content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the governance chain and reporting cadence between IT Management and the Risk Committee, focusing on how oversight is exercised and information flows upward to the board level. The mention of the 'Risk Committee' (a non-generic committee name) provides the single firm-specific detail needed for this classification.

provider: moonshotai

stage: benchmark


content_category: None/Other

reasoning: The paragraph contains generic statements about cybersecurity importance and threat types (ransomware, denial-of-service) without describing specific governance structures, management roles, internal processes, or actual incidents. The materiality language ('could materially adversely affect') constitutes generic risk speculation rather than a specific materiality assessment per SEC guidance.


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal workflow for threat monitoring, incident detection, severity assessment, and escalation procedures, including the cross-functional team composition and reporting cadence to executive leadership. While the Sr Director of Tech is mentioned as a key node in the process, the disclosure focuses on operational procedures rather than the individual's qualifications or board governance structure.


reasoning: The paragraph describes the governance chain and information flow for cybersecurity oversight: the CISO informs the Cybersecurity Executive Steering Body, and significant matters are elevated to the Audit Committee/Board. This describes the oversight structure and reporting cadence to the board, which is Board Governance. It contains the cybersecurity-specific title 'CISO' and the named non-generic committee 'Cybersecurity Executive Steering Body'.


reasoning: The paragraph describes internal processes for managing cybersecurity risk, including reporting flows to executive leadership and integration into the enterprise risk management program via internal audit. While the Chief Security and Trust Officer is mentioned, the focus is on the process and structure of risk management rather than the officer's qualifications or board-level governance.


reasoning: The paragraph consists primarily of forward-looking disclaimers about security limitations and a cross-reference to Item 1A Risk Factors. It contains no substantive description of governance, management, processes, or incidents, and does not include a materiality assessment (only speculative risk language and a pointer to where risks are discussed).


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including protocols, third-party assessments, ISO 27001 alignment, incident response planning, and employee training. While the CFO is mentioned as overseeing the program, the content focuses on the processes and frameworks rather than the individual's qualifications or identity, satisfying the Risk Management Process criteria. The disclosure names the ISO 27001 standard but lacks firm-specific details such as dates, headcounts, or named vendors, resulting in Sector-Adapted specificity.


reasoning: The paragraph describes the governance chain linking the risk management program to the board through the CISO's reporting relationship to the IT/Cybersecurity Committee, which constitutes oversight structure. It is not merely describing internal processes (RMP) nor the CISO's personal qualifications (MR), but rather how cyber risk information flows upward to the board.


content_category: Strategy Integration

reasoning: The paragraph contains a negative materiality assessment ('we have not experienced a material cybersecurity incident'), which the guidelines explicitly classify as Strategy Integration. The text is generic boilerplate beginning with 'Like other businesses' and contains no specific dates, named roles, frameworks, or verifiable facts unique to the company.


reasoning: Paragraph contains generic, forward-looking risk disclaimers ('there can be no assurance') and references to Item 1A Risk Factors. While it mentions past 'efforts' by bots to access systems, it explicitly states these were 'prevented' without providing dates, scope, affected systems, or response actions required for Incident Disclosure. No substantive disclosure about governance, management, or risk management processes is provided.


reasoning: The paragraph describes the governance structure for risk oversight, specifically that the full Board (rather than a committee) oversees risk management and receives reports from the Chief Risk Officer. This fits the Board Governance definition of describing oversight structure and information flow, even though a management role (CRO) is mentioned as part of the reporting chain.


content_category: Management Role

reasoning: The paragraph focuses on identifying a specific cybersecurity role (Senior Principal Security and Infrastructure Architect) and detailing their professional experience (over 20 years), which centers on WHO manages the processes rather than describing the processes themselves. The specific tenure and unique title provide firm-specific details.


reasoning: This paragraph contains standard forward-looking risk disclaimer language ('could have a material adverse effect') that appears in virtually all 10-K filings. It describes hypothetical threats and potential impacts without disclosing specific governance structures, management roles, risk management processes, actual incidents, or materiality assessments. The generic speculation about possible future effects does not constitute a substantive cybersecurity disclosure or a materiality assessment as defined in the taxonomy.


reasoning: The paragraph describes the company's internal risk management processes, specifically how risk management is embedded into business processes and how the enterprise risk management team collaborates with the CSO and IT risk team to evaluate and address risks. The mention of a Chief Security Officer (a cybersecurity-specific role) provides a firm-specific detail, but the paragraph lacks quantifiable metrics or named standards.


reasoning: The paragraph describes the company's cybersecurity organizational structure and internal processes, including the CISO-led InfoSec function, specific governance committees (InfoSec Steering Committee, InfoSec Governance Review Board), and alignment with the NIST Framework. While it names the CIO and CISO, the focus is on the program's operational structure and components rather than individual qualifications or biographical details, making it Risk Management Process rather than Management Role.


reasoning: The paragraph describes a governance chain delegating authority from the Enterprise Risk and Return Council to the Information Security Council (ISC) chaired by the CISO, with specific departmental representation, which constitutes oversight structure rather than individual qualifications or operational processes. It contains multiple firm-specific elements including named non-generic committees (Enterprise Risk and Return Council, ISC), a cybersecurity-specific role (CISO), and specific departmental composition (Privacy, Legal and Technology).


reasoning: The paragraph describes the governance chain and oversight structure for cybersecurity risk, detailing how the Information Security Department reports through the CISO and Chief Risk Officer to the Risk Management Council and ultimately to the Board Risk Committee. This focuses on the oversight structure and information flow to the board rather than individual officer qualifications or specific risk management processes.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity threat descriptions. It contains no substantive disclosure about the company's cybersecurity governance, management, processes, or incidents, and per the guidelines, cross-references with materiality language are classified as None/Other.


reasoning: Paragraph consists entirely of materiality assessments—both backward-looking ('have not materially affected') and forward-looking with SEC qualifier ('reasonably likely to materially affect')—concluding that cybersecurity threats and incidents have not had material impacts on the company. This matches the Strategy Integration definition for materiality assessments. The language is entirely boilerplate with no company-specific details, dates, or quantified facts.


reasoning: The paragraph details the company's internal incident response workflow, including threat identification, severity assessment, and escalation procedures. While it mentions reporting to the Board and Audit Committee, the primary focus is on operational processes rather than governance structure or individual qualifications. The disclosure includes firm-specific details regarding the cybersecurity-specific title 'VP of Tech' and the specific cross-functional team composition.


reasoning: The paragraph describes internal cybersecurity processes (the 'three lines of defense' model, incident monitoring, and response procedures) rather than specific management qualifications or board governance structures. It contains no named standards, specific dates, cybersecurity-specific titles, or other verifiable facts unique to the company.


reasoning: This is a cross-reference pointing readers to Item 1A for cybersecurity risk factors rather than providing substantive disclosure. Per the tiebreaker rules, cross-references with materiality language are classified as None/Other because they point elsewhere rather than stating a conclusion about the company's condition.


reasoning: The paragraph describes the governance chain and oversight structure, specifically how the ITSC and Chief Information Officer report cybersecurity matters to the Board of Directors quarterly. While it mentions integration with risk management, the primary purpose is to explain the upward information flow to the board. The disclosure includes firm-specific elements (the ITSC committee and the CIO role) but lacks quantifiable data or third-party names required for Quantified-Verifiable.


reasoning: The paragraph describes the governance chain and oversight structure (board → committees → officers), including how cybersecurity risk is overseen by the Board and managed at the operational level by specific officers, with regular updates flowing upward. It identifies cybersecurity-specific roles (CTO, Information Security Manager) and named non-generic committees (Board Risk Committee, Management Risk Committee, Executive Committee) unique to this disclosure.


reasoning: The paragraph describes the company's internal processes for monitoring cybersecurity risks, including briefings with security personnel, threat intelligence gathering, and security tool alerts. While the CISO and Sr. Director of Information Security are mentioned as leading the management team, the focus is on the monitoring mechanisms rather than the individuals' qualifications or credentials, making this Risk Management Process rather than Management Role.


reasoning: The paragraph describes the governance structure and oversight chain for cybersecurity risk, detailing how the Operational Risk Management Committee and Enterprise Risk Management Committee escalate risks to the Board and Risk Committee. This fits the Board Governance definition of describing oversight structure and information flow. It contains firm-specific details including named non-generic committees (ORMC, ERMC, Risk Committee) and specific officer titles (Chief Operational Risk Officer, Chief Risk Officer) that identify American Express's unique governance framework.


specificity_confidence: medium

reasoning: The paragraph describes internal processes for evaluating cybersecurity program effectiveness and executive-level review of strategy, policy, and standards, which falls under risk management processes. The mention of a specific 'executive security council' as a non-standard oversight body provides a firm-specific detail, distinguishing it from generic boilerplate.


reasoning: The paragraph contains a materiality assessment stating the company is 'not aware of any risks from cybersecurity threats... which have materially affected or are reasonably likely to materially affect our Company,' which qualifies as Strategy Integration under the SEC's materiality assessment definition. The content lacks specific dates, named roles, frameworks, or quantifiable details, consisting entirely of generic language applicable to any registrant.


