so specificity remains Level 1.

thinking:
Materiality assessment + cross-reference.

The paragraph states a conclusion about materiality: "have not materially affected... are not reasonably likely to materially affect" → SI per Rule 5.

The cross-reference to Item 1A is subordinate.

Specificity: "have not materially affected... business strategy, results of operations, or financial condition" — this is boilerplate SEC language. No domain terms, no firm-specific facts, no verifiable claims. The negative assertion about no incidents is not verifiable. Level 1.


fact: Chief Technology Officer (CTO) providing oversight

fact: over 25 years' experience in cybersecurity

reasoning: The paragraph primarily answers 'how is management organized?' — it names the CISO as primarily responsible, describes oversight from CTO and COO, and details the CISO's qualifications. Person-removal test leaves only generic risk language, confirming MR. 'Over 25 years' experience' is a lower-bound quantified fact (≥25) that is independently verifiable, elevating to Level 4.

thinking:
Let me classify this paragraph.

Content: About CISO's role, oversight from CTO and COO, CISO's experience (25+ years), ongoing knowledge. Person-removal test: remove CISO, CTO, COO, 25 years experience → "assessing and managing cybersecurity risks... latest developments in cybersecurity, including potential threats and innovative risk management techniques... prevention, detection, mitigation, and remediation of cybersecurity incidents." This is generic risk language, not a substantive program description. → MR.

Specific facts:
- CISO → named_role (firm-specific)

- CTO → named_role (firm-specific)
- COO → general executive role, not cybersecurity-specific, so doesn't count as firm-specific per the codebook
- "over 25 years' experience" → quantified and verifiable

This gives me MR at Level 4.


reasoning: The paragraph primarily answers how the board oversees cybersecurity — describing the board's role, the decision not to receive regular reports, and the conditions under which management would escalate to the board. No domain terminology, firm-specific facts, or verifiable claims are present; 'third-party IT firm' is unnamed, and all language is general business/risk vocabulary.

thinking:
Let me analyze this paragraph.

Content: The board oversees risk, management determined no regular cyber reports to board are needed, but would report material changes, and consults with third-party IT firm.

Category: This is about board oversight (or lack thereof) of cybersecurity. The primary question answered is "How does the board oversee cybersecurity?" — even though the answer is essentially "they don't regularly, but management would report if needed." This is BG.

Specificity: Let me scan for facts.
- "full board of directors" — generic, every company has one

- "management" — generic
- "third-party IT firm" — unnamed, not firm-specific
- No domain terminology — "IT systems," "cybersecurity," "security protections and best practices" are all general business language
- No specific numbers, dates, named entities, or certifications

This is Level 1 — Generic Boilerplate.


reasoning: The paragraph directly answers 'How are third-party cyber risks managed?' with vendor oversight as the central topic — due diligence and cybersecurity risk identification for vendors/service providers. Specificity is Level 1: the language ('rigorous due diligence,' 'oversight and identification of cybersecurity risks,' 'vendors and service providers') is generic business/ERM language with no domain terminology, firm-specific facts, or verifiable claims.


fact: CISO

fact: CRO

fact: RACC (Risk, Audit, and Compliance Committee — named non-generic committee)

fact: cyber defense

fact: application and product security

fact: more than 20 years of experience

reasoning: The paragraph's primary content is how management is organized to handle cybersecurity — the CISO's responsibilities, qualifications (20+ years experience), appointment by RACC, and reporting structure with the CRO. While it also describes program activities (incident response, evaluations, vendor engagement), the person-removal test shows the framing and emphasis center on the CISO's organizational role. Specificity reaches Level 4 because 'more than 20 years of experience' is a lower-bound quantified fact that is independently verifiable against the individual's career history.

thinking:
Let me analyze this paragraph carefully.

**Content Category:**
This paragraph covers multiple topics. Let me break it down:
- CISO role and team responsibilities
- CISO qualifications (20+ years experience)
- RACC oversight and reporting structure
- Information security program activities (incident response, evaluations)
- Engagement with vendors and law enforcement

The primary question: This is a complex paragraph. It starts with management organization (CISO role), then moves to qualifications, then reporting to RACC, then program activities.

Person-removal test: Remove CISO, CRO, their experience, reporting lines, team composition.

What remains? "Our information security program... includes incident response procedures... is regularly evaluated by internal and external experts... We also actively engage with key vendors, industry participants and intelligence and law enforcement communities..."

