reasoning: Applying the MR vs RMP three-step chain: Step 1 — mixed subjects (program + named roles). Step 2 — Person-removal test: removing the named titles, the paragraph still coherently describes how risks are identified, assigned to owners, and remediated — the process stands on its own. Step 3 — No qualifications, certifications, years of experience, or career history appear for any named role. The paragraph's primary communicative purpose is describing the company's risk identification and remediation workflow, with roles serving as incidental attribution for who performs each function. The EVP of Global IT, Risk Subcommittee, and VP/CISO are firm-specific facts but do not reach QV (no hard verifiable facts like dates, dollar amounts, or named third-party firms).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes:
1. Senior management meeting regularly to assess IT risks
2. EVP of Global IT and eDiscovery Operations reporting to Board via CEO, member of Risk Subcommittee
3. VP, CISO responsible for identifying cybersecurity risks and vulnerability assessments
4. Risk owners and remediation process

Let me apply the three-step decision chain for MR vs RMP:

Step 1 — Subject test: "Our risk management program" is the first subject, but then it shifts to named roles. Mixed subjects - continue to Step 2.

Step 2 — Person-removal test: When I strip away the titles and roles, what's left is the core process—how risks get identified, assigned to stakeholders, and remediated over time. But the paragraph is heavily focused on who holds which positions and their reporting relationships, so there's substantial organizational structure embedded here.
Step 3 — Qualifications tiebreaker: No years of experience, certifications, education, team size, or career history mentioned, so this doesn't help distinguish between the two categories.

Now I'm weighing whether the governance structure (reporting to the Board through the CEO) is the primary focus or just context for the risk management process. The Risk Subcommittee and the process of risk identification and remediation seem to be the main point, even though specific roles like the EVP of Global IT and eDiscovery Operations and VP CISO are named. The reporting line exists, but it's not the dominant theme—the process is. I'm going with Risk Management Process as the category.

Looking at the specificity now: the paragraph includes firm-specific titles and committee names like the Risk Subcommittee, VP CISO, and EVP of Global IT and eDiscovery Operations, but no quantifiable facts like dates, dollar amounts, or headcounts. This puts it at Firm-Specific level 3.

fact: Executive Vice President of Global IT and eDiscovery Operations

fact: Risk Subcommittee

fact: Vice President and Chief Information Security Officer (VP, CISO)


content_category: Board Governance

category_confidence: high

specificity_confidence: medium

reasoning: The paragraph describes how information flows upward to the full Board via the CFO, with details originating from the DIT and DIS — this is governance oversight structure (how the board stays informed). DIT and DIS are firm-specific cybersecurity/IT role abbreviations unique to this company's disclosure, qualifying as Firm-Specific. CFO alone would be generic, but the DIT/DIS roles are cybersecurity-adjacent titles not found at every company.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

This describes how the CFO provides updates to the Board, with information flowing from DIT and DIS roles. This is about the governance/oversight structure - how information flows upward to the board.

Category: Board Governance - describes reporting structure to the board, how information flows upward.

Specificity: "DIT" and "DIS" - these appear to be firm-specific role abbreviations (Director of IT, Director of Information Security or similar). These are cybersecurity-specific titles. So Firm-Specific.

Wait - CFO is generic C-suite (NOT list). But "DIT and DIS" are firm-specific abbreviations for cybersecurity/IT leadership roles.

The firm-specific role references DIT and DIS make this Firm-Specific (3).

fact: DIT (Director of Information Technology)

fact: DIS (Director of Information Security)


content_category: Strategy Integration

specificity_confidence: high

reasoning: The paragraph contains a backward-looking materiality assessment ('we have not experienced material adverse effects from cybersecurity threats to date'), which is a negative assertion about materiality triggering Strategy Integration per Rule 6. The opening sentence ('have the potential to materially affect') is speculative ('potential' ≈ 'could'), not an assessment, but the negative assertion is decisive. The cross-reference to Item 1A is incidental noise. No specific facts from the IS list are present — all language is generic boilerplate.

thinking:
Let me analyze this paragraph carefully.

The paragraph contains:
1. "Cybersecurity threats have the potential to materially affect our company, including our business strategy, results of operations, and financial condition." - This uses "have the potential to materially affect" which is closer to "could" than "reasonably likely to." It's speculative, not an assessment.

2. "While we have not experienced material adverse effects from cybersecurity threats to date" - This IS a backward-looking materiality assessment (negative assertion).

3. "we recognize the evolving nature of these risks and remain vigilant" - generic

The second sentence is the key here—it's a clear backward-looking negative assertion about materiality. Even though the first sentence is speculative language, the statement that we haven't experienced material adverse effects triggers Strategy Integration under Rule 6. There are no specific facts disclosed from the IS, so this would be classified as Strategy Integration with no specificity.


category_confidence: medium

reasoning: This is a governance-chain paragraph describing the oversight structure: incident response procedures exist, the Audit Committee oversees cybersecurity, and the Senior Director - Information Security coordinates initiatives. The purpose is mapping the oversight hierarchy (board committee → named officer → personnel), making it Board Governance. The Senior Director - Information Security is a cybersecurity-specific title (IS list), elevating specificity to Firm-Specific; the Audit Committee is generic and does not count.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three sentences:
1. "Cybersecurity incidents are investigated and remediated in accordance with our incident response procedures and other policies and procedures." - RMP
2. "Cybersecurity is overseen by the Audit Committee of the Board of Directors." - BG
3. "The Senior Director - Information Security coordinates with and directs cybersecurity initiatives through information technology and cybersecurity personnel throughout RPM." - This could be MR or RMP

This is a governance-chain paragraph spanning board → officer → program. What's the purpose? It's describing the oversight structure: incidents follow procedures, Audit Committee oversees, Senior Director coordinates. The purpose is describing the structure of oversight and responsibility.

Looking at the three distinct topics here - incident response, board oversight, and the Senior Director's role - I'm seeing a governance overview that maps out who oversees what at different levels. The Audit Committee provides board-level oversight, the Senior Director manages the operational coordination, and the incident response process sits underneath. This is fundamentally about describing the oversight structure and how responsibility flows through the organization.

Now examining the specificity: "Audit Committee" is generic governance language, but "Senior Director - Information Security" is a concrete, firm-specific title that signals this is tailored to their actual organizational structure. There are no named frameworks or quantified facts here, so this lands as Board Governance with firm-specific details.

fact: Senior Director - Information Security


content_category: Risk Management Process

reasoning: The paragraph describes how the company's cybersecurity function is organized and operates — outsourced to service providers who handle IT, facilities, and IP protection, with prevention/detection/mitigation/remediation oversight. Applying the person-removal test: removing 'Principal Financial Officer' leaves a coherent process description of outsourced security operations and reporting channels, so this is RMP, not Management Role. Third-party providers are mentioned as a component of how the company manages cybersecurity internally, not as the central topic of vendor oversight requirements. No cybersecurity-specific titles (PFO is a generic financial role, not on the IS list), no named frameworks, no named firms, no specific dates or quantified facts — all entities are unnamed ('service providers,' 'Principal Financial Officer') and cadences are generic ('regular communication').

thinking:
Let me analyze this paragraph.

Content: The paragraph describes an outsourced IT security team, two service providers, one handling IT/facilities/IP protection, reporting to the Principal Financial Officer, who oversees prevention/detection/mitigation/remediation.

Category analysis:
- This describes the management structure for cybersecurity - who is responsible and how the outsourced team reports
- The Principal Financial Officer oversees cybersecurity efforts
- There's a third-party element (outsourced to service providers)
- But the central topic is really about how the company manages cybersecurity through these providers and the reporting structure

- Now I'm working through the decision rules to categorize this properly. The outsourced providers are mentioned, but the focus isn't on vendor oversight requirements—it's on the company's internal management structure and how cybersecurity responsibilities are organized and reported up through the PFO. This looks like it's primarily about the company's risk management process and organizational structure rather than third-party vendor management. The PFO is really just incidental here—removing it doesn't break the core description of how the company manages its cybersecurity process through service providers. Looking at specificity, "Principal Financial Officer" isn't a cybersecurity-specific title, the service providers are unnamed, and outsourcing itself is firm-specific rather than universal. The number "two" might qualify as a specific headcount, but I need to think through whether that crosses into the kind of detail the IS list is flagging.

Actually, counting vendors feels different from counting people or dollars—it's more of a vague organizational detail without named entities. And even though full outsourcing of the Information Security Team is somewhat distinctive, there's no named framework, no cybersecurity-specific titles per the IS list, no named firms, and no dates or qualifying numbers. This reads as generic boilerplate to me.


reasoning: This is a governance-chain paragraph describing the oversight and responsibility structure for cybersecurity risk management — the board and a named committee provide oversight while the IT management team executes. Per Rule 2, governance-chain paragraphs describing who oversees and who is responsible are Board Governance. The Nominating and Corporate Governance Committee (rather than the standard Audit Committee) handling cybersecurity oversight is a firm-specific structural fact; COO, CFO, and General Counsel are generic C-suite titles on the NOT list.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes who is responsible for cybersecurity risk management. Let me apply the decision rules.

Subject: "Our IT management team" - this is the grammatical subject.

The paragraph mentions:
- IT management team (subject)
- Board of Directors (oversight)
- Nominating and Corporate Governance Committee (oversight)
- COO, CFO, General Counsel (management team members)
- Responsibility: "assessing and managing material risks from cybersecurity threats"

Category analysis:
- This spans board oversight and management roles. What's the purpose?
- The paragraph describes a governance/oversight STRUCTURE - who is responsible, with oversight from whom.