reasoning: The paragraph provides a backward-looking materiality assessment stating that cybersecurity threats have not materially affected the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration per the SEC disclosure guidelines. It contains no specific dates, named roles, frameworks, dollar amounts, or other verifiable facts unique to the company—only generic materiality language and a cross-reference to standard risk factors that could apply to any registrant.


reasoning: The paragraph describes the company's internal cybersecurity organizational structure and incident response planning. While the Chief Information Officer is mentioned as leading the Information Security Office, the disclosure focuses on the risk management framework and processes rather than the individual's qualifications, experience, or reporting lines, making it Risk Management Process rather than Management Role. The specific cybersecurity title (CIO) and department name (Information Security Office) provide firm-specific details.


reasoning: The paragraph describes the governance/oversight structure and information flow from management to the Information Technology Steering Committee (quarterly) and full Board (annually), which is the defining characteristic of Board Governance. The naming of the specific 'Information Technology Steering Committee' (rather than a generic 'Audit Committee') provides a firm-specific detail.


reasoning: The paragraph describes internal cybersecurity processes (hiring personnel, integrating risk considerations, preparing for incidents, approving budgets/processes, reviewing assessments) carried out by management. Under the person-removal test, the text remains a coherent description of program activities without reference to specific individuals. It does not identify specific cybersecurity officers (CISO/CTO) or their qualifications, nor does it contain specific dates, dollar amounts, named frameworks, or other verifiable facts.


reasoning: The paragraph contains generic statements about IT dependence and the importance of cybersecurity without describing specific governance structures, management roles, risk processes, or materiality assessments. It qualifies as generic IT-dependence language and forward-looking risk acknowledgment under None/Other.


reasoning: Paragraph describes internal processes for preventing, detecting, and mitigating cyber risks through various means including briefings from security personnel, threat intelligence, and security tool alerts. While 'management team' is the grammatical subject, removing the personnel references leaves a coherent description of the company's risk management process rather than focusing on the qualifications of specific individuals. No named frameworks, tools, dates, or quantifiable details are provided.


reasoning: The paragraph describes the company's internal risk management structure and processes, specifically the CSWAT team and its responsibilities for managing cybersecurity risks, business continuity, and operational controls. It includes firm-specific details such as the named internal program (CSWAT) and the specific cross-functional composition of the team (IT, operations, risk, legal and compliance leaders).


reasoning: The paragraph describes internal cybersecurity processes including program implementation, incident response plans, and risk management methodologies (mitigation, transference, acceptance). While it mentions the Director – Information Systems as the role responsible, the content focuses on the program and processes rather than the individual's qualifications or background, making it Risk Management Process rather than Management Role. The specificity is Firm-Specific due to the identification of the cybersecurity-specific leadership title.


reasoning: The paragraph's primary purpose is to provide a backward-looking materiality assessment stating that cybersecurity risks 'have not materially affected us, including our business strategy, results of operations or financial condition, to date.' While it briefly mentions experiencing threats and breaches, this serves only as context for the materiality conclusion rather than constituting a specific incident disclosure. The language contains no named entities, frameworks, dates, or specific details that would identify it as unique to this company.


reasoning: The paragraph describes the governance oversight structure, specifically which officers (CIO and General Counsel) brief the Board and its committees on cybersecurity matters, including the specific program areas reviewed, constituting a description of briefing cadence and information flow to the board rather than management qualifications or internal process details.


reasoning: Paragraph describes the governance chain (Board → CTO → VP/Director → team) and oversight structure, including quarterly/annual board briefings and the Board's role in enterprise risk assessment. Specific cybersecurity leadership titles (CTO, VP of IT, Senior Director of IT Security) provide firm-specific detail, though no quantifiable metrics or dates are present.


reasoning: The paragraph describes internal processes for monitoring cybersecurity incidents, managing risk processes, and operating the incident response plan and disclosure controls, which falls under Risk Management Process. While it mentions the 'InfoSec Leadership Team,' the focus is on their functional activities in the process rather than their qualifications or identity. The specific cybersecurity title elevates the paragraph above generic boilerplate to Firm-Specific.


reasoning: The paragraph contains a backward-looking materiality assessment stating the company is not aware of cybersecurity threats that have materially affected its business, which qualifies as Strategy Integration per the guidance on materiality assessments. The language is standard SEC boilerplate ('materially affected... business strategy, results of operations, or financial condition') with no specific dates, dollar amounts, named roles, or other verifiable facts unique to the firm.


reasoning: The paragraph contains a backward-looking materiality assessment stating that 'cybersecurity incidents have not materially affected our business to date,' which qualifies as a Strategy Integration disclosure per the guidance. The remaining content consists of forward-looking disclaimers, cross-references to Risk Factors, and generic resource allocation statements without specific details.


reasoning: Paragraph describes the governance structure and oversight chain (Board → Audit Committee → SVP), focusing on reporting lines, briefing cadences, and oversight responsibilities rather than individual qualifications or internal security processes. Contains only standard governance entities (Board of Directors, Audit Committee) and generic reporting cadences ('quarterly') without firm-specific details.


reasoning: The paragraph describes the internal working group structure, program implementation, and real-time monitoring processes for cybersecurity threats. While it names specific roles (CISO, CCO, COO), the content focuses on the collaborative process and program operations rather than individual qualifications or board oversight structure. The inclusion of the CISO title and the specific composition of the working group (CCO, COO, CISO) provides firm-specific details.


reasoning: Paragraph describes the governance structure and reporting cadence from cybersecurity officers (CIO, CISO, VP of Product Security) to board committees (Audit Committee, QRC), including escalation processes to the Board, which constitutes board oversight of cyber risk.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically the Enterprise Risk Committee (ERC), its delegated authority from the BRC (Board Risk Committee), and the interim CISO's briefing cadence to the committee. This constitutes a governance-chain description (board/committee → officer) rather than a focus on management qualifications or internal risk processes.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risk, including the Board's enterprise-wide oversight, specific committee responsibilities (Governance and Compliance Committee and Technology Committee), and reporting lines from the CISO to these committees. It focuses on how oversight is exercised and how information flows upward rather than describing the CISO's qualifications or the technical details of risk management processes.


reasoning: The paragraph contains a backward-looking materiality assessment ('to date the Company... has not been materially affected by a cybersecurity breach'), which qualifies as Strategy Integration under the definition for backward assessments. The remainder consists of generic forward-looking risk warnings and cross-references to Item 1A. It contains no specific dates, dollar amounts, named roles, frameworks, or other verifiable facts that would identify it as unique to this company.


reasoning: The paragraph presents a generic forward-looking risk warning about potential operational disruptions from cyber incidents. It does not describe the company's governance structure, management roles, risk management processes, third-party oversight, or an actual incident. It also lacks the specific SEC-qualified materiality assessment language ('reasonably likely to materially affect') required for Strategy Integration, instead using speculative boilerplate ('could disrupt').


reasoning: The paragraph contains a negative materiality assessment ('we have not experienced any recent material cybersecurity incidents'), which qualifies as a Strategy Integration disclosure under SEC guidelines. However, the text consists entirely of generic risk disclaimers and forward-looking cautionary language that could appear in any company's filing without modification.


reasoning: The paragraph's grammatical subject is 'leaders' and 'individuals' from specific internal teams, and it focuses on their quantified experience (20 years) and specific functional backgrounds. While it mentions processes, the content is primarily about WHO these people are and their credentials, not the process mechanics themselves. The specific department names and experience duration make this Firm-Specific rather than generic.


reasoning: The paragraph describes the company's operational process for identifying and assessing cybersecurity threats through a retained third-party firm and internal coordination, not the qualifications of specific personnel (Management Role) or vendor security oversight (Third-Party Risk). It contains firm-specific organizational details regarding the departmental composition ('finance and operations') and the specific role title ('IT Lead') responsible for cybersecurity, distinguishing it from generic boilerplate.


reasoning: The paragraph describes internal cybersecurity processes—directing, coordinating, planning, and organizing security activities and leading strategy development—with the CDO as the grammatical subject performing these actions. Per the person-removal test, the remaining text coherently describes the company's risk management activities without requiring personal qualifications, making this Risk Management Process rather than Management Role. The specific title 'CDO' (distinct from generic C-suite roles like CEO/CFO) constitutes a firm-specific fact.


reasoning: The paragraph identifies the Senior Director of Cybersecurity and specifies their 15 years of experience, triggering the qualifications tiebreaker for Management Role. It also details the security steering committee's specific cross-functional composition (finance, internal audit, compliance, legal), which constitutes firm-specific organizational structure.


reasoning: The paragraph identifies a specific cybersecurity leadership role (Director of Information Technology and Security) and provides detailed qualifications (over 40 years of experience), triggering the Management Role category under the Step 3 qualifications tiebreaker. While it describes processes executed by the CSIRT, the presence of specific experience years and the cybersecurity-specific title makes this Firm-Specific.