There's still substantive program description remaining. But the bulk of the paragraph is about the CISO's role, qualifications, and reporting structure to RACC. The paragraph is really structured around organizational roles and governance—the CISO manages the program and reports to RACC, which oversees it, and then it lists what the program actually does. Most of the content focuses on who's responsible and how they're organized rather than what the program accomplishes. what flows to oversight)
6. Incident response procedures with escalation (RMP with governance elements)
7. Program evaluated by internal/external experts (RMP)
8. Engage with vendors, industry, law enforcement (RMP)

The first half centers on the CISO's role, qualifications, and reporting chain to the RACC—that's clearly Management Role content. The second half shifts to describing actual program activities. Text-wise they're roughly balanced, but the paragraph leads with and emphasizes the organizational structure and the CISO's position, so this reads as primarily Management Role with program description as supporting context.

Looking at specificity: "CISO" is a named firm role at VP-level equivalent, "more than 20 years of experience" is a verifiable lower bound, "CRO" is the Chief Risk Officer title, and "RACC" is the specific committee name. All firm-specific identifiers.

The generic elements—quarterly cadence, domain terms like application security and risk management, incident response procedures, and strategy/policy/standards language—don't push toward higher specificity. The lower bound on experience qualifies as Level 4 verifiable, and the named committee is Level 3 firm-specific, so this lands at Level 4 overall.


reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing reviewing and updating systems/processes to safeguard against threats; the third-party consultants serve the company's own program (Rule 3 → RMP). All language is generic business risk management ('review and update systems, processes and procedures,' 'safeguard against potential threats') with no domain terminology, no firm-specific facts (third-party consultants are unnamed), and no verifiable claims.

thinking:
Let me classify this paragraph.

Content: Describes reviewing/updating systems against threats, mentions third-party consultants review attacks. Mix of generic risk language and a brief mention of third-party consultants.

Category: "What question does this primarily answer?" It's about reviewing and updating systems/processes to safeguard against threats - this is about what the cybersecurity program does (RMP). The third-party mention is subordinate (Rule 3: third parties serving the company → RMP). The "no guarantee" language is generic risk caveat, not a materiality assessment.

→ RMP

Now scanning the specificity here. The language about regularly reviewing and updating systems is standard boilerplate, the third-party consultants aren't named or firm-specific, and there's no domain terminology or concrete facts about the company's actual practices. This is clearly Level 1 generic material.


fact: threat intelligence

fact: tactics, techniques, and procedures (TTPs) utilized by threat actors

fact: phishing exercises

fact: monitoring and detection of cybersecurity environment

fact: cybersecurity incident response plan ("CIRP") — named internal program with distinguishing identifier

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing threat intelligence, training, phishing exercises, third-party monitoring, vendor assessments, and an incident response plan — all program activities (RMP). While third-party vendor assessment is mentioned, it is one component among many, not the central topic. Specificity reaches Level 3 because the 'cybersecurity incident response plan ("CIRP")' is a named internal program with a distinguishing identifier, qualifying as firm-specific per the codebook.

thinking:
Let me analyze this paragraph.

Content Category: This paragraph describes multiple cybersecurity program activities - threat intelligence, training, phishing exercises, third-party monitoring, vendor assessments, and incident response plan. The primary question it answers is "What does the cybersecurity program do?" → RMP

There's some third-party content (vendor assessments, third-party monitoring), but it's part of a broader program description, not the central topic.

Specificity: Let me scan for facts:
- "threat intelligence" - domain term

- "tactics, techniques, and procedures" - domain term (TTPs)
- "phishing exercises" - domain term
- "monitoring and detection" - could be generic, but in cybersecurity context
- "cybersecurity incident response plan ("CIRP")" - named internal program with distinguishing identifier → firm-specific
- "third-party service provider to provide monitoring and detection" - unnamed, not QV

The named program CIRP with its distinguishing identifier qualifies as firm-specific per the codebook, so this lands at Level 3.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by explaining the company relies entirely on its external Manager's processes for assessing, identifying, and managing cybersecurity risks — this is a description of the risk management approach, albeit a delegated one. Specificity remains Level 1 because the language ('processes for assessing, identifying, and managing material risks from cybersecurity threats') is generic ERM phrasing with no domain terminology; 'Bimini' is a related-entity/parent name akin to a subsidiary reference, which is not firm-specific under the codebook.

thinking:
Let me analyze this paragraph from Orchid Island Capital's 10-K filing.