- The IT management team holds primary responsibility for cybersecurity risk assessment and management, while the board and its governance committee provide oversight. This is fundamentally about describing the governance chain and reporting structure for cybersecurity accountability.

- The paragraph doesn't focus on individual qualifications or credentials—it's generic about roles (COO, CFO, General Counsel) and the IT management team itself. The only named entity is the Nominating and Corporate Governance Committee.

- Since this describes who oversees and who manages cybersecurity risks within the organizational hierarchy, it's a governance-chain paragraph, which typically falls under Board Governance per the classification rules.

- Applying the Management Role vs. Risk Management Process test: the subject is a group (IT management team), not a specific person. Removing titles, the core claim is about responsibility assignment for assessing and managing cybersecurity risks—not about describing actual processes or procedures.

- The communicative purpose is clearly to explain the oversight and reporting structure for cybersecurity risk management—who reports to whom and how information flows to the board. This aligns with Board Governance.

- For specificity, I'm checking whether named committees qualify as "non-generic." The Nominating and Corporate Governance Committee is actually a standard committee at most public companies, similar to the Audit Committee. The codebook explicitly excludes Audit Committee from the IS list, but doesn't mention Nominating and Corporate Governance Committee. It's somewhat unusual for this committee to handle cybersecurity oversight, which makes me uncertain whether it should count as non-generic for the IS list.

I'll classify it as firm-specific since it's a named committee handling cybersecurity oversight in a way that reveals something about this company's particular governance structure, even if the committee itself is standard. That gives me one firm-specific fact: the Nominating and Corporate Governance Committee. There are no QV facts here—no dates, amounts, headcounts, third-party firms, tools, certifications, or experience metrics.

fact: Nominating and Corporate Governance Committee (non-standard committee for cybersecurity oversight)


reasoning: This is a governance-chain paragraph describing how cybersecurity information flows upward: CIO → Executive Leadership Team → Audit Committee → Board. The purpose is describing the oversight and escalation structure, not who the CIO is or what the program does operationally. Firm-Specific due to CIO (cybersecurity-specific role), named CSIRP with abbreviation, and named teams (Executive Leadership Team, Executive Response Team), but no two QV-eligible hard facts.

thinking:
Let me analyze this paragraph.

Content category: This describes governance structure - how information flows from CIO to Executive Leadership Team to Audit Committee to Board. It's about oversight structure and reporting chains.

The paragraph covers:
1. CIO provides briefings to Executive Leadership Team
2. CIO updates Audit Committee biannually
3. Board members can raise concerns
4. CSIRP includes escalation to Board

This is a governance-chain paragraph. The purpose is describing how oversight works - information flow from management up to board. Per Rule 2, governance-chain paragraphs are Board Governance.

Now I'm checking the specificity of each element. The CIO is a cybersecurity-specific title, and CSIRP is a named internal program with its own abbreviation. The Executive Leadership Team is identified by its composition, and there's mention of an Executive Response Team that might be a named team. However, the Audit Committee and Board of Directors are generic references, and "biannually" is just a standard cadence without particular specificity. The IS facts I'm pulling out are the CIO, CSIRP, and the Executive Leadership Team.

Looking at the QV criteria—there are no dates, dollar amounts, headcounts, or named third-party firms or tools mentioned, so this doesn't qualify as QV. Since there's at least one IS fact present, this falls into the Firm-Specific category.

fact: CIO provides cybersecurity briefings

fact: Executive Leadership Team (Company's executive officers and other senior leaders)

fact: CSIRP (Cyber Security Incident Response Plan) with escalation protocol

fact: Executive Response Team


content_category: None/Other

reasoning: The paragraph is a generic risk warning about the company's inability to effectively manage cybersecurity due to lack of manpower, expertise, and financial resources. It describes no processes, governance structures, management roles, or materiality assessments. Per the SPAC/no-operations exception and its spirit, the explicit absence of cybersecurity capability is not a substantive disclosure of a program — it is an admission of inadequacy with boilerplate risk language ('no assurance or guarantee'). No facts from the IS list are present.

thinking:
This is a small company (Peak Bio) explicitly stating they lack resources for cybersecurity. Let me classify this.

Content: Says identification/detection/prevention is costly, they don't have manpower/expertise/resources, no guarantee they won't be damaged. This is essentially saying they have no real cybersecurity program - similar to SPAC/shell company language. But it's not quite saying "we have no program" - it's saying they lack resources to effectively manage cyber risk.

This reads like generic risk language about their inability to manage cyber risks. No processes described, no governance, no materiality assessment. It's closer to None/Other or possibly Strategy Integration (discussing resource constraints as business impact)?

They're acknowledging resource limitations as a risk statement, but there's no materiality assessment, no process description, no governance structure - just generic warning language about lacking the capacity to manage cyber risk effectively. This doesn't fit the substantive categories since there's no board governance mentioned, no management roles defined, and they explicitly say they lack the resources for risk management processes. It's closer to the SPAC rule where companies stating they have no real program get classified as None/Other. they CAN'T do this effectively)
- Not Third-Party Risk
- Not Incident Disclosure
- Not Strategy Integration (no materiality assessment, no business strategy connection per the rules - "could" language is speculation not assessment)

The paragraph is essentially a risk warning about their cybersecurity inadequacy. It's generic risk language. → None/Other, Specificity 1.

Wait, but Rule 5 says "Assign None/Other ONLY when the paragraph contains no substantive cybersecurity disclosure content." Does acknowledging you lack cybersecurity resources count as substantive disclosure?

The SPAC exception says "The absence of a program is not a description of a program." This is similar - they're saying they can't effectively do cybersecurity. This is closer to the "no formal processes" category.

I'll go with None/Other, Specificity 1 because this is just a generic risk warning without any actual description of cybersecurity programs, governance structures, or a meaningful assessment of business impact.


reasoning: This paragraph describes generic cybersecurity threat landscape language (hackers, nation-state actors, social engineering, cyber extortion) without any company-specific disclosure, process description, or materiality assessment. Despite the header mentioning 'business strategy, results of operations or financial condition,' the paragraph itself makes no materiality conclusion — it merely catalogs threat types that apply to any company.


reasoning: This is a governance-chain paragraph whose explicit purpose ('To further maintain governance and oversight') is describing the oversight structure spanning named committees → CISO → CEO → board. Per the codebook, governance-chain paragraphs are Board Governance even when management figures are prominent, because the communicative purpose is describing how oversight works. Specificity is Firm-Specific due to two named non-generic committees (Information Security Council, Executive Information Security Committee) and a cybersecurity-specific role (CISO), but none of these are QV-eligible hard facts.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes governance and oversight structure including:
1. Information Security Council and Executive Information Security Committee
2. CISO and colleagues with experience
3. CEO receives updates from CISO
4. Internal and external auditors
5. Quarterly reviews by management, committees, and board

This spans multiple layers. Let me apply the decision rules.

Purpose test: The paragraph describes the oversight STRUCTURE - how governance works, who reports to whom, how information flows. It mentions the board at the end receiving quarterly reviews. But the primary focus is on the management-level governance structure (councils, committees, CEO-CISO interaction).

Actually, I need to reconsider the framing here. The opening explicitly states this is about maintaining governance and oversight, and while the bulk describes management-level committees and the CEO-CISO relationship, the paragraph does conclude with quarterly board reviews. The core purpose is establishing the governance chain from management committees up through the CEO to the board, so this is fundamentally a board governance paragraph.

Now I'm checking the specificity of the elements mentioned. The named committees like "Information Security Council" and "Executive Information Security Committee" are specific governance bodies, and the CISO is a cybersecurity-specific role, so those count as information security facts. The CEO reference is generic C-suite, so that doesn't add specificity.

For the quantitative verification threshold, I need at least two hard facts like dates, dollar amounts, headcounts, named firms, tools, or certifications. Named roles and committees alone don't qualify. Since this paragraph only has information security facts without meeting the QV requirement, it falls into Firm-Specific classification.

fact: Information Security Council

fact: Chief Information Security Officer


content_category: Management Role

reasoning: The paragraph is entirely about WHO sits on the ISO Committee — their titles, operational expertise, and qualifications. Applying the person-removal test, removing all roles and credentials leaves no coherent content; the paragraph is fundamentally about the people. The qualifications tiebreaker (25 years of experience) confirms Management Role. Specificity is Firm-Specific: multiple cybersecurity-specific roles (CISO, CTO) and a named non-generic committee (ISO Committee), plus one QV-eligible fact (25 years), but only one QV-eligible fact does not reach the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This describes the composition of the ISO Committee - naming specific roles and their qualifications.

Category: This is about who the people are on a management committee - their roles, titles, and qualifications. The paragraph describes the composition of the ISO Committee with specific roles and experience.

Let me apply the decision chain:
- Step 1: The subject is the ISO Committee and its members - people/roles as subjects.
- Step 2: Person-removal test - if I remove all roles, titles, qualifications, the paragraph has nothing left. It's entirely about WHO is on this committee and what they bring.

- Step 3: The paragraph includes specific qualifications like "over 25 years of experience in risk management."

This is clearly Management Role - it's focused on the people, their specific titles like CISO, CTO, and Chief Risk Officer, and what qualifications they bring to the committee. The ISO Committee itself isn't a board committee based on the structure described, so this is definitely management-focused rather than governance-focused. I'm checking the specificity: the committee has a named title, the roles are named and specific, there's a concrete number for experience, and the company is identified as First American Title Insurance Company.