reasoning: The paragraph presents a generic, forward-looking risk warning about potential data breaches and their consequences without describing the company's specific governance structure, management roles, internal risk processes, or any actual incidents. It contains no substantive disclosure specific to OSS's cybersecurity program and could appear in any company's filing unchanged.


reasoning: The paragraph describes the company's internal governance processes for cybersecurity oversight, including the establishment of a management committee (Executive Cybersecurity Steering Committee) and the designation of Information Security Officers in business units with specific responsibilities and certification requirements. It focuses on the organizational structure and operational processes rather than Board oversight or individual qualifications.


reasoning: The paragraph contains a forward-looking materiality assessment using the SEC-qualified language 'reasonably likely to materially affect our business strategy, results of operations, or financial condition,' which defines Strategy Integration. It lacks specific governance structures, management details, process descriptions, or incident narratives, and functions primarily as a risk disclosure with a cross-reference to Item 1A.


reasoning: Paragraph primarily describes internal incident response procedures, policy structure, monitoring mechanisms, and training programs. While it names the VP Infrastructure and Security and departmental composition, these serve to illustrate the process governance chain rather than constituting a profile of the individual (no qualifications, experience, or career history provided). Step 2 Person-Removal Test confirms the process description remains coherent without the named role. Contains firm-specific organizational facts: specific cybersecurity title (VP Infrastructure and Security) and explicit departmental composition (Legal, HR, Finance) of the incident response team.


reasoning: The paragraph describes the governance chain (Board oversight → CFO direction → security governance structure) for cyber risk oversight, which is the defining characteristic of Board Governance. It mentions the CFO only as part of this oversight structure rather than describing their qualifications or role-specific expertise.


reasoning: The paragraph contains a backward-looking materiality assessment stating the company has not experienced cybersecurity incidents that materially affected its business strategy, results of operations, or financial condition, which falls under Strategy Integration. It lacks specific dates, dollar amounts, named entities, or other verifiable facts, consisting instead of boilerplate language and cross-references to generic risk factors.


reasoning: The paragraph contains a backward-looking materiality assessment ('we have not experienced material adverse effects from cybersecurity threats to date'), which qualifies as Strategy Integration under the taxonomy. It contains no specific facts, dates, named roles, or frameworks—only generic risk warnings and cross-references that could appear in any company's filing.


reasoning: Paragraph describes the governance chain and oversight structure (board → committee → officers), including the specific Information Technology Steering Committee and its composition. While officers are mentioned, the purpose is to explain oversight flow rather than individual qualifications.


reasoning: The paragraph describes the governance chain and oversight structure, specifically how the CTO reports to the Audit and Finance Committee and executive leadership on a quarterly basis regarding cybersecurity matters. While officers are mentioned, the purpose is to explain upward information flow and board oversight mechanisms, not to detail management qualifications or internal operational processes.


reasoning: The paragraph describes an internal process for briefing senior management on cybersecurity matters (prevention, detection, mitigation, remediation). While it mentions the SVP of IT, the focus is on the briefing activity and information flow rather than the individual's qualifications or Board-level governance. The specific title 'SVP of IT' qualifies as a cybersecurity-specific role under the Firm-Specific criteria, but no quantifiable details (dates, dollars, headcounts, named firms) are present to reach Quantified-Verifiable.


reasoning: The paragraph describes internal processes for monitoring information systems and following a written incident response runbook. While the CISO and cybersecurity team are mentioned as actors, the content focuses on the processes themselves rather than personnel qualifications, making this Risk Management Process under the three-step test. The mention of the CISO (CICSO) role provides one firm-specific fact, but there are no dates, dollar amounts, headcounts, or named third-party firms/tools to reach Quantified-Verifiable.


reasoning: The paragraph contains forward-looking disclaimers and generic risk warnings regarding the company's lack of cybersecurity resources and potential vulnerability to damage, but does not describe actual governance structures, management roles, risk management processes, or materiality assessments. It functions as a generic risk disclosure rather than substantive cybersecurity program description.


reasoning: The paragraph provides generic descriptions of cybersecurity threats (hackers, nation-state actors, social engineering) without describing the company's specific governance structures, risk management processes, or materiality assessments. It contains no named entities, frameworks, dates, or firm-specific details that would constitute substantive disclosure.


reasoning: The paragraph contains a backward-looking materiality assessment stating the company has 'not experienced any material cybersecurity threats or incidents in recent years,' which qualifies as Strategy Integration under the negative assertion rule. However, the disclosure lacks specific dates, dollar amounts, named entities, or frameworks, consisting entirely of generic language that could apply to any company.


reasoning: The paragraph contains a backward-looking materiality assessment stating that cybersecurity risks 'have not materially affected us, including our business strategy, results of operations or financial condition.' While it briefly mentions past breaches and threats, it provides no specific details (dates, scope, systems affected, or response actions) and serves primarily to convey the materiality conclusion rather than describe an incident. The content is generic boilerplate containing no named frameworks, roles, dates, or quantifiable facts.


reasoning: The paragraph describes the company's internal risk management structure and processes—assigning responsibility for identifying, assessing, and mitigating cybersecurity risks to the General Counsel, executive leadership, and IT teams. While it mentions specific roles, it lacks credentials, certifications, or career history that would qualify as Management Role content, and does not reference the board (Board Governance) or any specific incident (Incident Disclosure). All mentioned roles (General Counsel, CEO, IT leaders) are generic titles found at any company with no qualifying details, making the disclosure generic boilerplate.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, including specific committees (Information Security Council, Executive Information Security Committee) and reporting relationships between the CISO, CEO, and board. This focuses on oversight mechanisms and information flow rather than individual management qualifications or internal risk management processes.


reasoning: The paragraph describes the governance chain and oversight structure: board-level and management-level IT/Cybersecurity Committees, reporting lines (CISO to board committee, management committee to Enterprise Risk Committee), and meeting cadences. This is classic governance structure disclosure. Specificity is Firm-Specific due to named committees (IT/Cybersecurity Committee, Enterprise Risk Committee), cybersecurity-specific titles (CISO, CIO), and specific departmental compositions, but lacks quantified data (dates, dollar amounts, headcounts) required for Quantified-Verifiable.


reasoning: The paragraph describes the governance chain and oversight structure for cybersecurity risk management (Board → Committee → management team), which is the defining characteristic of Board Governance. It names standard governance entities (Board of Directors, Nominating and Corporate Governance Committee) and generic C-suite roles (COO, CFO, General Counsel) without providing specific qualifications, dates, frameworks, or verifiable metrics, making it generic boilerplate.


reasoning: The paragraph describes the company's cyber risk management process for preventing, detecting, and remediating security threats, as well as resource investments for IT protection. While generic management titles (SVP, Operations; VP, Deputy General Counsel) are mentioned, they lack cybersecurity-specific credentials or qualifications, and the focus remains on the process activities rather than individual career details or board governance.


reasoning: The paragraph describes the company's internal risk management program operations, including risk assessment, vulnerability management, and remediation workflows. While it names specific officers (VP, CISO and EVP) and mentions reporting to the Board, the content focuses on process mechanics rather than individual qualifications (not MR) or board oversight structure (not BG). Specificity is Firm-Specific due to the cybersecurity-specific title (CISO), named committee (Risk Subcommittee), and unique EVP title, but lacks quantifiable data (dates, numbers, vendors) needed for Quantified-Verifiable.


reasoning: Paragraph describes governance structure and oversight chain: cybersecurity team reports to the Audit Committee with quarterly briefings covering risks, mitigation strategies, and third-party assessments. This is a classic governance-flow description (team → committee). While 'quarterly' specifies cadence, it falls under generic periodicity without specific dates; 'Audit Committee' is standard governance architecture; and 'cybersecurity team' is a generic functional reference without named roles, credentials, or headcounts. No specific dates, dollar amounts, named third-party firms, or unique organizational facts are present.


reasoning: The paragraph describes the governance structure for cybersecurity risk oversight, detailing the TRCC committee (a sub-committee of the ERC), its composition including the CISO, appointment of its chair, and its responsibilities for oversight, escalation, and ensuring risks remain within tolerances. This focuses on the oversight structure and information flow rather than specific risk management activities or individual qualifications.


reasoning: The paragraph focuses primarily on the CISO's qualifications, prior career history (previous CTO role, senior leadership positions), and the composition of the Cybersecurity Governance Council (Deputy CISOs with specific expertise). Under the Step 3 qualifications tiebreaker, extensive experience details and career history trigger Management Role over Risk Management Process despite mentions of CGC responsibilities.


reasoning: The paragraph consists entirely of generic forward-looking risk disclaimer language ('could adversely affect our business, financial condition, and results of operations') and vague assurances ('implemented measures') without describing any specific cybersecurity processes, governance structures, incidents, or materiality assessments. Per the guidelines, generic risk warnings using 'could adversely affect' are boilerplate speculation, not Strategy Integration materiality assessments. No named entities, frameworks, dates, or specific details appear.