The company is externally managed and relies on its Manager for IT and cybersecurity. It mentions relying on the Manager's processes for "assessing, identifying, and managing material risks from cybersecurity threats." The last sentence notes executive officers are also officers/directors/employees of Bimini.

Category: This is describing the company's risk management arrangement - but it's really saying "we don't have our own program, we rely on our Manager." The primary question it answers is about how cybersecurity risks are managed - through the external manager. This could be RMP or could be N/O given the lack of substantive disclosure.

Actually, I'm reconsidering - the paragraph does articulate a risk management approach by describing how the Manager's processes handle cybersecurity threats. Even though it's generic language about assessing and identifying risks, it's still substantive enough to indicate a program exists through the external manager rather than claiming no program at all. The Bimini reference is just organizational context. This feels more like RMP than N/O because it actually answers what the cybersecurity program does, even if the answer is "we delegate to our Manager."

On specificity, the "assessing, identifying, and managing material risks" phrasing is standard ERM boilerplate - that's Level 1. But Bimini itself is a named entity identifying the specific parent company managing this arrangement, which makes it firm-specific in that sense, though it's not a cybersecurity role or committee per se.

Actually, wait - the codebook treats parent and subsidiary names as non-firm-specific references. Bimini is just the manager's name, similar to how you wouldn't count a subsidiary name as firm-specific. So there's really nothing here that qualifies as firm-specific language. It's all generic risk management terminology, which puts this at Level 1.


reasoning: This paragraph acknowledges threats generically and cross-references Item 1A for further discussion, without providing any substantive cybersecurity disclosure. It's a cross-reference paragraph with speculation ('threats are severe') — N/O with no domain terminology or specific facts.


reasoning: The first sentence states a materiality conclusion — both backward-looking ('materially affected') and forward-looking ('reasonably likely to materially affect') — making this SI per Rule 5. Specificity is Level 1: 'In 2024' is reporting-period context not a cybersecurity fact, the negative materiality assertion is not externally verifiable, and the remaining text is generic hedging and a cross-reference to Item 1A.

thinking:
Let me analyze this paragraph.

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

Category: The first sentence is a materiality assessment - "did not identify any privacy or cybersecurity threats that materially affected or are reasonably likely to materially affect our business strategy, results of operations, or financial condition." This is SI per Rule 5 (backward-looking + forward-looking assessment). The second sentence is hedging/speculation. The third is a cross-reference (N/O). But the primary content is the materiality conclusion → **Strategy Integration**.

The language here is generic boilerplate—just temporal framing and negative self-assertions without any concrete cybersecurity facts, domain-specific details, or company-specific vulnerabilities. This is clearly Level 1 materiality language.


fact: firewalls

fact: vulnerability and patch management processes

fact: access controls

fact: phishing tests

fact: security awareness training

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing implemented controls, tools, and processes; the third-party mention is subordinate assistance to the company's own program (Rule 3 → RMP). Multiple cybersecurity domain terms (firewalls, IDS/IPS, vulnerability and patch management, phishing tests) elevate to Level 2, but no firm-specific facts or verifiable claims are present.

thinking:
Let me analyze this paragraph from VERU INC.'s 10-K filing.

**Content Category:**
This paragraph answers "What does the cybersecurity program do?" — it describes cybersecurity measures, controls, tools, and processes. Third-party service provider is mentioned but as assistance to the company's own program (Rule 3 → RMP). This is clearly **Risk Management Process**.

**Specificity:**
Let me scan for facts:

Domain terms (Level 2):
- firewalls
- intrusion detection and prevention systems (IDS/IPS)

- vulnerability and patch management
- phishing tests
- security awareness training
- access controls

These are all standard cybersecurity domain terms that pass the ERM test.

Firm-specific (Level 3): Nothing unique to this company specifically.

QV (Level 4): No named external entities, no specific numbers, no dates, no certifications held.

Specificity = Level 2 (Domain-Adapted)


reasoning: The paragraph describes how a board-level committee receives cybersecurity reports from management and gets updates on incidents, directly answering 'how does the board oversee cybersecurity?' No domain terminology, firm-specific facts, or verifiable claims are present — 'the Committee,' 'management,' and 'periodic reports' are all generic governance language found at any public company.

thinking:
Classify this paragraph.