For QV-eligible facts, I'm only finding one: the "over 25 years of experience" is quantified. The named roles and company name don't count as QV-eligible. That puts this in the Firm-Specific category.

fact: ISO Committee (named non-generic management committee)

fact: CISO

fact: Chief Technology Officer (CTO)

fact: Chief Risk Officer chairs the committee

fact: Chief Intellectual Property and Privacy Officer

fact: over 25 years of experience in risk management (Chief Risk Officer)

type: quantified


reasoning: This is a governance-chain paragraph describing how a management-led Risk Committee is composed, what it reviews (including cybersecurity risk), and how it reports upward to a board committee. The purpose is describing the oversight structure — how cybersecurity risk information flows from management to the board — making it Board Governance per the governance-chain rule. The specific composition of the Risk Committee (a non-generic named committee) and inclusion of the CIO (cybersecurity-specific title) provide firm-specific facts, but no QV-eligible hard facts reach the two-fact threshold.

thinking:
Let me analyze this paragraph.

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

Category analysis:
- This describes a management committee structure and its composition
- The Risk Committee is management-led (not a board committee)
- It reports TO "the Committee" (likely a board committee)
- The purpose is describing the governance chain: management Risk Committee → board Committee

This is a governance-chain paragraph. The purpose is describing oversight structure - how the Risk Committee is composed, what it reviews, and how it reports upward.

Now I'm reconsidering the classification. The Risk Committee is a management-level body, not a board committee itself, so this could fall under Management Role rather than Board Governance. The paragraph focuses on the committee's composition and function, with the reporting relationship being secondary. It's describing what management does in the governance structure, not primarily how the board oversees things. This feels more like Management Role territory. also see this as Management Role since it's about management's organizational structure for cybersecurity. However, Management Role focuses on individual qualifications, not committee structures, so Board Governance is the better fit here. This describes the oversight chain and how cybersecurity risk flows through the governance structure. The Risk Committee itself is a named non-generic committee with specific roles like the CIO, which satisfies the list criteria. There are no hard verifiable facts like dates or dollar amounts, so this isn't Quantified Verification. It's firm-specific since the Risk Committee is unique to this organization.

fact: Named management-led Risk Committee

fact: Chief Information Officer on committee

fact: Committee composed of President/CEO, CFO, General Counsel, Chief Compliance Officer, Chief Internal Auditor, Risk & Insurance Program Manager, SVP-AIU, SVP-CTU, CIO, VP-HR


reasoning: The paragraph's dominant content is the management-level 'information security advisory board' — its composition across named functional areas and its cybersecurity responsibilities. Per the MR definition, management committees responsible for cybersecurity fall under Management Role. The opening sentence about reporting to the Board is subordinate to the advisory board description. 'Director and VP of IT' are generic IT titles (NOT list), but the named information security advisory board and its specific departmental composition are firm-specific facts.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes:
1. An incident response team headed by Director and VP of IT that reports to executive officers and Board
2. An information security advisory board composed of senior leaders from various functions
3. The responsibilities of this advisory board

Let me apply the category decision rules:

**Category Analysis:**
- The first sentence describes reporting structure (incident response team → executive officers → Board). This touches on governance chain.
- The bulk of the paragraph describes an "information security advisory board" - its composition and responsibilities.

Is this Board Governance, Management Role, or Risk Management Process?

The "information security advisory board" here is an internal management-level advisory body (comprised of senior leaders within the Company), not the Board of Directors. This is describing a management committee structure. Applying the board-line test, the first sentence mentions reporting to the Board, but that's just one sentence. The dominant content is about the management-level advisory board - its composition and responsibilities. So this is primarily about the management committee structure - who comprises it and what it does.

Now I'm looking at the advisory board's responsibilities - what it actually does. The board's duties are largely advisory and oversight-focused: advising on policy, roadmap, investments, training, compliance, and risk mitigation. This describes a governance and oversight structure at the management level. The key question is whether this is about the Board of Directors or a management committee. Since the "information security advisory board" is explicitly an internal management committee, not the Board itself, and the paragraph focuses on the committee's composition and responsibilities rather than individual credentials, this falls under Management Role - it's describing the management committee structure responsible for cybersecurity oversight. I'm seeing that the first sentence about reporting to the Board actually points toward Board Governance, but the bulk of this is really about the management-level advisory board itself—its composition and responsibilities. The advisory board is a management committee responsible for cybersecurity oversight, which fits the Management Role definition. The titles mentioned like "Director of IT" and "VP of IT" are generic IT leadership, not cybersecurity-specific roles, so they don't push this toward a more specialized classification.

However, the "information security advisory board" is a named, cybersecurity-specific committee, and the detailed departmental composition across product, sales, manufacturing, legal, finance, HR, supply chain, IT, and regional teams makes this Firm-Specific. Since the verifiable facts here are the named committee and its composition—neither of which count as QV per the rules—this lands at Firm-Specific specificity.

So this is Management Role with Firm-Specific detail.

fact: information security advisory board (named non-generic committee)

fact: Composition includes product line, sales and marketing, manufacturing, legal, finance, human resources, supply chain, information technology, and regional representation


reasoning: Applying the MR vs RMP three-step chain: Step 1 — the grammatical subject is 'processes/program,' but the paragraph immediately pivots to who implements them. Step 2 — removing roles and qualifications strips significant content (the 25 years of experience, the CTO/CISO collaboration structure), weakening coherence. Step 3 — the paragraph includes a specific quantified qualification ('25 years of experience'), which is MR-specific content. The paragraph's purpose is identifying WHO runs the program and their qualifications/team composition, not describing WHAT the program does. For specificity, '25 years of experience' is one QV-eligible fact and the named roles (CTO, CISO) plus specific departmental composition are Firm-Specific but not QV-eligible, yielding only one QV-eligible fact — Firm-Specific, not Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph mentions the CTO and CISO with "25 years of experience" and describes their role in implementing cybersecurity processes. Let me apply the three-step decision chain for MR vs RMP.

Step 1 — Subject test: "Our cybersecurity risk assessment and management processes as well as our Information Security program" is the grammatical subject of the first clause — these are processes/programs. But then it says "implemented and maintained by certain Company management, including our CTO and our CISO, who have 25 years of experience..." So the subject is the processes, but then it pivots to who implements them with qualifications.

Step 2 — Person-removal test: If I strip out the specific roles and their qualifications, the core structure remains intact — the text still conveys that there's a program maintained by management working with a cross-functional team across IT, Legal, Privacy, Finance, and other departments. The 25 years of experience gets lost, but the essential program structure and departmental involvement still comes through.

Step 3 — Qualifications tiebreaker: The mention of "25 years of experience" is a specific, quantifiable qualification that pushes this toward Management Role. Looking at the three components — the CTO and CISO implementing the processes, their collaboration with a cross-functional team, and the multiple departments involved — this is fundamentally about who's responsible and their expertise. The CTO and CISO are both cybersecurity-specific titles, and that specific experience number makes this person and role-focused rather than process-focused.

Checking what's actually QV-eligible here: the "25 years of experience" is a concrete number, so that counts. The named roles and department compositions are Firm-Specific details but don't qualify as QV facts. That's only one QV-eligible fact, which means this falls short of the two needed for QV classification — so it stays Firm-Specific.

fact: CTO

fact: 25 years of experience in cybersecurity and IT Operations

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


reasoning: The paragraph's purpose is describing the governance/oversight structure: how the CISO and CTO report to the Board and Audit Committee, and the role of the ERM Committee in the reporting chain. This is a governance-chain paragraph where officers appear as intermediaries, making it Board Governance per the purpose test. Specificity is Firm-Specific due to cybersecurity-specific roles (CISO, CTO), the named ERM Committee, and the quantified 'six components,' but only one QV-eligible hard fact (the number six), insufficient for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content category: This describes oversight structure - CISO reports to Board, Audit Committee oversight, reporting cadence. The purpose is describing governance/oversight structure and how information flows upward. This is Board Governance.

Specificity: Let me check facts:
- CISO (cybersecurity-specific title) ✓ IS
- CTO (cybersecurity-specific title) ✓ IS
- "Information Security program" with "six components" - specific number
- Enterprise Risk Management Committee - named non-generic committee ✓ IS
- Audit Committee - generic, ✗ NOT

- The "six components" reference is a quantified fact that counts toward firm-specificity, while the named roles themselves don't. That gives me one QV-eligible item, making this Firm-Specific overall.

fact: CISO reports to the full Board of Directors

fact: six components of Information Security program

fact: Enterprise Risk Management Committee


reasoning: The paragraph contains a negative materiality assertion ('have not experienced any material cybersecurity threats or incidents'), which per Rule 6 is a materiality assessment → Strategy Integration. It also mentions cybersecurity insurance and a cross-reference to Risk Factors, but the materiality conclusion is the substantive disclosure content. No firm-specific facts: insurance is mentioned generically with no amounts or named insurers, and the cross-reference is noise.

thinking:
Let me analyze this paragraph.

The paragraph contains:
1. "have not experienced any material cybersecurity threats or incidents" - negative assertion with materiality framing → SI per Rule 6
2. Generic risk warning about future threats
3. Mention of cybersecurity insurance (no specifics)
4. Cross-reference to Risk Factors

The materiality assessment ("have not experienced any material cybersecurity threats or incidents") is the key content. Per Rule 6, negative assertions with materiality framing → Strategy Integration.