reasoning: The paragraph describes the governance chain from the board to the Information Technology Steering Committee and back, including reporting cadences and oversight structure. While it mentions specific officers (CIO, CTO, ISO), the purpose is to explain oversight flow rather than individual qualifications. Specificity is Firm-Specific due to the named committee, cybersecurity-specific titles, and specific department reference, but lacks hard verifiable facts (dates, dollars, headcounts, external firms) required for Quantified-Verifiable.


reasoning: The paragraph describes the governance chain for cybersecurity oversight (Board → audit committee → Management → Principal Accounting Officer → consultants), which is the defining characteristic of Board Governance. It includes quantifiable hard facts: specific fiscal years (2023, 2022, 2021) and the percentage independence of the audit committee (100%), meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph's primary substantive content is a materiality assessment regarding previous cybersecurity threats, containing the backward-looking negative assertion 'not aware of any previous cybersecurity threats that have materially affected' combined with the forward-looking SEC-qualified language 'reasonably likely to materially affect the Company.' This constitutes a firm-specific conclusion about business impact, which is the defining characteristic of Strategy Integration. However, the paragraph contains no quantified or verifiable specific facts (no dates, dollar amounts, headcounts, named third-party firms, products, certifications, or named officers) and relies entirely on generic vulnerability descriptions ('security breaches, computer viruses...') and cross-references to Item 1A, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the company's internal cyber risk management processes, including program oversight, use of threat intelligence, and engagement of external consultants. While management is mentioned as the responsible party, the content focuses on what the program does (administration, informing stakeholders) rather than who the specific personnel are (no CISO/CTO/CIO identified, no detailed qualifications). The Audit Committee mention is brief and secondary to the process description.


reasoning: The paragraph describes the governance structure and upward information flow regarding cybersecurity oversight, specifically detailing the Compliance Committee's role in escalating issues to senior management and the Board. While it mentions the CIO as a committee member, the primary purpose is explaining the oversight chain and escalation processes (Committee → management → Board), not the individual's qualifications or internal operational processes alone. The presence of the specific title 'Chief Information Officer' and the defined 'Compliance Committee' composition make this firm-specific rather than generic.


reasoning: This paragraph is a cross-reference pointing to Item 1A (Risk Factors) for materiality assessments regarding cybersecurity threats, rather than providing substantive disclosure about the company's cybersecurity governance, processes, or incidents. It contains no specific facts about the company's program and functions as a navigational pointer.


reasoning: Paragraph centers on Mr. Daly's oversight and explicitly details the cybersecurity team's professional certifications (CISSP, SANS Institute), triggering the qualifications tiebreaker for Management Role under the MR vs RMP decision chain. Specific certifications and named individual make the disclosure Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity risk management program and the responsibilities for assessing and managing risks, which falls under Risk Management Process. While it mentions the COO and management team, it does not provide qualifications, credentials, or career history (which would make it Management Role), nor does it describe board oversight structures (which would make it Board Governance). The paragraph contains no specific dates, dollar amounts, named third-party firms, or other verifiable facts; terms like 'COO,' 'management team,' and 'external cybersecurity consultants' are generic and appear at any company, making this Generic Boilerplate.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, technical controls, and program components, with the CTO and CISO mentioned as part of the governance structure overseeing these processes rather than as the main focus. The disclosure includes cybersecurity-specific titles (CTO, CISO) and a specific qualification detail (twenty years of experience), making it firm-specific rather than generic boilerplate.


reasoning: The paragraph contains a backward-looking materiality assessment ('have not materially affected') and a forward-looking SEC-qualified assessment ('reasonably likely to materially affect'), which are definitive characteristics of Strategy Integration. The paragraph lacks any specific facts, dates, named roles, frameworks, or company-specific details, making it generic boilerplate that could apply to any company.


reasoning: The paragraph describes the company's internal incident response structure and processes, including the Rapid Response Team's composition, its function under the Incident Response Policy, and procedures for investigating threats and assessing materiality. While it mentions reporting lines to the audit committee and board, the primary focus is on operational risk management activities rather than board oversight governance or individual management qualifications.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, including coordination between the CISO and internal teams (Technology and ERM), implementation of protection measures, incident response protocols, and real-time monitoring processes. While it mentions reporting to the Board at the end, the primary purpose is to explain the operational risk management process rather than board oversight structure or individual management qualifications. It qualifies as Firm-Specific due to the cybersecurity-specific title (CISO) and specific internal team composition (Technology and ERM teams), but lacks the two hard verifiable facts (dates, numbers, named vendors) required for Quantified-Verifiable.


reasoning: The paragraph provides a backward-looking materiality assessment ('have not been materially impacted') regarding cybersecurity threats and prior incidents, which qualifies as Strategy Integration under the materiality assessment rules. It contains no specific facts, dates, named roles, frameworks, or quantifiable details—only generic references to filing sections and standard materiality language—rendering it Generic Boilerplate.


reasoning: The paragraph primarily describes the governance structure for Board oversight of cybersecurity risk, including the quarterly reporting cadence from the CIO to the Board and the specific content of those reports (scorecards, threat updates). While it includes details about the CIO's experience and support team, these elements serve to describe the oversight chain and information flow upward to the Board rather than focusing solely on the individual's credentials.


reasoning: The paragraph describes governance structures and reporting chains (incident response team reporting to executives and Board, and the composition/responsibilities of an information security advisory board), which fits Board Governance. It includes firm-specific details such as the specific functional representation on the advisory board and the 'Director and VP of IT' title, but lacks quantifiable data like dates, dollar amounts, or headcounts needed for Quantified-Verifiable.


reasoning: The paragraph describes oversight responsibilities—specifically reviewing personnel capabilities and cybersecurity strategy/resource allocation—which falls under board governance structure. However, it contains only generic descriptors without naming specific roles, qualifications, dollar amounts, or frameworks.


reasoning: The paragraph's primary purpose is to provide a backward-looking materiality assessment ('have not materially affected us... to date'), which is the defining characteristic of Strategy Integration. While it mentions experiencing threats and breaches, it provides no specific incident narrative (dates, scope, or response actions), so it does not qualify as Incident Disclosure. The text contains no named frameworks, roles, dates, or verifiable specifics, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the management chain and qualifications of personnel responsible for cybersecurity (executive officers led by a third-party consultant who is advised by a Security Operations Center Manager with technical certifications), focusing on who holds these roles rather than describing internal processes or board governance. It contains one firm-specific fact: the cybersecurity-specific title 'Security Operations Center Manager'.


reasoning: The paragraph contains generic, forward-looking risk warnings about potential cyber threats and their hypothetical consequences (disruptions, theft, expenses) without describing specific governance structures, management roles, internal processes, or materiality assessments. It uses boilerplate language applicable to any company and lacks substantive disclosure about AFG's specific cybersecurity program.


reasoning: The paragraph describes the governance chain and oversight structure, detailing how the Board and Audit Committee exercise oversight through the CFO, who receives reports from the IT Director. While it mentions the IT Director's role, the focus is on the upward reporting structure (IT Director → CFO → Board/Audit Committee) rather than the individual's qualifications.


reasoning: The paragraph primarily contains backward-looking materiality assessments ('have not been materially impacted,' 'have not identified any risks... that have materially affected') and references forward-looking materiality assessments ('reasonably likely to materially affect'), which are definitive Strategy Integration content per the guidelines. It contains no specific dates, named roles, frameworks, dollar amounts, or other firm-specific details that would elevate it beyond generic boilerplate language applicable to any company.


reasoning: The paragraph describes internal risk management processes (monitoring threat environments, analyzing intelligence, conducting scans) where the Director of Information Technology is mentioned only as the process leader rather than the primary subject. Removing the named role leaves a coherent description of risk assessment activities. No specific frameworks, dates, named vendors, or quantifiable details are provided—only generic descriptions of security activities and unnamed third-party assistance.


reasoning: The paragraph describes the company's cybersecurity risk management structure, specifically that the Information Security Team is outsourced to service providers who assess risk and report to the Principal Financial Officer regarding prevention and remediation efforts. It does not name specific individuals (PFO is generic C-suite), vendors, tools, dates, or quantities—only unnamed 'service providers' and generic reporting cadences.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity, including the CIO's reporting cadence to the Audit Committee, Board members' authority to raise concerns, and the CSIRP's escalation protocol requiring reporting to the Board of Directors. It contains firm-specific details through the cybersecurity-specific title (CIO) and a uniquely identified internal program (CSIRP), but lacks quantifiable data points like specific dates, dollar amounts, or named third-party firms needed for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity program, risk assessment processes, and controls. While it names the CISO, CTO, and CIO, applying the person-removal test reveals the text remains a coherent process description (focused on program implementation, controls, and assessments), making it Risk Management Process rather than Management Role. It identifies specific cybersecurity titles (CISO, CTO, CIO), which qualifies as Firm-Specific.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes (systems for securing data, third-party risk management, training programs, and incident response plans). While it includes detailed qualifications of the CISO and COO, these are supporting details within a broader program description rather than the primary focus. Specificity is Firm-Specific due to the identification of the CISO role, specific team compositions, and exact years of experience cited for leadership, but it lacks the two hard verifiable facts (dates, dollar amounts, named firms/tools) required for Quantified-Verifiable.