Category: This describes how the Audit Committee receives reports from management about cybersecurity risks and incidents. It answers "How does the board oversee cybersecurity?" → Board Governance.

Specificity: Let me scan for facts.
- "The Committee" - generic (Audit Committee implied), not firm-specific
- "periodic reports" - generic cadence
- "management" - generic
- "cybersecurity risks" - general business language
- "cybersecurity incidents" - general

No domain terminology (no specific security practices/tools), no firm-specific facts (no named roles beyond generic "Committee" and "management"), no QV facts.

Level 1.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' by describing the Board's oversight role and acknowledging lack of expertise — classic BG content. No domain terminology, no firm-specific facts (only generic 'Board'), and no verifiable claims, so Level 1.


reasoning: The paragraph primarily answers 'how are third-party cyber risks managed?' — describing outsourcing of financial records to a third-party accounting firm and stating that consideration of provider cybersecurity protections is part of the engagement decision. This is vendor oversight as the central topic. Specificity is Level 1 because all language is general business terminology ('cybersecurity protections and procedures,' 'service provider,' 'management's decision') with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Let me analyze this paragraph.

This is a small company explaining their minimal IT systems and that they outsource bookkeeping to a third-party firm, relying on that firm's cybersecurity protections.

Category: The paragraph describes how they manage third-party cyber risks - they consider the protections of their service providers. But it also describes their general situation. The central topic is about relying on a third party's cybersecurity and how they evaluate providers. This feels like Third-Party Risk - "How are third-party cyber risks managed?" The paragraph describes their reliance on and evaluation of third-party cybersecurity.

Actually, I'm reconsidering the framing here. They're explaining their approach to third-party oversight through outsourcing decisions and reliance on provider protections, which does constitute substantive disclosure about third-party risk management. But looking at the specificity - there's no domain terminology beyond generic references to "cybersecurity protections," no named roles, and no firm-specific facts that would indicate deeper engagement with the topic.

The paragraph is fundamentally about their minimal IT footprint and outsourcing arrangement, with cybersecurity treated as a secondary consideration in provider selection. This is third-party risk management, but it's entirely generic business language without the technical depth or organizational specificity that would elevate it beyond Level 1.


reasoning: The paragraph answers 'How does the board oversee cybersecurity?' describing Board of Directors and audit committee oversight, briefing cadences, and independent director composition — all classic BG content. Specificity is Level 1 because the paragraph contains no domain terminology (no specific security practices or frameworks), no firm-specific facts (Board of Directors, audit committee, and independent directors exist at every public company; 'Dropbox' is a self-reference), and no QV-eligible facts (generic cadences like 'at least once a year' and 'at least quarterly' are not verifiable specific dates).

thinking:
Let me classify this paragraph.

Content: Board and audit committee oversight of cybersecurity. This answers "How does the board oversee cybersecurity?" → Board Governance.

Specificity analysis:
- "Board of Directors" - generic, every company has one
- "audit committee" - generic (Audit Committee exists at every public company)
- "independent directors" - generic governance term
- "at least once a year" / "at least quarterly" - generic cadences
- "cybersecurity risk management" - general term
- "Dropbox's business strategy" - company self-reference

No domain terminology (no specific security practices/tools/frameworks).

There are no firm-specific facts or cybersecurity-specific roles mentioned, just standard governance structures. This is Level 1 - Generic Boilerplate.


fact: NIST (National Institute of Standards and Technology) framework

fact: ISO (International Organization for Standardization) framework

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

reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing framework adoption (NIST, ISO), annual risk assessments, and the company-wide approach to managing cybersecurity risks — all program activities → RMP. NIST and ISO are named standards referenced as alignment (not certification), and the CIA triad is domain terminology, elevating to Level 2 but no higher since there are no firm-specific or verifiable facts.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity program - frameworks (NIST, ISO), risk assessments, and general approach to managing cybersecurity risks.