Specificity: No named standards, no firm-specific facts. "Cybersecurity insurance" is mentioned but no details.

This is generic boilerplate language without substantive disclosure.


reasoning: Applying the person-removal test: removing the CISO reference, the paragraph still coherently describes monitoring processes and an incident response runbook. The CISO is mentioned as staying informed, but the dominant content is the cybersecurity team's processes—regular monitoring, incident response procedures, and remediation. No qualifications, credentials, or career history are provided. One IS-list fact (CISO title) elevates specificity to Firm-Specific, but no second hard verifiable fact exists for QV.

thinking:
Let me analyze this paragraph.

Content category: The paragraph mentions "CICSO" (likely typo for CISO) and describes what the cybersecurity team does - monitoring, incident response, etc.

Step 1 (Subject test): Mixed - CICSO is subject of first sentence, "cybersecurity team" is subject of later sentences. Not decisive.

Step 2 (Person-removal test): Remove "The CICSO is regularly informed about..." - the remaining content about the cybersecurity team implementing monitoring and following incident response runbook is coherent. The CICSO mention is about staying informed, not about who the person is.

Step 3 shows no personal qualifications or certifications. Looking at the specificity, the CISO title is firm-specific, but the written security incident response runbook and cybersecurity team references are generic without unique identifiers, frameworks, dates, or named tools. This points to a Risk Management Process category with just one firm-specific fact.

fact: CICSO (CISO) role referenced


reasoning: The CISO is the grammatical subject, but applying the person-removal test, the paragraph describes the program's structure — multidisciplinary teams, monitoring activities, incident response coordination, and reporting flow. No personal qualifications or credentials are mentioned; the CISO is incidental attribution for a process description. The tail-end reporting to the audit committee/board is subordinate to the process focus. Firm-Specific due to the named CISO role and specific team compositions (Technology and ERM teams).

thinking:
Let me analyze this paragraph.

Content category: The paragraph describes what the CISO does in coordination with teams to implement a cybersecurity program. Let me apply the MR vs RMP decision chain.

Step 1 — Subject test: "AGM's CISO" is the grammatical subject. Person/role as subject → signal, continue to Step 2.

Step 2 — Person-removal test: Remove "AGM's CISO" and role references.

After stripping out the CISO and their role, what remains is still fundamentally about coordinating teams, implementing programs, and monitoring threats—all activities that require human judgment and discretion. This still reads as a Material Responsibility because the core functions don't work without someone actively making decisions and overseeing the process. The CISO role itself doesn't qualify as a quantifiable fact, and there are no dates, financial figures, or headcount specifics mentioned, so this doesn't meet the QV threshold. However, the presence of the CISO as an information systems role does make this Firm-Specific.

fact: CISO

fact: AGM Technology and ERM teams


reasoning: This is a governance-chain paragraph describing how oversight flows from the executive team through the Audit Committee and Board, with the CIO reporting upward. The primary communicative purpose is the oversight/reporting structure (who briefs whom, at what cadence), making it Board Governance. The CIO's 20-year experience in the final sentence is subordinate to the governance description. Specificity is Firm-Specific: CIO is a cybersecurity-specific role (IS list) and 'over 20 years' is a QV-eligible fact, but with only one QV-eligible hard fact it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Executive team + Audit Committee assess/manage cyber risk (governance structure)
2. Audit Committee and Board are briefed on cyber risks annually
3. CIO reports to Audit Committee on various topics
4. CIO's background (20 years experience)

Purpose test: This is a governance-chain paragraph describing how oversight works - from executive team → Audit Committee → Board, with the CIO reporting upward. The last sentence adds CIO qualifications.

The dominant purpose is describing the oversight/reporting structure. The CIO qualifications in the last sentence are subordinate. → Board Governance

Now I'm checking the specificity. The CIO title is firm-specific, and the "over 20 years" of experience is a concrete duration that qualifies for QV eligibility. But since the CIO is a named role, which doesn't count toward QV per the rules, I only have one QV-eligible fact. That makes this Firm-Specific overall.

fact: Chief Information Officer

fact: over 20 years of experience in information security


reasoning: Applying the MR vs RMP three-step chain: Step 1 — the grammatical subject is 'processes,' but the paragraph pivots immediately to the person. Step 2 — removing the VP's title, experience, and departmental description leaves only 'Our cybersecurity risk assessment and management processes are implemented and maintained by our executive leadership team,' a thin shell; the bulk is about who the person is and what they oversee. Step 3 — '20 years of experience' is a qualification, confirming Management Role. Specificity: one QV-eligible fact (20 years of experience) plus firm-specific facts (VP of Informatics title, team composition), but only one hard verifiable fact, so Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph mentions "Vice President of Informatics" who leads cybersecurity risk assessment and management processes, with "more than 20 years of experience in information technology" and oversees a department.

Let me apply the three-step decision chain for MR vs RMP:

Step 1 — Subject test: "Our cybersecurity risk assessment and management processes are implemented and maintained by..." — The grammatical subject is "processes." But then it pivots to describing the person. Not decisive, continue.

Step 2 — Person-removal test: Remove "led by the Vice President of Informatics, who has more than 20 years of experience in information technology and oversees the Informatics department which includes the Company's hardware, software, help desk, and cybersecurity team." What remains? "Our cybersecurity risk assessment and management processes are implemented and maintained by our executive leadership team." That's a coherent but very thin statement. The bulk of the paragraph is about the person — their title, experience, and what they oversee.

The qualifications tiebreaker confirms this is a Management Role. The Vice President title is cybersecurity-specific, and the "more than 20 years of experience" is a quantifiable fact that qualifies for QV eligibility.

However, I only have one QV-eligible fact when I need at least two, so this doesn't meet the QV threshold. The other details—the VP title and department composition—are firm-specific but not QV-eligible, which means this falls into the Firm-Specific category.

fact: Vice President of Informatics

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


reasoning: The paragraph contains an explicit backward-looking materiality assessment ('such risks have not materially affected us, including our business strategy, results of operations or financial condition'), which per Rule 6 triggers Strategy Integration. The cross-references to Item 1A and generic threat language are subordinate to this materiality conclusion. No firm-specific facts from the IS list are present—risk factor titles and generic threat mentions are not specific facts.

thinking:
Let me analyze this paragraph carefully.

The paragraph contains:
1. "such risks have not materially affected us, including our business strategy, results of operations or financial condition" - This is a backward-looking materiality assessment → Strategy Integration per Rule 6
2. Some generic threat language
3. Cross-references to Item 1A

The materiality assessment is explicit: "have not materially affected us, including our business strategy, results of operations or financial condition" - this is a clear backward-looking materiality conclusion → Strategy Integration.

Specificity: No named standards, no firm-specific facts from the IS list. The cross-references mention specific risk factor titles but those are just cross-references.

But looking at the overall language and structure, this is really just generic boilerplate without substantive risk disclosure.


reasoning: The paragraph describes how the CTO reports to a board committee on cybersecurity risks, how the committee escalates to the full board, and how committee members receive cybersecurity education — all describing the oversight/reporting structure. The CTO is an intermediary in the governance chain, not the focus of personal qualifications. CTO is a cybersecurity-specific title on the IS list, providing one firm-specific fact; 'quarterly' and 'the Committee' are generic and do not count.

thinking:
Board Governance - describes oversight structure, reporting to committee and board, briefing cadence.

Specific facts: CTO (cybersecurity-specific title per IS list). That's one fact → Firm-Specific.

No second QV-eligible fact. "Quarterly" is generic cadence.

fact: Chief Technology Officer


reasoning: The paragraph opens with a backward-looking materiality assessment ('has not experienced a cybersecurity threat or incident that materially affected its business strategy, results of operations or financial condition'), which is a company conclusion about materiality triggering Strategy Integration per Rule 6. The remainder is a cross-reference to risk factors, which is secondary. No specific facts from the IS list are present — all elements (Board, Audit Committee, company self-references, generic language) are on the NOT list.

thinking:
Materiality assessment + cross-reference. The first clause is a backward-looking materiality assessment ("has not... experienced a cybersecurity threat or incident that materially affected its business strategy, results of operations or financial condition"). Per Rule 6, this is Strategy Integration. The cross-reference is noise.

Specificity: No specific facts from the IS list. Generic boilerplate materiality language.


reasoning: The paragraph spans Board Governance (one sentence on Board approval), Management Role (CISO credentials), and Risk Management Process (IS Program focus areas, IR Team, detailed incident response plan). Applying the person-removal test: removing the CISO's title and 15-year experience leaves a coherent description of program activities, the IR team's mission, and the incident response plan — the process content is dominant by text volume. Specificity is Firm-Specific: CISO as a cybersecurity-specific title and 'over 15 years' are IS-list facts, but only one QV-eligible hard fact (years of experience) prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This is a complex paragraph spanning multiple categories. Let me apply the decision rules.

The paragraph covers:
1. Board approval/oversight of IS Program (Board Governance)
2. CISO credentials - 15 years experience (Management Role)
3. IS Program activities - preventing, detecting, responding (Risk Management Process)
4. Incident Response Team and incident response plan (Risk Management Process)

Let me apply the dominant category rule. The paragraph starts with one sentence about the Board, then moves to CISO credentials (one sentence), then spends the majority describing the IS Program's focus and incident response processes.