reasoning: The paragraph describes internal processes for supervising cybersecurity efforts and the information sources used (internal personnel, threat intelligence, external consultants, security tools), which constitutes a Risk Management Process disclosure. It contains no specific details, named roles (e.g., CISO), dates, frameworks, or quantified data that would identify it as unique to this company.


reasoning: While the paragraph mentions the SVP IT's experience, the content primarily describes the operational cybersecurity program—team responsibilities, supervision of internal/external personnel, threat monitoring processes, and reporting mechanisms—passing the person-removal test for Risk Management Process. It contains firm-specific details including a specific leadership title, a precise experience duration, and the company-named security program.


reasoning: Paragraph describes the governance chain and oversight structure, specifically how the CISO reports cybersecurity risk information to the Technology Risk Management Committee, Audit Committee, and Board, including the topics covered in these periodic updates. It identifies the cybersecurity-specific CISO role and a non-generic Technology Risk Management Committee.


reasoning: The paragraph describes internal cybersecurity risk assessment and management processes, including integration into enterprise risk management and incident preparation. While generic C-suite roles (CEO, CFO) and the Board are mentioned, they appear as actors within process descriptions rather than as subjects of credential or qualification disclosure. Upon removal of named roles, the text remains a coherent description of cybersecurity processes. No specific dates, dollar amounts, headcounts, percentages, named third parties, products, certifications, or frameworks are present to elevate the content beyond generic boilerplate.


reasoning: The paragraph describes the governance chain and oversight structure for cybersecurity, detailing how information flows from internal teams to management and ultimately to the Board/Audit Committee. It identifies specific organizational entities (Information Security team, Disclosure Committee) and a specific reporting pattern (alternating quarters), which distinguishes it from generic boilerplate.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, including the composition and reporting cadence of the Information Security Governance Committee to the Board, and board educational sessions. It focuses on oversight mechanisms rather than technical processes or individual management qualifications.


reasoning: The paragraph identifies the CISO, describes reporting lines for information security directors, and details specific industry certifications held by the team (CISSP, CISM, CRISC, CEH), which are qualifications-focused content characteristic of Management Role disclosures.


reasoning: The paragraph primarily describes the governance oversight structure, including Board and Audit Committee briefing cadence (at least annually), the information flow from the CIO to the committee, and the scope of those reports. While the CIO's experience is mentioned, this is incidental to describing the governance chain. The disclosure includes the cybersecurity-specific title 'Chief Information Officer' and a specific duration of experience (20 years), making it firm-specific.


reasoning: The paragraph describes the governance chain and oversight structure, detailing how the Chief Technology Officer reports cybersecurity risks and incidents to the Committee, which in turn reports to the full Board, including continuing education activities. While it identifies the specific cybersecurity role of Chief Technology Officer, it lacks hard verifiable facts such as dates, dollar amounts, or named third-party firms, making it Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, framework adoption (NIST, ISO), and ERM integration rather than focusing on board governance structure or management roles. While the Board is mentioned as overseeing the program, the substantive content addresses the company's policies, standards, and cross-functional approach to managing cyber risks.


reasoning: The paragraph contains a backward-looking materiality assessment stating that the company has not experienced 'any material financial losses related to cybersecurity attacks,' which qualifies as Strategy Integration. The remainder consists of generic risk warnings and forward-looking disclaimers without specific frameworks, dates, dollar amounts, or named entities, making it Generic Boilerplate.


reasoning: The paragraph describes the governance chain from the Audit and Risk Committee through the Cybersecurity Infrastructure Committee to specific management roles (CIO, Senior Director of Information Security) and back to the committee via reporting lines, fitting the definition of Board Governance. It includes specific role titles, qualifications (15 years experience, degree), and a named internal committee with meeting cadence, making it Firm-Specific.


reasoning: The paragraph describes the governance and oversight structure for cybersecurity risk management, including the Board of Directors' oversight rights, the delegation of portfolio management from the General Partner to the Investment Manager, and reliance on the parent company Blackstone for risk assessment and management. It establishes the organizational chain of command and oversight relationships rather than describing specific processes, individual officer qualifications, or incidents.


reasoning: The paragraph describes the company's internal cybersecurity risk management structure and processes, including designated supervisory divisions conducting assessments and reporting to the Risk Management Officer through the Risk Management Committee. It provides firm-specific organizational details including the 64-member team size and specific division names (Quality Innovation Operations and Corporate Administration Operations), but lacks a second hard verifiable fact (such as a specific date or dollar amount) needed for Quantified-Verifiable classification.


reasoning: The paragraph describes the information flow and reporting structure to the Board (CFO provides updates to the full Board based on input from DIT and DIS), which is a governance/oversight structure. While 'CFO' and 'Board' are generic, 'DIT' and 'DIS' are specific internal role abbreviations (likely Director of Information Technology and Director of Information Security) that identify this company's particular organizational structure, making it Firm-Specific rather than generic boilerplate.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically how the COO reports to the full board and Audit Committee on cyber programs, risks, and incidents. This is a governance-chain description (board/committee ← officer) focused on oversight structure rather than the COO's qualifications or internal risk processes. The specific timing 'beginning in 2024' provides one firm-specific detail, while roles like COO and Audit Committee are generic per exclusion rules.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically the Audit and Examination Committee's responsibility for overseeing the risk management program and the Information Security Officer's quarterly reporting cadence to the board. The inclusion of the specific cybersecurity role title 'Information Security Officer' elevates this beyond generic boilerplate.


reasoning: The company explicitly states it is a SPAC with no business operations and has not adopted any cybersecurity risk management program or formal processes. Per the classification guidelines, SPACs explicitly stating the absence of operations or programs are classified as None/Other, and such paragraphs automatically receive Generic Boilerplate specificity.


reasoning: The paragraph identifies specific cybersecurity leadership roles (Director of Enterprise Information Security and Information Security Officer), details their reporting lines and responsibilities, and provides specific qualifications including years of experience (30 and 22 years respectively). Per the qualifications tiebreaker, specific years of experience trigger Management Role classification. The specificity is Quantified-Verifiable due to two hard numerical facts (30 and 22 years) combined with named cybersecurity-specific titles.


reasoning: The paragraph primarily describes the governance oversight structure, detailing how the Board's Technology Committee and ERM Committee oversee the information security team and receive regular updates on the program, successes/failures, and emerging threats. While it mentions the CISO's qualifications (CISSP certification) and the team's combined experience (50 years), these details support the governance chain description rather than making the paragraph primarily about management identity.


reasoning: The paragraph describes the Audit Committee's oversight responsibility and the upward information flow from the CIO/CISO to the committee, constituting governance structure. The inclusion of the cybersecurity-specific titles CISO and CIO provides firm-specific detail beyond generic board oversight language.


reasoning: The paragraph describes the governance chain and oversight structure from the Board to the Audit Committee through to the CTO and VPCS, fitting the Board Governance definition of explaining how oversight is exercised and information flows upward. It is Firm-Specific because it names cybersecurity-specific roles (CTO and VPCS) rather than using generic management references.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk disclosures. It contains no substantive disclosure about the company's cybersecurity governance, management, processes, or incidents, and per the guidelines, cross-references with materiality language pointing elsewhere are classified as None/Other.


reasoning: Paragraph primarily describes internal processes—incident response procedures and how cybersecurity initiatives are coordinated through IT and security personnel. While the Audit Committee is mentioned, the reference to the 'Senior Director - Information Security' describes their functional role in directing initiatives rather than their personal qualifications or reporting lines, and no explicit governance chain is described, making Risk Management Process the appropriate category.


reasoning: Paragraph describes the internal process for identifying and overseeing third-party cyber risks by relying on specific personnel (CCO and Investment Adviser staff), which falls under Risk Management Process rather than Third-Party Risk because it focuses on internal reliance mechanisms rather than vendor requirements or contractual oversight. Contains firm-specific structural details including the CCO role, the Investment Adviser relationship, and the specific cross-functional team composition (risk management, legal, IT, compliance) involved in the process.


reasoning: The paragraph describes the governance oversight structure, specifically how the Cybersecurity Committee and Chief Information Security Officer oversee and monitor cybersecurity policies and processes. This constitutes a governance-chain description (board committee → officer → program) focused on oversight mechanisms rather than the CISO's personal qualifications or the technical details of risk management processes.


reasoning: The paragraph describes the governance chain and information flow for cybersecurity oversight, detailing how the CISO reports to executive management and escalates significant matters to the Compliance Committee and full Board of Directors. While the CISO is mentioned, the focus is on the oversight structure rather than individual qualifications.


reasoning: The paragraph describes the governance and oversight structure, including reporting lines from the CISO and CTO to the Board and Audit Committee, and the role of the Enterprise Risk Management Committee. It focuses on how the board exercises oversight and information flows upward, which is characteristic of Board Governance.