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

Specificity:
- "NIST" and "ISO" are named standards → domain terminology → Level 2
- "confidentiality, integrity, and availability" - CIA triad, domain concept → Level 2
- No firm-specific facts (no named roles, committees, etc.)
- No QV facts - "aligned with" NIST/ISO, not certified → Level 2

- The references to NIST and ISO are framework alignments rather than formal certifications, confirming this stays at Level 2.


fact: virtual Chief Information Security Officer (vCISO)

reasoning: The paragraph describes how third-party risk information flows to management and the Board via a quarterly summary—answering 'how does the board oversee cybersecurity?' The governance-chain rule places this in BG since the purpose is describing the reporting/oversight structure, not the substance of third-party risk management itself. The vCISO title is a firm-specific cybersecurity leadership role elevating specificity to Level 3, but no verifiable facts (specific numbers, dates, named external entities) are present.

thinking:
Let me analyze this paragraph.

Content: describes a vCISO compiling quarterly executive summary of third-party risk, presented to management and Board, for data-driven decisions on third-party engagements.

Category: This answers "How does the board oversee cybersecurity?" - information flows to the board about third-party risk. But it also touches on third-party risk and management role.

The primary purpose is describing how information flows to leadership (both management and Board) about third-party risk. The governance-chain rule says these default to BG when describing oversight structure. The paragraph describes how information flows to the board - that's BG.

The real question is whether the focus is on the reporting mechanism itself or vendor requirements. Since this is about a quarterly summary presented to leadership rather than what's actually demanded of vendors, it's clearly BG. The vCISO role is firm-specific and the quarterly cadence is generic, putting this at Level 3 specificity.


fact: threat detection

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' — it describes using employees and contracted third-party firms for program evaluation, monitoring, threat detection, and assessments. The third parties here serve the company's own program (Rule 3 → RMP), and the notification requirement is subordinate to the overall program description. 'Threat detection' passes the ERM test as domain-specific terminology, but the rest of the language (assessments, monitoring, mitigation) is generic business/risk management vocabulary, yielding Level 2.

thinking:
Let me analyze this paragraph.

Content: Describes using employees and third-party firms for security program evaluation, monitoring, threat detection, and assessment. Also mentions requiring third parties to notify of risks/threats/incidents.

Category: This is primarily about what the cybersecurity program does - using employees and third parties for monitoring, assessment, threat detection. The third-party mention is as a component of the internal program (Rule 3: third parties hired to serve the company → RMP; third parties mentioned as one component of internal program → RMP). The notification requirement could lean TP, but it's subordinate to the overall program description. → RMP

Now I'm checking the language for specificity. Most of the terms here are fairly generic—continuous monitoring, assessments, and information security program are standard process descriptions. "Threat detection" is somewhat domain-specific to cybersecurity, though it could be used by a general ERM professional. The third parties mentioned are unnamed and not firm-specific, which keeps this at a general level rather than pointing to particular vendors or services.

Looking at the codebook's exclusions, "continuous system monitoring" overlaps with "regular monitoring," and while "threat detection" shows some domain knowledge, it's borderline. I think this lands at Level 2 with "threat detection" as the domain-specific terminology that tips it slightly above purely generic language.


reasoning: This paragraph is a cross-reference pointing readers to Item 1A for materiality discussion. It describes what another section covers rather than stating a materiality conclusion itself, making it N/O per the codebook rule ('risks that may materially affect... see Item 1A' → N/O). No substantive cybersecurity disclosure is present, so specificity is Level 1.


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


reasoning: The paragraph is a general preamble acknowledging cybersecurity threats, listing types of IT systems at risk, and cross-referencing Item 1A Risk Factors. It describes no actual cybersecurity measures, processes, or governance structures — only that the company 'devot[es] resources' (vague) and that incidents 'could negatively impact' the business (speculation, not a materiality assessment). The cross-reference to Item 1A and generic threat definition provide no substantive disclosure. N/O always receives Specificity 1.

thinking:
Let me analyze this paragraph.

Content: The paragraph discusses the company's commitment to securing IT systems, references risk factors, acknowledges cybersecurity threats, and defines what cybersecurity threats include. It doesn't describe specific processes, governance, or incidents. It's mostly general risk acknowledgment language with a cross-reference to Item 1A.

Category: This is general risk language with a cross-reference. No specific cybersecurity measures are described. The mention of "accounting software, point-of-sale software, and back-of-house software" names types of systems but doesn't describe what the program DOES. The paragraph acknowledges threats exist and references Item 1A.

The language here is speculative rather than substantive—"could negatively impact" signals speculation, not actual assessment. There are no real cybersecurity measures outlined, just vague references to "devoting resources to secure." This is essentially a preamble that defines cybersecurity threats generically and points elsewhere for details, so it lands as N/O with a Level 1 specificity rating.