Looking at the text volume, the core content is really about what the program does and how it handles incidents. The CISO credentials are mentioned briefly, but the paragraph's substance focuses on the Risk Management Process—the program's preventive and detective capabilities, the incident response team, and the formal plan in place. Even if I remove the CISO reference, the paragraph still makes sense as a description of the program's risk management approach.

For the specificity assessment, "over 15 years" is a concrete number that could count toward QV, but the named roles like CISO and IS Program Coordinator don't qualify under the rules. The program name and team name are somewhat generic organizational terms rather than truly unique identifiers.

So I'm looking at just one QV-eligible fact here, which means this falls into Firm-Specific territory rather than QV. The content is anchored by specific internal designations and experience level, but lacks the third-party references or certifications that would push it higher.

fact: CISO designated as IS Program Coordinator

fact: Over 15 years of relevant IT, security, and program management experience

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

fact: Information Security Incident Response Team


reasoning: This is a governance-chain paragraph: the board approves management committees, the IT Steering Committee provides oversight, and the Information Security Officer reports back to the board. The communicative purpose is describing the oversight structure—how information flows from the committee up to the board—making it Board Governance per the purpose test. Multiple firm-specific facts (named non-generic committee, three cybersecurity-specific roles) place it at Firm-Specific, but none are QV-eligible hard facts (named roles don't count toward QV).

thinking:
Let me analyze this paragraph carefully.

This paragraph describes a management committee (IT Steering Committee) that provides oversight of technology and security programs. Let me work through the category and specificity.

**Category Analysis:**

The paragraph describes:
1. Board approved management committees (governance chain)
2. IT Steering Committee's focus and role
3. Committee composition (CIO, CTO, ISO)
4. Committee meeting cadence (quarterly)
5. Reporting to the board (ISO reports to board)

This is a governance-chain paragraph spanning board → committee → officers → program. The purpose is describing the oversight STRUCTURE - how oversight works, who sits on the committee, how information flows to the board.

The IT Steering Committee is a management-level body chaired by managers and staffed with the CIO, CTO, and ISO, and since it's established by board approval and reports back to the board, this fits the Board Governance category - it's describing how the oversight structure flows from the board through management committees and back up again.

Now I'm identifying the specific firm facts here: the named committee itself, plus the three named roles from the IS list. That gives me at least one IS fact, making this Firm-Specific content, though there aren't enough hard verifiable facts like dates or dollar amounts to trigger the QV threshold.

fact: Information Technology Steering Committee

fact: Information Security Officer


reasoning: This is a governance-chain paragraph describing the oversight structure from Board → Audit Committee → Management (Principal Accounting Officer) → cybersecurity consultants. The purpose is describing how oversight works and how information flows upward, making it Board Governance per the purpose test. No facts from the IS list are present: 'Principal Accounting Officer' is not a cybersecurity-specific title, 'Audit Committee' is generic, 'cybersecurity consultants' are unnamed, and 'at least annually' is a generic cadence.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a governance chain: Board → Audit Committee → Management (Principal Accounting Officer) → cybersecurity consultants. It covers oversight structure, reporting lines, and how information flows upward.

Category analysis:
- Board has overall oversight responsibility
- Management identifies/assesses risks, establishes processes
- Principal Accounting Officer directs cybersecurity programs, receives reports from consultants
- Significant incidents reported to Audit Committee → Board
- Management presents assessment to Audit Committee annually

This is a governance-chain paragraph spanning board → committee → officer → program. Per Rule 2, the PURPOSE is describing the oversight structure — how the board exercises oversight, how information flows upward. → Board Governance.

Now I'm checking the specificity of the entities mentioned. The Principal Accounting Officer is a generic accounting role, not a cybersecurity-specific title like CISO or CIO, and the cybersecurity consultants are unnamed. There are no named frameworks or specific facts from the IS list—just generic governance language around board composition, committee structure, and reporting cadence.


reasoning: This paragraph describes a governance/oversight structure spanning board and management. The board's oversight role is explicitly mentioned, and the purpose is describing the governance structure (who oversees what), making it Board Governance per the governance-chain rule. However, CFO is on the ✗ NOT list as generic C-suite — but here CFO is specifically identified as directing cybersecurity governance, which is unusual (typically CISO/CIO). On reflection, CFO is explicitly listed as generic C-suite (✗ NOT list), so no firm-specific facts remain after validation. However, the paragraph names a specific non-standard cybersecurity leadership arrangement (CFO directing cyber governance rather than a dedicated cybersecurity role), which is arguably firm-specific organizational structure. Given the borderline nature, I'll keep Firm-Specific since the CFO leading cybersecurity governance is an unusual, company-specific arrangement — though CFO alone is on the NOT list. Revising: after strict validation, CFO is on the NOT list, 'the Board' is generic, no named standards. This should be Generic Boilerplate.

fact: CFO directs security governance


reasoning: Applying the person-removal test: removing 'Our Director of Information Technology' and the service provider attribution, the paragraph still coherently describes the company's risk management processes (monitoring, threat intelligence, scanning, risk assessment). The paragraph is about the function, not the person. 'Director of Information Technology' is a generic IT title on the ✗ NOT list, 'managed information technology service provider' and 'third party service providers' are unnamed entities, and no frameworks, dates, tools, or numbers are present — leaving no specific facts after validation.

thinking:
Let me analyze this paragraph carefully.

**Content Category:**

Step 1 — Subject test: "Our Director of Information Technology, assisted by our managed information technology service provider and other third party service providers" is the subject — a person/role. Continue to Step 2.

Step 2 — Person-removal test: Remove "Our Director of Information Technology, assisted by our managed information technology service provider and other third party service providers" → "leads the Company's cybersecurity risk management processes. This group works to identify and assess risks from cybersecurity threats by monitoring and evaluating our threat environment and the Company's risk profile using various methods..." — Yes, this is a coherent process description.

So this falls under **Risk Management Process**. The paragraph outlines the program's core activities: identifying and assessing risks, monitoring threats, leveraging tools, subscribing to threat intelligence reports, and running security scans.

**Specificity:**

Checking the details here — "Director of Information Technology" is a generic IT title that doesn't match the cybersecurity-specific roles on the list (CISO, CTO, CIO, VP of IT/Security), so it doesn't count. The managed service provider and third-party vendors are unnamed, and there are no frameworks, dates, numbers, or specific tool names mentioned.

After going through everything, there are no concrete facts or named standards that would add specificity to this content.


reasoning: The paragraph briefly mentions the Board's involvement in risk oversight but spends the majority of its text describing the company's cybersecurity risk management program — its integration into ERM, framework alignment (NIST, ISO), and cross-functional approach focused on confidentiality, security, and availability. The dominant communicative purpose is describing internal processes. Named frameworks (NIST, ISO) trigger Sector-Adapted, but no firm-specific facts from the IS list are present (Board is generic, no cybersecurity-specific roles, no dates, no numbers).

thinking:
Let me analyze this paragraph.

Content: Board oversight mentioned briefly, then shifts to describing the risk management program - framework adoption (NIST, ISO), cross-functional approach, confidentiality/security/availability goals.

Category: The paragraph starts with a generic trust statement, briefly mentions Board oversight, then spends most of its text describing the risk management program's integration, frameworks, and approach. The dominant content is RMP.

Specificity: Names NIST and ISO frameworks → Sector-Adapted. No firm-specific facts from the IS list (Board is generic, no CISO/CTO, no specific committees, no dates, no numbers).

fact: National Institute of Standards and Technology (NIST)

type: framework

fact: International Organization for Standardization (ISO)


reasoning: This is a governance-chain paragraph describing the oversight structure from Board → Audit Committee → IT Director → CFO → Board reporting. The primary purpose is describing how cybersecurity oversight flows through the organization, making it Board Governance per Rule 2. For specificity, 'IT Director' maps to generic IT leadership ('Director of IT') on the NOT list, 'Audit Committee' and 'CFO' are generic governance/C-suite, 'extensive experience' is vague, and 'regular updates' is a generic cadence — no IS-list facts remain after validation.

thinking:
This is a governance-chain paragraph spanning board → committee → officer → program. Let me apply the rules.

Category: This paragraph describes the oversight structure - Board oversees, Audit Committee has authority, IT Director leads, reports to CFO, CFO updates Board. The PURPOSE is describing the governance/oversight structure and how information flows. Per Rule 2, governance-chain paragraphs are Board Governance.

But wait - there's "IT Director who has extensive experience in information systems and cybersecurity" - this is a qualification mention. Let me check if this is dominant. No, it's brief. The paragraph's purpose is describing the oversight chain.

→ Board Governance

Now I'm checking the specificity of the roles and language used. The IT Director title is generic rather than cybersecurity-specific, and the same goes for Audit Committee, Board, and CFO - all generic governance terms. The descriptions like "extensive experience" and "regular updates" are vague without concrete details, so this paragraph lacks the specificity needed to demonstrate actual cybersecurity governance depth.


reasoning: The paragraph describes how the company monitors and manages cybersecurity incidents — prevention, detection, mitigation, remediation — through service provider notifications and Investment Manager ISP personnel. Applying the MR vs RMP decision chain: 'Management' is the generic subject (Step 1, not decisive), and removing it leaves a coherent process description about monitoring and incident handling (Step 2 → RMP). No cybersecurity-specific roles, named frameworks, specific dates, or firm-specific facts from the IS list are present.

thinking:
Let me analyze this paragraph.

Content: Management monitors cybersecurity incidents through notifications from service providers and communications with ISP personnel of the Investment Manager.

Category: This describes management's role in monitoring cybersecurity. The subject is "Management" (generic). It describes how management stays informed - through service provider notifications and ISP personnel communications.