reasoning: The paragraph describes the governance chain and escalation protocol for reporting cybersecurity incidents upward from management to the Audit Committee and Board, focusing on oversight structure and information flow. It contains only generic elements (Audit Committee, management, Board, incident response plan) with no specific dates, named individuals, departmental compositions, or quantifiable details.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically how the BDT & MSD CTO reports to the board of directors on risk developments, controls, and third-party oversight. While it mentions risk evaluation processes, the primary purpose is to explain the oversight chain and briefing cadence to the board.


reasoning: The paragraph describes the Company's cybersecurity policies, standards, and processes, including integration of recognized frameworks (ISO, NIST) and a cross-functional approach to identifying and mitigating threats, which aligns with Risk Management Process. It names specific recognized standards but contains no unique implementation details, dates, or quantified metrics, making it Sector-Adapted.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically how the CISO and CIO inform the Board of Directors and Audit Committee about risks and initiatives. While it names specific cybersecurity leadership roles (CISO and CIO), the primary purpose is to explain the oversight and information flow structure rather than the individuals' qualifications or internal risk management processes.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically management's responsibility to report to the Board and the cadence of Board updates (at least annually). This fits Board Governance as it explains how information flows upward to the Board. However, it contains only generic terms ('Management', 'Board', 'annually') without naming specific officers, committees, dates, or frameworks, making it Generic Boilerplate.


reasoning: This paragraph is a cross-reference to Item 1A Risk Factors containing generic forward-looking risk warnings ('could have a material adverse effect'), which constitutes boilerplate speculation rather than a substantive cybersecurity disclosure or materiality assessment.


reasoning: Paragraph describes an internal process of briefing management to prepare them for risk assessment and management. While the CFO is mentioned, the focus is on the training/briefing process rather than the CFO's qualifications or identity. No specific facts survive filtering: 'CFO' is a generic C-suite role, 'cybersecurity advisory firm' and 'third-party service providers' are unnamed entities, and no certifications are named.


reasoning: Paragraph primarily describes the governance chain: Board of Directors and Audit Committee receive briefings at least annually, and the CIO reports regularly to the Audit Committee on cybersecurity matters. While the paragraph includes one sentence about the CIO's qualifications (20 years experience), the main purpose is describing oversight structure and reporting lines, making Board Governance the appropriate category. The paragraph contains specific facts including the cybersecurity-specific title 'Chief Information Officer' and the specific duration 'over 20 years', making it Firm-Specific.


reasoning: The company is a SPAC explicitly stating it has not adopted any cybersecurity risk management program or formal processes. Per the annotation guidelines, SPACs and shell companies explicitly stating the absence of a program are classified as None/Other regardless of incidental mentions of board oversight or materiality assessments.


reasoning: The paragraph contains a negative materiality assessment ('have not experienced a cybersecurity incident that we deemed to be material'), which qualifies as a Strategy Integration disclosure per the negative assertion rule. It lacks specific dates, dollar amounts, named roles, frameworks, or other verifiable facts, consisting only of generic IT-dependence language and a cross-reference to Item 1A.


reasoning: The paragraph describes the governance chain and oversight structure (Board → Audit Committee → Management → Principal Accounting Officer → consultants), including reporting cadences and responsibility assignments. While it mentions management processes, the primary purpose is to explain how the Board exercises oversight and how information flows upward. It is Firm-Specific because it identifies the Principal Accounting Officer (rather than a generic CISO or CIO) as directing cybersecurity programs and specifies the Audit Committee's 100% independent composition.


reasoning: The paragraph describes the governance structure and oversight chain, specifically how the CISO and CRO support the Board and risk committee through periodic reporting and escalation processes, rather than detailing the individuals' qualifications or internal risk management operations.


reasoning: The paragraph describes the company's internal processes for maintaining cybersecurity governance documents and a strategic plan, including annual reviews, updates, and approval workflows. While the CISO and Audit & Risk Committee appear in the governance chain, the primary focus is on the operational Risk Management Process rather than board oversight structure or management qualifications.


reasoning: The paragraph contains generic forward-looking risk warnings ('could have a material adverse effect') about potential cyber threats and third-party risks, which constitutes boilerplate speculation rather than a substantive disclosure of governance, processes, or materiality assessments. It lacks specific details regarding the company's actual cybersecurity program, governance structure, or management roles.


reasoning: The paragraph describes the company's internal cybersecurity processes and program oversight, including risk measurement, incident prevention/detection, and policy implementation. While it mentions the VP of IT services and reporting lines, the content focuses on the security team's functional responsibilities rather than individual qualifications or board governance structure.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, identifying the Board's oversight role and the CFO's directional role in maintaining a security governance framework. It contains no specific details, dates, named frameworks, or unique identifiers—only generic references to standard C-suite and Board roles that could apply to any company.


reasoning: The paragraph contains a negative materiality assessment ('have not experienced any material cybersecurity threats or incidents'), which classifies as Strategy Integration per the guidance that negative assertions about material incidents are materiality assessments. The language is entirely generic with no specific dates, named roles, frameworks, or quantifiable details that would identify this as unique to Amesite.


reasoning: The paragraph describes the governance chain for cybersecurity oversight, detailing how the Board delegates oversight to the Audit and Compliance Committee, which receives reports from the CIO and management periodically. This is a classic governance-structure paragraph mapping the flow of oversight (Board → Committee → Officers), rather than describing management qualifications or operational security processes.


reasoning: The paragraph contains a backward-looking materiality assessment stating that no material cybersecurity threats or incidents have been incurred to date, which qualifies as Strategy Integration under the negative assertion rule. However, it lacks specific dates, quantified metrics, named entities, or other verifiable facts that would elevate it beyond generic boilerplate; 'to-date' is vague and 'the Company' is a generic self-reference per the exclusion list.


reasoning: The paragraph describes the composition and structure of the Technology and Operations Committee, a named non-generic governance body, identifying specific cybersecurity leadership roles (CIO, CISO) and departmental representatives that comprise it. This describes governance structure rather than individual qualifications (Management Role) or operational processes (Risk Management Process).


reasoning: The paragraph identifies a specific cybersecurity leadership role (Director of Information Technology) and includes specific qualifications (over 20 years of experience), triggering the Step 3 tiebreaker for Management Role. While it describes team processes, the inclusion of experience duration makes it person-focused. The disclosure contains firm-specific facts including the specific title and a verifiable duration of experience, meeting the Firm-Specific threshold.


reasoning: The grammatical subject is 'Our cybersecurity risk assessment and management processes,' which triggers Step 1 of the MR vs. RMP decision chain for Risk Management Process. While the paragraph mentions the VP of Informatics and their experience, the primary purpose is describing how the company's internal processes are implemented and maintained. The specificity is Firm-Specific due to the named role, specific experience duration, and detailed departmental composition, but it contains only one hard verifiable fact (20 years experience) and lacks a second required for Quantified-Verifiable.


reasoning: The paragraph lists hypothetical cybersecurity risks (data breaches, service disruption, IP theft) and their potential business consequences using speculative language ('could lead to,' 'could disrupt,' 'could be significant'). This constitutes generic risk factor boilerplate without a materiality assessment, governance description, management roles, internal processes, or incident narrative.


reasoning: This paragraph is a cross-reference directing readers to Item 1A risk factors for materiality assessments regarding cybersecurity threats. It does not itself make a materiality assessment, describe governance structures, or disclose specific cybersecurity processes or incidents. Per the tiebreaker rules, cross-references with materiality language that point elsewhere (rather than concluding) are classified as None/Other.


reasoning: The paragraph describes a governance chain from the Board and Audit Committee through management to the standing Security Steering Group (SSG), whose membership includes specific cybersecurity and technology leadership roles. This describes the oversight structure and how it is organized, fitting the Board Governance definition. It contains firm-specific details including the cybersecurity-specific CISO title, the named internal Security Steering Group program, and the specific composition of that group (including the Vice President of Cloud Technology), but lacks quantifiable data like dates, dollar amounts, or named third-party firms needed for Quantified-Verifiable.


reasoning: Colombier Acquisition Corp. II is a SPAC that explicitly states it lacks significant investments in data security protection and sufficient resources to protect against cyber incidents. Per the annotation rules, SPACs explicitly stating they have no formal cybersecurity processes are classified as None/Other regardless of incidental mentions of board oversight or risk factors.


reasoning: Paragraph describes the governance structure and oversight chain of a management-led Risk Committee, including its specific composition and reporting relationship to the Board committee. While management roles are listed, the purpose is to illustrate the oversight structure and information flow upward, not to detail individual qualifications.


reasoning: The paragraph describes the governance chain and oversight structure, specifically that the board delegated oversight to a PRC subsidiary's Information Security Committee headed by the CEO. This fits Board Governance as it explains how oversight flows from the board downward. It is Firm-Specific due to the named non-generic committee (Information Security Committee) and reference to the specific PRC subsidiary structure.