This is about management's monitoring function. Let me apply the MR vs RMP decision chain:
- Step 1: "Management" is the subject - generic, not a cybersecurity-specific role. Continue to Step 2.
- Step 2: Remove "Management" - "is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents...

The rest describes how the company receives incident notifications and relies on communications with ISP personnel - this is fundamentally about the monitoring and information flow process rather than a specific management role. There's no named individual, no qualifications, no credentials mentioned. This reads as a Risk Management Process that outlines the structure for how cybersecurity incidents are monitored and communicated.

Looking at the specificity: there are no named frameworks, no specific facts from the IS list, and "Management" is too generic. "Service providers" and "ISP personnel of the Investment Manager" are vague - while "Investment Manager" is somewhat specific to their fund structure, it's still a generic term in that context. No cybersecurity-specific titles, no named committees, no dates, no tools. This is Generic Boilerplate.


reasoning: The paragraph opens by establishing WHO leads the cybersecurity program — the SVP of IT with 20+ years of experience — and then describes the team's qualifications (relevant experience, similar positions at large tech companies). While sentences 3-5 describe team activities (prevention, detection, reporting), the framing purpose is identifying the management structure and the people's credentials. Applying Step 3 of the MR vs RMP chain: the paragraph includes years of experience and team background, which are MR-specific content. Specificity is Firm-Specific: the SVP of IT role is a cybersecurity-adjacent title on the IS list, and '20 years' is one QV-eligible fact, but only one hard verifiable fact prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the SVP of IT with 20 years of experience, then describes what the team does (oversees information security program, manages cybersecurity risks, supervises internal and external personnel, prevents/detects/mitigates/remediates risks through various means, provides reports to senior management).

Category analysis:
- Step 1 (Subject test): The grammatical subject starts as "Our Senior Vice President of Information Technology" then shifts to "the team." Mixed.

- Step 2 (Person-removal test): The opening focuses on who these people are—the SVP's background and the team members' qualifications—before transitioning into what they actually do. So there's a structural shift from describing personnel to describing their functions.

- Step 3: The paragraph does contain material-relevant details in those first two sentences—the 20 years of experience and the team's prior roles at large tech companies. But the real substance is in sentences 3-5, which lay out the actual work: overseeing the cybersecurity program, implementing prevention and detection methods, managing risk mitigation, and reporting findings. If I strip away the credentials and titles, the core description of their responsibilities remains intact and coherent. That suggests this leans toward RMP rather than MR.

But I'm second-guessing myself because the opening really does emphasize *who* is in charge and *what they've done*. The paragraph's structure is: establish the leader and their background, then describe what the team does. The person details aren't just window dressing—they're foundational to the message. I think the intent is to establish management structure and credibility, which points toward Management Role. The process description serves to show what that management team is responsible for, not to be the main point. The SVP of Information Technology title is close enough to the listed "VP of IT/Security" that I'll count it as a cybersecurity-adjacent role. The "over 20 years of experience" qualifies as a QV-eligible fact, but that's just one, so it doesn't meet the QV threshold. Now I'm identifying the firm-specific facts in the paragraph.

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


reasoning: The paragraph describes WHO is responsible for cybersecurity management — executive officers, a third-party consultant, and their Security Operations Center Manager — along with the SOC Manager's qualifications ('variety of technical certifications,' 'extensive background in IT infrastructure, risk mitigation, and incident response planning'). Applying the three-step MR vs RMP test: Step 2 (person-removal) leaves little coherent process description, and Step 3 confirms qualifications content. However, specificity is Generic Boilerplate because no facts from the IS list are present: the consultant and SOC Manager are unnamed, certifications are unspecified ('a variety of'), experience is vague ('extensive background'), and no cybersecurity-specific titles from the IS list (CISO, CTO, CIO, etc.) appear.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes executive officers' responsibility for risk management, a third-party consultant leading cybersecurity strategy, and the consultant's Security Operations Center Manager advisor with certifications and background.

**Content Category:**

Applying the MR vs RMP three-step chain:

Step 1 — Subject test: "Our executive officers" and "a third-party consultant" are the subjects. Person/role as subject → signal, continue to Step 2.

Step 2 — Person-removal test: Remove all roles, titles, qualifications. What remains? "...responsible for day-to-day management of material risks...

Now looking at what's left after removing the roles and titles—the consultant oversees cybersecurity strategy and works across departments to assess risks, while their advisor holds various technical certifications and has deep experience in IT infrastructure, risk mitigation, and incident response. Step 3 confirms this is about qualifications since the certifications and background experience are explicitly highlighted as credential descriptors. Security Operations Center Manager isn't on the specific IS list, so it's borderline whether it counts as a named cybersecurity-specific title. The real issue is that everything here is unnamed — the consultant, the manager, the certifications — which pushes this toward generic boilerplate rather than specific evidence of governance.


reasoning: The paragraph primarily describes the company's cybersecurity program — assessments, controls, threat intelligence sources, and managed security services. The CISO, CTO, and CIO are mentioned as attributions for who oversees what, but no personal qualifications, credentials, or career history are provided. Applying the person-removal test: removing the role mentions leaves a coherent process description. Three cybersecurity-specific titles (CISO, CTO, CIO) qualify as IS-list facts pushing to Firm-Specific, but named roles do not count toward the QV threshold, and there are no dates, dollar amounts, headcounts, or named firms/tools to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph covers multiple topics - it describes the cybersecurity program, risk assessment processes, and mentions CISO/CTO/CIO roles. Let me apply the decision chain.

Step 1 - Subject test: The subjects are "We" (the company) and then named roles (CISO, CTO, CIO). The primary content describes what the program does.

Step 2 - Person-removal test: If I remove "Our CISO is responsible for overseeing and implementing our cybersecurity program and enforcing our cybersecurity policy" and the CTO/CIO mentions, the remaining text still describes a coherent cybersecurity program - assessments, controls, threat intelligence, managed security service provider. So the process stands on its own.

Step 3 - Qualifications tiebreaker: The named individuals have no years of experience, certifications, education, or career history mentioned, so this falls under Risk Management Process where the roles serve as attribution rather than the main focus. The CISO, CTO, and CIO are all cybersecurity-specific titles that qualify as IS facts, but the Managed Security Service Provider is unnamed and therefore not specific. The phrase "adversely and materially affect" uses "material" as a contextual adjective in a risk assessment, not as a materiality assessment itself.

For the QV check, the named roles don't count toward the threshold since there are no dates, dollar amounts, headcounts, named firms, or named tools present. However, having at least one IS fact like CISO, CTO, or CIO is enough to classify this as Firm-Specific.

fact: Chief Information Security Officer (CISO)

fact: Chief Technology Officer (CTO)

fact: Chief Information Officer (CIO)


reasoning: This is a governance-chain paragraph whose primary purpose is describing how oversight flows from the information security program through a named committee up to the Board of Directors. The Board is the ultimate recipient of incident reports, risk summaries, program updates, and educational sessions. Although the paragraph opens with a program description and mentions the CIO, the dominant communicative purpose is the oversight structure — how information reaches the Board and what the Board receives. The named non-generic committee ('Information Security Governance Committee') and the CIO title are firm-specific facts, but neither qualifies as QV-eligible, yielding Firm-Specific.

thinking:
Let me analyze this paragraph carefully.

This is a complex, multi-topic paragraph. Let me break down what it covers:

1. "We have a formal information security program" - RMP
2. "governed by a committee comprising members of senior management, including our CIO" - mentions CIO and a governance committee
3. "which meets regularly and reports to the Board of Directors at least annually" - governance chain
4. The committee is named: "Information Security Governance Committee" - this is a named non-generic committee
5. The committee oversees communications with the Board regarding material incidents, provides risk summaries, updates on the program

6. The Board also receives cybersecurity educational sessions from external advisors

The core purpose here is describing the governance structure—how oversight flows from the program through the committee up to the Board, which serves as the ultimate recipient of reports, briefings, and educational content. This is fundamentally about the oversight chain.

Per Rule 2, governance-chain paragraphs are Board Governance because the purpose is describing the oversight structure. The specific facts include a CIO (cybersecurity-specific title) and a named committee called "Information Security Governance Committee."

Since there are no quantifiable facts like dates, dollar amounts, headcounts, or certifications, this doesn't meet the QV threshold. But with at least one IS-specific fact present, this qualifies as Firm-Specific.


reasoning: The paragraph opens with an explicit backward-looking materiality assessment ('have not materially affected') and a forward-looking assessment using the SEC qualifier ('not reasonably likely to materially affect... business strategy, financial condition or results of operations'), squarely triggering Rule 6 for Strategy Integration. The remainder is generic risk warning and a cross-reference to Item 1A. No firm-specific facts appear — all language is boilerplate materiality disclosure.

thinking: Materiality assessment paragraph.


reasoning: The paragraph opens with the Board's oversight responsibility and describes the quarterly reporting structure from CIO to Board (including scorecard content), making the governance chain the primary frame. While the CIO's qualifications and team (25 years, Director of IT Security, vCISO) occupy the latter half, per the codebook governance-chain paragraphs are Board Governance unless qualifications are dominant — here the oversight structure is the opening frame. Multiple IS-list facts (CIO, Director of IT Security, vCISO, 25 years) make it Firm-Specific, but only one QV-eligible fact (25 years of experience), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph starts with board oversight, then describes the CIO's reporting to the board (quarterly briefings with specific content), then the CIO's reporting line, then the CIO's qualifications and team.