reasoning: The paragraph identifies specific personnel managing cybersecurity processes (Manager of Information Technology and COO) and provides detailed qualifications including specific years of experience (25 and 15 years), triggering the qualifications tiebreaker for Management Role. The inclusion of two distinct numerical values regarding professional experience satisfies the Quantified-Verifiable threshold.


reasoning: The paragraph describes the governance chain for cybersecurity oversight (CFO/IT consultant → audit committee → Board) and briefing cadences, fitting Board Governance. It contains only generic roles (CFO, IT consultant, audit committee, Board) and vague temporal references ('periodic', 'regular') with no specific dates, names, numbers, or cybersecurity-specific titles, making it Generic Boilerplate.


reasoning: The paragraph contains a negative materiality assessment ('not aware of having experienced any prior material data breaches') and discusses potential future business and financial impacts, which qualifies as Strategy Integration. However, it lacks any specific dates, dollar amounts, named roles, or frameworks, making it generic boilerplate.


reasoning: The paragraph describes the governance chain from Board oversight through the CISO to the IS Program and incident response teams, emphasizing the oversight structure and upward information flow to the Board. While it mentions the CISO's qualifications, the primary purpose is describing governance structure rather than profiling the officer or detailing operational processes in isolation.


reasoning: The paragraph describes the governance structure and oversight chain of the Engineering Risk Steering Group, including its reporting relationship to the Firmwide Technology Risk Committee and its leadership by the CISO. The focus is on oversight structure rather than the CISO's individual qualifications or specific operational processes.


reasoning: The paragraph describes the governance chain and oversight structure (Board → Risk Committee → Cybersecurity Committee → Chief Risk Officer → CISO), which is the defining characteristic of Board Governance. While it includes extensive CISO qualifications, these support the governance description rather than making the paragraph primarily about the individual. The specificity is Quantified-Verifiable due to the specific number ('over 20 years') and multiple named professional certifications (CISSP, CISM, GLAW, GSEC).


reasoning: The paragraph consists primarily of materiality assessments—both backward-looking ('not aware of having experienced any material cybersecurity incidents') and forward-looking with the SEC qualifier ('reasonably likely to materially affect')—which explicitly define Strategy Integration per the guidelines. The fragment mentioning 'third-party security experts' lacks specificity (unnamed entities), and the cross-reference to Item 1A is generic.


reasoning: The paragraph identifies specific cybersecurity leadership roles (CTO and CISO) and their qualifications (25 years of experience), triggering the Step 3 tiebreaker for Management Role. While it mentions processes, the focus is on the specific individuals and cross-functional team structure responsible for implementation.


reasoning: The paragraph describes the governance structure for cybersecurity oversight, specifically how the Director of Compliance provides regular reports to the Board of Directors on cyber risks, controls, and third-party oversight. This is a classic governance-chain description. The identification of the specific role 'Director of Compliance' as the person providing these reports (rather than generic 'management') provides one firm-specific detail, though no dates, quantified metrics, or named standards are present.


reasoning: The paragraph describes the governance oversight structure and information flow, specifically that the CISO presents cybersecurity reports to the Risk Committee on a quarterly basis. While it mentions the CISO, the purpose is to explain the board/committee oversight mechanism (who reports to the committee and what information is provided), not the CISO's qualifications or the internal risk management processes themselves.


reasoning: The paragraph is primarily focused on identifying the CIO and CISO and detailing their extensive qualifications, educational backgrounds (Purdue University, Wayne State University, Carnegie Mellon University), certifications (CISSP), and professional memberships, which aligns with the Management Role category. Specificity is Quantified-Verifiable due to multiple hard facts including named third-party educational institutions and a named professional certification.


reasoning: Paragraph describes the company's internal cybersecurity processes, including the cross-functional incident response team structure, use of a GRC platform, and engagement of third-party detection services. While specific management roles and their experience are mentioned, the primary focus is on operational processes and program management rather than individual qualifications or board governance.


reasoning: The paragraph contains a negative materiality assessment ('has not experienced any material cybersecurity events'), which under SEC disclosure guidelines qualifies as a Strategy Integration conclusion about business impact. The remaining content consists of generic forward-looking risk warnings and a cross-reference to Item 1A, with no specific dates, frameworks, roles, or organizational details unique to the company.


reasoning: The paragraph describes the company's internal governance process for cybersecurity oversight through a specific management-level committee, its composition, and its activities (quarterly reviews, strategy approval). The grammatical subject is the committee itself, not the individuals, and removing the named roles leaves a coherent description of the oversight process. It includes firm-specific organizational details such as the 'Information Security committee' name and cybersecurity-specific roles (CDIO, CISO), but lacks quantifiable data like dates, costs, or headcounts needed for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal risk assessment processes, safeguard implementation, and monitoring activities. While it identifies the Senior Director, Head of IT and Informatics as the role responsible for these functions and notes their reporting relationship to the CFO, the content focuses on the risk management process itself rather than the individual's qualifications or background. Applying the person-removal test, the text remains a coherent description of cybersecurity risk assessment and mitigation processes without the named roles.


reasoning: The paragraph primarily describes the governance chain and oversight structure: the Board's responsibility for cybersecurity oversight, the reporting relationship between the Director of Information Technology and the Board, and the specific content of those reports (threat landscape, defensibility measures, control effectiveness). While risk assessment processes are mentioned, they are framed within the context of management's role in supporting Board oversight. The inclusion of the specific title 'Director of Information Technology' (functioning as the cybersecurity officer who reports to the Board) provides the single firm-specific detail needed for this classification.


reasoning: Paragraph describes generic internal processes for cybersecurity threat assessment and incident response (escalation to board, mitigation, disclosure) without naming specific frameworks, dates, dollar amounts, headcounts, tools, or individuals. Grammatical subjects 'management' and 'board of directors' are generic roles; 'Public Offering' lacks specific dates or amounts to constitute a hard fact. After removing these generic roles, the remaining text describes standalone processes rather than specific governance structure or individual qualifications.


reasoning: The paragraph describes the company's internal cybersecurity controls (firewalls, endpoint detection, vulnerability management, backups) and processes for managing third-party technology risks, placing it in Risk Management Process. While it mentions the CISO and CIO in an oversight context, the grammatical subject is the 'cybersecurity organization' and its activities, not the individuals' qualifications. The identification of a Chief Information Security Officer provides one firm-specific fact, but no second hard verifiable fact (dates, amounts, named products/firms) is present to reach Quantified-Verifiable.


reasoning: The paragraph consists of generic IT-dependence language ('IT systems are critically important') and describes the types of data handled and regulatory environment (HIPAA/CCPA) without disclosing specific cybersecurity governance structures, management roles, risk management processes, or materiality assessments. It provides business context rather than substantive cybersecurity program disclosure.


reasoning: The paragraph describes the governance structure for Board oversight of cybersecurity, specifically how information flows upward via periodic briefings from the VP of Technology and an Executive Officer to the Board of Directors. The inclusion of the specific cybersecurity leadership title 'Vice President of Technology' (functionally equivalent to VP of IT/Security) distinguishes this from generic boilerplate, though no other firm-specific details (dates, names, frameworks) are present.


reasoning: The paragraph describes governance structure and oversight chains—specifically the composition and functions of the IT Steering Committee and the reporting relationship where the IT manager briefs the Risk Management committee quarterly. This focuses on how cybersecurity oversight is organized and how information flows upward through committees, which is the defining scope of Board Governance.


reasoning: The paragraph centers on identifying specific cybersecurity personnel (CTO, Information Security Manager/Officer) and details the CTO's professional qualifications (30+ and 20+ years of experience), triggering the qualifications tiebreaker for Management Role. It contains two specific numeric facts (years of experience) that satisfy the Quantified-Verifiable threshold.


reasoning: The paragraph describes the company's internal Cyber Incident Management Team (CIMT), its specific departmental composition, and its coordination responsibilities for incident response (containment, investigation, recovery). While it mentions reporting relationships to the Board and Governance Committee, the primary subject is the incident response process and team structure, not board oversight or individual management qualifications. It contains firm-specific details including the named CIMT program, specific cybersecurity titles (IT Director, Cyber Security; CDO), and explicit departmental composition.


reasoning: The paragraph describes the governance structure of a management-level committee, its composition, and reporting lines (director of information security → committee), which falls under Board Governance. It includes firm-specific details such as the named 'Bank Technology Governance Committee' and cybersecurity-specific roles (CIO, director of information security).


reasoning: The paragraph describes the company's internal management committee structure and processes for cybersecurity oversight (IT Steering Committee and IT Subcommittee), including their composition and responsibilities (reviewing controls, monitoring threats). While it mentions specific officers, the content focuses on the governance process and operational functions rather than individual qualifications (Risk Management Process). It contains firm-specific details including named committees and cybersecurity-specific roles (CISO, CTO, CRO), but lacks quantifiable data like dates, dollar amounts, or headcounts needed for Quantified-Verifiable.


reasoning: The paragraph primarily describes the governance chain and oversight structure for cybersecurity (CFO directs programs, significant incidents reported to the Board, Audit Committee receives updates). It specifically notes the structural detail that the Board lacks a designated cybersecurity committee. While the paragraph includes a backward-looking materiality assessment regarding 2024, the governance description constitutes the primary content and purpose.