It spans Board Governance and Management Role. Let me apply the decision rules.

The paragraph opens with board oversight, describes the reporting structure (CIO reports to board quarterly), then shifts to describing who the CIO is (experience, reporting lines, support team).

Purpose test: The paragraph describes the governance chain - board oversight → CIO reports to board → CIO's reporting line to CEO → CIO's qualifications and team. It's a mix.

Looking at the structure more closely, the first two sentences establish the board's oversight role and the CIO's quarterly reporting cadence, while the remaining sentences focus on the CIO's background—25 years of experience, direct reporting to the CEO, and the team supporting them. This feels like it's primarily about Board Governance since the governance chain is the framing device, even though there's meaningful detail about the CIO as an individual. The codebook is clear that governance-chain paragraphs default to Board Governance unless the officer's personal qualifications dominate the content, and here they're roughly balanced—the opening frame and quarterly reporting structure anchor this as governance oversight. Looking at the specificity markers, I've got the CIO title and Director of IT Security as named roles, plus "over 25 years" as a specific number that counts toward QV eligibility, but that's just one quantifiable fact among the governance details, so it doesn't shift the classification.

fact: over 25 years of experience in IT Operations

fact: Director of IT Security

fact: virtual Chief Information Security Officer (vCISO) service


reasoning: The paragraph opens with a negative materiality assertion ('not aware of having experienced any prior material data breaches... or cyber security incidents'), which is the company stating a conclusion about materiality per Rule 6. The remainder is generic risk speculation ('could result in...') and a cross-reference to Item 1A, which do not override the materiality assessment. No firm-specific facts, named standards, or verifiable details are present.

thinking:
Let me analyze this paragraph.

The paragraph contains:
1. "not aware of having experienced any prior material data breaches, regulatory non-compliance incidents, or cyber security incidents" - This is a negative materiality assertion
2. Generic risk warnings about future impacts
3. Cross-reference to Item 1A

The key question: Is "we are not aware of having experienced any prior material data breaches... or cyber security incidents" a materiality assessment?

Per the codebook, negative assertions like "we have not experienced material incidents" → Strategy Integration. This is the company stating a conclusion about whether cybersecurity has affected them.

But then the rest is generic risk warning ("could result in...") and a cross-reference.

The opening statement is the materiality assessment here. That negative assertion about not experiencing material cybersecurity incidents maps to Strategy Integration under Rule 6, since the company's framing it as a materiality conclusion. The language is generic boilerplate with no named standards or firm-specific details from the IS list, so that's Specificity 1.


reasoning: The paragraph is framed around the CISO — their reporting line (to EVP of Cloud + AI), experience, and prior career history (CTO role, senior leadership at multiple organizations). The CGC is introduced explicitly 'to support the CISO,' making the CISO the focal point. While the CGC responsibilities (risk assessment, NIST CSF alignment, compliance) touch on process, the dominant communicative purpose is describing WHO leads cybersecurity and the organizational structure around that person. Multiple firm-specific facts (CISO, Deputy CISOs, named CGC with abbreviation, reporting to EVP Cloud + AI) but no QV-eligible hard facts (no specific dates, dollar amounts, headcounts, named third-party firms, or certifications).

thinking:
Let me analyze this paragraph carefully.

This is a complex paragraph that spans multiple categories. Let me work through it.

The paragraph covers:
1. CISO's reporting line and experience (Management Role)
2. CISO's prior career history (Management Role)
3. Cybersecurity Governance Council (CGC) - named internal program with unique identifier
4. Deputy CISOs comprising the CGC (Management Role / Board Governance)
5. CGC responsibilities - risk assessment, NIST CSF alignment, compliance (Risk Management Process)
6. Security training for employees (Risk Management Process)

Now I'm applying the decision rules to separate the content. The grammatical subjects shift across the paragraph—starting with the CISO as a person, then moving to the CGC and its governance responsibilities. When I remove the CISO's background and experience, the remaining content about the CGC's structure and risk management functions still holds together coherently. So this is really two distinct sections: the first part focuses on the CISO as an individual with their reporting line and history, while the second part pivots to the CGC's organizational role and responsibilities.

Looking at the breakdown sentence by sentence, the first three sentences are clearly about the CISO's management role—their reporting structure, experience level, and prior positions. The remaining sentences shift to governance and risk management processes, describing the CGC's composition and its specific responsibilities around risk assessment, NIST CSF alignment, and training. The second half is actually longer and more substantive, so the dominant category here is organizational structure and risk management processes rather than personal background. go with **Management Role** as the dominant category since the paragraph centers on the CISO as the key figure, with the CGC positioned as supporting infrastructure. The person-specific details—experience, prior roles, and reporting structure—carry substantial weight here. Looking at what qualifies as specific and verifiable: the CISO title, reporting line to the EVP of Cloud + AI, prior CTO background, the named CGC program, and Deputy CISO positions are all firm-specific and cybersecurity-focused. The NIST CSF reference is more sector-level. I don't see any concrete dates, financial figures, headcounts, percentages, third-party vendors, products, or certifications that would push this into different territory.

So this lands as Firm-Specific (3) with no QV eligibility.

fact: CISO leads cybersecurity strategy, engineering, and operations

fact: CISO reports to EVP of Cloud + AI

fact: CISO served in a prior Chief Technology Officer role

fact: Cybersecurity Governance Council ("CGC")

fact: CGC comprised of Deputy CISOs

fact: NIST CSF


reasoning: The paragraph contains an explicit backward-looking materiality assessment ('have not identified any risks from cybersecurity threats that have materially affected the Company, our business strategy, our results of operations or our financial condition'), which triggers Strategy Integration per Rule 6. The cross-reference to Item 1A and generic investment/threat language are subordinate to this materiality conclusion. No firm-specific facts remain after filtering — generic governance language, unnamed threats, and boilerplate phrasing throughout.


reasoning: The paragraph is a cross-reference directing the reader to the Risk Factors section. It describes what that other section covers ('we describe whether and how risks... have materially affected') rather than making its own materiality conclusion. Per the codebook: 'For risks that may materially affect us, see Item 1A' = N/O because the paragraph's purpose is pointing elsewhere, not stating the company's own assessment.

thinking:
This paragraph contains a cross-reference to Risk Factors that uses materiality language. Let me apply the codebook rules.

The key distinction from the codebook: "For risks that may materially affect us, see Item 1A" = N/O (pointing elsewhere, not concluding). vs "Risks have not materially affected us. See Item 1A" = SI (the first sentence IS an assessment).

This paragraph says "In our Risk Factors, we describe whether and how risks... have materially affected or are reasonably likely to materially affect us." This is pointing the reader to another section — it's describing what the Risk Factors section covers, not making its own materiality conclusion.

So this codes as None/Other.


reasoning: The paragraph is generic risk-acknowledgment language — AFG 'recognizes the importance' of managing cyber risks, then lists common threat types (cyberattacks, ransomware, phishing) and generic consequences (disruptions, theft, expenses). 'Material' is used as an adjective ('material risks'), not as a materiality assessment connecting cybersecurity to business outcomes. There is no description of any process, program, governance structure, or incident — it could appear in virtually any company's filing unchanged.

thinking:
Let me analyze this paragraph.

Content: Generic risk acknowledgment language. Says AFG "recognizes the importance" of managing cyber risks, then describes generic threats (cyberattacks, ransomware, phishing, hacking) and generic consequences (disruptions, theft, reputational harm, expenses).

Category: No specific processes, no board oversight, no management roles, no incidents, no third-party risk. "Material risks associated with cybersecurity threats" uses "material" as an adjective, not a materiality assessment. No materiality conclusion. This is generic risk language. → None/Other

This is pure boilerplate with no firm-specific details or named frameworks—just standard language you'd find in any company's disclosure.


reasoning: The paragraph contains a backward-looking materiality assessment ('have not been materially impacted... with respect to our business strategy, results of operations or financial condition'), which is a conclusion about cybersecurity's impact on business outcomes per Rule 6. The cross-reference to Item 1A and the forward-looking caveat are secondary. No firm-specific facts are present.


reasoning: This is a broad overview paragraph describing the company's comprehensive approach to cybersecurity risk management. While it briefly mentions Board and Audit Committee oversight, the primary communicative purpose is introducing the overall program — policies, processes, the named Security Steering Group (SSG) with its specific composition, and resource commitment. Applying the person-removal test, removing the named roles still leaves a coherent description of the program and its structure, confirming RMP over Management Role. The SSG with its unique abbreviation is a named internal program with a distinguishing identifier, and the CISO is a cybersecurity-specific title, both qualifying as firm-specific facts. However, none of these are QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools), so specificity stays at Firm-Specific.

thinking:
Let me analyze this paragraph from Pegasystems' 10-K filing.

This is a broad overview paragraph spanning multiple topics. Let me identify the primary purpose.

Content: Opens with generic importance statement, mentions Board and Audit Committee oversight, mentions management involvement, mentions policies/processes, names the Security Steering Group (SSG) with specific members (CISO, Chief Product Officer, VP of Cloud Technology), mentions resource investment, ends with a disclaimer.

This spans Board Governance, Risk Management Process, and Management Role. The dominant purpose seems to be an overview of the company's cybersecurity approach - it's describing the overall structure and program.

The paragraph is really about how the company structures its cybersecurity risk management across multiple levels - from Board oversight down through the SSG and management processes. While governance elements are present, the core message is the comprehensive program itself and how different parts of the organization contribute to managing cybersecurity risks.