reasoning: The paragraph describes the governance chain and oversight structure (board → management → VP of Operations → audit committee → board), explaining how cybersecurity risk is overseen and reported upward. It mentions the VP of Operations only to describe reporting lines, not qualifications or credentials. No specific dates, numbers, frameworks, or cybersecurity-specific titles (e.g., CISO) are present, making the content generic boilerplate.


reasoning: The paragraph constitutes a materiality assessment stating that cybersecurity threats have not materially affected and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which aligns with Strategy Integration. It contains no specific dates, named roles, frameworks, or quantifiable details—only generic materiality language and cross-references that could appear in any filing.


reasoning: The paragraph presents a backward-looking materiality assessment stating that cybersecurity incidents have not materially affected the company's business strategy, results of operations, or financial condition, which is the defining characteristic of Strategy Integration. It contains no specific dates, named third-party providers, dollar amounts, or other verifiable facts—only generic references to 'third-party service providers' and 'the date of this report'—making it generic boilerplate.


reasoning: The grammatical subject is 'cybersecurity risk management and strategy processes,' describing internal oversight structure rather than individual officer qualifications or board governance. The specific naming of five distinct departments (IT, InfoSec, Product Security, Compliance, Legal) constitutes a firm-specific organizational detail.


reasoning: The paragraph describes the composition and leadership of the ISO Committee, establishing the governance structure for cybersecurity oversight (committee → officer chain). Although management roles and qualifications are mentioned, the purpose is to describe the oversight structure, not individual biographies. Specificity is Firm-Specific due to the named ISO Committee, the cybersecurity-specific CISO role, and the quantified experience metric.


reasoning: The paragraph describes internal cybersecurity processes (Incident Response Plan maintenance, annual testing, training, incident logging) using the CISO and CTO as grammatical subjects, but the content constitutes a coherent process description when persons are removed (passing the person-removal test) and lacks qualifications or experience details. It identifies specific cybersecurity roles (CISO, CTO) and a non-generic committee (Risk Committee), making it Firm-Specific.


reasoning: The paragraph presents a materiality assessment using the SEC's forward-looking qualifier 'reasonably likely to materially affect,' constituting a Strategy Integration conclusion that no material cybersecurity weaknesses exist. It contains no specific facts, dates, named entities, or quantifiable data—only generic negative assurance language applicable to any company.


reasoning: The paragraph describes the governance chain for cybersecurity oversight: the MAT assesses threats identified by the CIO/CISO and reports material items to the Risk Committee. This describes the oversight structure and information flow to the board level, fitting Board Governance. It contains specific organizational details (CISO, CIO, Risk Committee, MAT) but no quantified data like dates or dollar amounts, making it Firm-Specific.


reasoning: Paragraph describes the structure and composition of specific oversight committees (OROC and IT Steering Committee) responsible for cybersecurity governance, including their leadership (CRO, CIO), meeting cadence, and departmental composition. This is governance structure, not management qualifications or risk processes.


reasoning: The paragraph contains a negative materiality assertion stating that the company did not experience any cybersecurity incidents during the specific year 2024, which falls under Strategy Integration per the guidance that negative assertions ('have not experienced any material cybersecurity incidents') are materiality assessments. The reference to the specific calendar year 2024 constitutes one firm-specific fact, but no additional hard verifiable facts (such as exact dates, dollar amounts, or named entities) are present to reach Quantified-Verifiable.


reasoning: The paragraph describes the internal process for monitoring cybersecurity incidents (prevention, detection, mitigation, remediation) and the information flow from service providers. Under the person-removal test, removing 'Management' and 'ISP personnel' leaves a coherent description of the monitoring process, confirming Risk Management Process rather than Management Role. The paragraph contains no named frameworks, specific dates, dollar amounts, or unambiguous specific roles (e.g., CISO), and terms like 'Management' and 'service providers' are explicitly generic per the exclusion list.


reasoning: The paragraph consists of forward-looking risk warnings and generic descriptions of potential consequences from cyber incidents (data misappropriation, operational disruption) without describing specific governance structures, management roles, internal processes, or actual events. It contains no materiality assessment conclusion and lacks any firm-specific details, named entities, or verifiable facts.


reasoning: Paragraph describes the governance structure and reporting cadence (semi-annual/annual) between the VP of IT and the Audit and Reserves Committee regarding cybersecurity oversight. Despite the VP IT being the grammatical subject, the purpose is describing the oversight chain (committee ← officer), making this Board Governance per the governance-chain rule.


reasoning: The paragraph describes the company's internal cybersecurity incident management processes, including the establishment of a crisis management team led by CIO/CISO and a cyber incident disclosure committee for materiality assessments. It focuses on operational protocols and governance structures rather than individual qualifications or board oversight mechanisms.


reasoning: This is generic forward-looking speculation about potential consequences of a cyber attack ('could be subject to fines...could significantly harm'), not a substantive disclosure of governance, processes, or an actual incident. It lacks SEC-qualified materiality assessment language ('reasonably likely to materially affect') and contains no specific facts, dates, or identifiable details unique to the company.


reasoning: While the paragraph describes governance reporting lines, it focuses substantively on the qualifications and experience of the CISO (15 years, CISSP certification) and the specific composition of the cybersecurity leadership team and Enterprise Risk Committee. Under the three-step test, the presence of specific certifications and years of experience triggers Management Role classification. Specificity is Firm-Specific due to named cyber-specific roles, non-generic committees (Risk and Technology Committee), exact experience duration, and detailed cross-functional team composition.


reasoning: The paragraph focuses on the qualifications and experience of personnel (IT Lead with 11 years of experience, external agency with about 8 years of expertise). Applying the three-step MR vs. RMP test: (1) persons are grammatical subjects, (2) removing person details leaves minimal coherent disclosure about the actual processes, and (3) the paragraph includes specific years of experience. For specificity, '11 years' is one hard fact, but 'about 8 years' is approximate (similar to 'approximately two weeks' in the calibration examples) and does not count as a second hard verifiable fact; thus it is Firm-Specific rather than Quantified-Verifiable.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors and contains generic forward-looking risk disclaimers ('may disrupt our businesses, result in losses') rather than substantive disclosure of governance structures, management roles, risk processes, or actual incidents.


reasoning: The paragraph describes the governance/oversight structure for cybersecurity, specifically how the Board of Directors of the Sponsor receives reports from BlackRock regarding BlackRock's cybersecurity program and how the Sponsor relies on BlackRock's ERM framework for the Trust's risk management. This focuses on the oversight chain (Board → Sponsor → BlackRock) rather than describing internal risk management processes or management qualifications.


reasoning: Paragraph primarily describes the company's Enterprise Risk Management (ERM) program structure, including the specific committee overseeing it, internal reporting lines, and integration of cybersecurity risk into the ERM process. The mention of board member cybersecurity training appears as a supporting detail rather than the primary focus. Contains two or more independently verifiable hard facts: named third-party entities providing training/certification (National Association of Corporate Directors and Software Engineering Institute at Carnegie Mellon University) and named certifications (CERT Certificate in Cybersecurity Oversight).


reasoning: The paragraph contains a backward-looking materiality assessment (negative assertion) stating the company 'have not experienced a cybersecurity incident that resulted in a material adverse impact,' which qualifies as Strategy Integration. The remainder is generic risk speculation without specific dates, amounts, named entities, or firm-unique details.


reasoning: The paragraph describes the company's internal risk management framework (three lines of defense), technology control testing, risk assessments, and monitoring processes. While the VP, ISS is mentioned as the grammatical subject, the content focuses on what the program does rather than the individual's qualifications or credentials. The specific title 'Vice President of Information Security Systems' constitutes one firm-specific fact, but there are no dates, dollar amounts, headcounts, or named third-party firms/tools to reach Quantified-Verifiable.


reasoning: The paragraph describes the company's internal incident response governance structure and processes, including the establishment of a crisis management team, communication protocols to the Board, and materiality evaluation procedures. While it mentions cybersecurity-specific roles (CIO, CISO) and specific internal committees, the primary focus is on the organizational process for managing incidents rather than the qualifications of individuals or Board oversight structure.


reasoning: Paragraph describes the company's internal risk management framework and processes (identification, analysis, and response to risks) and a management committee structure for overseeing day-to-day risk administration. While an Executive Director of Information Technology is mentioned as chairing the committee, this title is not a cybersecurity-specific role per the defined list (e.g., CISO, CIO, Director of IT Security), and the disclosure contains no named frameworks, dates, quantified metrics, or other firm-specific details that would distinguish it from generic risk management language applicable to any company.


reasoning: The paragraph describes the governance chain and oversight structure: board-level committees (Innovation and Technology Committee) receive reports from management committees (IT Steering Committee, Operational Risk Management Committee) which are chaired by specific officers and include the CISO. This focuses on how the board exercises oversight and how information flows upward, which is the definition of Board Governance.