Looking at what's actually specific to this company: the Security Steering Group with its abbreviation is a named internal program, and the CISO is a firm-specific role. Neither of these count toward quantifiable verification though, since they're just named entities rather than hard facts I could verify independently.

fact: Security Steering Group ("SSG")

fact: CISO

fact: Chief Product Officer as SSG member

fact: Vice President of Cloud Technology as SSG member


reasoning: The paragraph describes a management-level committee ('Information Security committee') responsible for cybersecurity oversight, its composition (CDIO, CFO, CAO/GC), and the CISO's reporting relationship to it. Per the codebook, 'management committees responsible for cybersecurity' is a key marker for Management Role. The primary content is about the organizational structure and who comprises the committee, not about processes/tools (RMP) or board-level oversight (BG). Specificity is Firm-Specific due to the named non-generic committee and cybersecurity-specific roles (CDIO, CISO); however, these named roles/committees do not count toward QV thresholds.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a management-level committee (Information Security committee) that oversees the cybersecurity program. It names its composition and describes what it does.

Category analysis:
- "Information Security committee" - this is a named non-generic committee
- The committee consists of senior management including CDIO, CFO, CAO/GC
- The committee reviews updates quarterly, approves strategy proposed by CISO

Is this Board Governance or Management Role or Risk Management Process?

This is about a management committee, not a board committee. The "Information Security committee" consists of senior management. This describes oversight structure at the management level.

The key distinction here is that this is a management committee rather than a board committee, and the paragraph focuses on the organizational structure and reporting relationships—specifically how the CISO proposes strategy to this management-level group for approval and oversight.

For the specificity assessment, the named committee and cybersecurity-specific titles like CISO and CDIO count as firm-specific facts, while the generic C-suite positions don't. There are no quantifiable metrics, dates, or external references, so this doesn't qualify as quantifiable value.

fact: Information Security committee

fact: CDIO (Chief Digital and Information Officer)


reasoning: This is a continuation of an enumerated list describing topics that a board or committee oversees (personnel qualifications, cybersecurity strategy, resource allocation). The purpose is describing the scope of governance oversight. No named roles, frameworks, dates, or firm-specific facts are present — entirely generic oversight language.

thinking:
Classifying this paragraph from Mannatech's 10-K Item 1C.

This appears to be a list of items (g and h) that some oversight body reviews. It describes topics covered in oversight - personnel qualifications, strategy, priorities, resource allocation. This is likely part of a longer enumerated list describing what the board or a committee oversees.

Category: This describes oversight topics - what a board/committee reviews. The items listed are about oversight scope (personnel capabilities, strategy, resource allocation). This is Board Governance - describing the scope of board/committee oversight.

Specificity: No named frameworks, no specific facts from the IS list. "Audit Committee" isn't mentioned, no cybersecurity-specific titles, no dates, no named tools.

The language here is generic boilerplate - standard governance disclosure without substantive detail.


reasoning: The paragraph's first sentence describes the company's internal risk assessment and safeguard process (evaluate, re-design, implement, monitor), which is the primary communicative purpose. The second sentence attributes this process to two roles with their experience levels. Applying the person-removal test (Step 2): removing all role/qualification content leaves a coherent process description → RMP. The roles themselves (Manager of IT ≈ 'IT Manager' on NOT list; COO on NOT list) do not trigger Firm-Specific, but the two specific experience durations ('over 25 years', 'over 15 years') are QV-eligible hard facts, meeting the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two parts:
1. First sentence: describes the risk assessment process (evaluate, re-design, implement, maintain safeguards, address gaps, monitor effectiveness) — this is clearly process description.
2. Second sentence: identifies two people (Manager of IT, COO) with their experience levels who manage the process.

Category decision - MR vs RMP three-step chain:

Step 1 — Subject test: First sentence has "we" as subject (process). Second sentence has named roles as subjects. Mixed → continue to Step 2.

Step 2 — Person-removal test: Remove "Our Manager of Information Technology, who has over 25 years of information technology experience, and our Chief Operating Officer, who has over 15 years of information technology management experience, manage the risk assessment and mitigation process." The first sentence still stands as a coherent process description.

The second sentence is fundamentally about the people themselves. The paragraph splits between process in the first part and personnel qualifications in the second. The first sentence is substantial and describes what the company does, while the second attributes that process to specific roles with their years of experience listed. Looking at dominance, the process content is more substantial, but the qualifications are explicitly stated, which points toward MR.

Let me test this differently. If I remove the second sentence, the first still stands as a complete process description. But the codebook is clear that MR requires content about who the person is and what qualifies them—and that's exactly what the second sentence provides with those experience numbers. The paragraph genuinely straddles both categories, but the qualifications tiebreaker in Step 3 suggests MR is the right call. I'm working through the three-step chain systematically. Step 2 asks if the paragraph remains coherent after removing all person-specific information—and it does, since the core content describes the risk assessment and mitigation process itself. That gives me a YES result pointing to RMP. Step 3 only applies if the answer is borderline, which this isn't according to the strict reading. The paragraph's primary purpose is explaining the process, even though the second sentence focuses heavily on the people managing it. I'll classify this as RMP while acknowledging the substantial person-related detail.

Now I'm checking the specificity of the roles mentioned. "Manager of Information Technology" doesn't appear on the cybersecurity-specific list—it's more generic IT leadership, which falls into the NOT category. "Chief Operating Officer" is next on my list to verify.

The experience metrics are what stand out here: "over 25 years" and "over 15 years" are specific numbers that qualify as quantified-verifiable facts. These count toward the QV-eligible criteria, even though the role titles themselves don't meet the specificity threshold. The specific years of experience are still countable facts even though they're tied to roles on the exclusion list, so that's two QV-eligible data points. Looking back at the comparison cases, my paragraph does emphasize process more than pure attribution—the people details serve as supporting qualifications rather than the main point. I'm confident this is RMP with Quantified-Verifiable.

fact: over 25 years of information technology experience (Manager of IT)

fact: over 15 years of information technology management experience (COO)


reasoning: The paragraph describes the governance/oversight structure for cybersecurity risk — the ERM program, the ERC management committee reporting to Co-CEOs, the Enterprise Risk Officer's coordination with the CISO, and a board Director's cybersecurity credentials. The purpose is showing how cybersecurity risk oversight is structured across the organization, culminating in board-level expertise (Ms. Murray), making this Board Governance. Two QV-eligible hard facts: a named certification (CERT Certificate in Cybersecurity Oversight) and a named university in credential context (Carnegie Mellon University).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes:
1. AFG's ERM program design
2. The Enterprise Risk Committee ("ERC") composition - Chief Administrative Officer and Chief Human Resources Officer, CFO, General Counsel, and Great American Insurance Company's President
3. ERC oversight of ERM process
4. ERC members report to Co-CEOs
5. Enterprise Risk Officer oversees day-to-day ERM, meets with CISO
6. Cybersecurity as significant risk under ERM
7. Ms. Murray, independent Director, completed NACD Cyber-Risk Oversight Program and received CERT Certificate in Cybersecurity Oversight from Carnegie Mellon University

8. The governance structure shows how ERM operates at both the management level through the ERC and at the board level through Ms. Murray's cybersecurity expertise, with clear reporting lines to Co-CEOs and coordination between the Enterprise Risk Officer and CISO on cybersecurity matters. chain from ERM program → ERC → Co-CEOs, plus board member expertise.

Actually, this is tricky. The ERC members are management (CAO, CFO, General Counsel, subsidiary President) - not board members. They report to Co-CEOs. The Enterprise Risk Officer is management. The CISO is mentioned incidentally.

But Ms. Murray is a board Director with cybersecurity credentials.

The paragraph is really about the oversight STRUCTURE - how risk is managed from ERM through committees to leadership, plus board expertise. This feels like Board Governance because the overall purpose is describing the oversight structure, and it culminates with board-level cybersecurity expertise.

Wait - the ERC is a management committee, not a board committee. So much of this is about management-level oversight. But the purpose test: the paragraph describes the governance chain structure. The Rule 2 guidance says governance-chain paragraphs (board → committee → officer → program) are almost always Board Governance.

Actually, this goes program → management committee → Co-CEOs, then separately board member expertise. It's a mixed paragraph. The dominant theme is the oversight structure overall. I think Board Governance is appropriate - the paragraph describes the oversight ecosystem including both management oversight structure AND board-level expertise (Ms. Murray). The purpose is showing how cybersecurity risk is governed.

For specificity, I'm noting the named committee (Enterprise Risk Committee/ERC), the specific team composition (CAO, CFO, General Counsel, subsidiary President), the named role (Enterprise Risk Officer), the cybersecurity-specific title (CISO), and the named individual (Ms. Murray) - all of these qualify as list items.

Now looking at the next part: the NACD Cyber-Risk Oversight Program is a named program, the CERT Certificate in Cybersecurity Oversight is a named certification, and Carnegie Mellon University is a named university in credential context. That's two QV-eligible facts right there - the named certification and the named university. So this section qualifies as Quantified-Verifiable.

fact: Enterprise Risk Committee ("ERC")

fact: ERC composition: Chief Administrative Officer and Chief Human Resources Officer, CFO, General Counsel, and Great American Insurance Company's President

fact: Enterprise Risk Officer role

fact: Ms. Murray, named independent Director

fact: Carnegie Mellon University (Software Engineering Institute)

fact: NACD Cyber-Risk Oversight Program