reasoning: This is a governance-chain paragraph describing how the Board receives updates, management's role in cybersecurity risk oversight, and the reporting flow back to the Audit Committee. The purpose is describing the oversight structure (who reports to whom, how information flows upward), making it Board Governance per the purpose test. No IS-list facts are present: 'Board of Directors,' 'Audit Committee,' 'CEO,' 'management,' and 'periodic/regularly' are all on the NOT list. CEO is generic C-suite, not a cybersecurity-specific title.

thinking:
Let me analyze this paragraph.

The paragraph describes a governance chain: Board receives updates → Management identifies/assesses risks → CEO directs cybersecurity programs → Management updates Audit Committee.

Category analysis:
- Board receives periodic updates from management and Audit Committee
- Management's responsibilities for cybersecurity risk
- CEO directs cybersecurity programs
- Management updates Audit Committee on programs

This is a governance-chain paragraph spanning board → management → program. The PURPOSE is describing the oversight structure - how information flows, who is responsible for what, how the board/committee gets informed.

Per Rule 2, governance-chain paragraphs are almost always Board Governance.

The core focus here is the oversight and reporting structure itself - the flow of information and accountability between the board, management, and audit committee. While management's specific cybersecurity duties are mentioned, they're secondary to the main point about how governance operates. The specificity check confirms this: all the entities and cadences are generic without named frameworks or particular details. This is clearly Board Governance.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the company's cybersecurity program — its governance policy, protective measures (encryption, DLP, authentication, access control, anti-malware), vulnerability management, monitoring processes, and framework alignment. The CTO and Head of Technology Infrastructure are mentioned as attribution for who manages the program; applying the person-removal test, the substantive content about processes and controls stands on its own without the role references. Specificity is Firm-Specific: the named ISG Policy (unique identifier) and cybersecurity-specific roles (CTO, Head of Technology Infrastructure) are IS-list facts, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named third-party firms/tools) reach the two-fact threshold.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph carefully.

This is a dense paragraph covering multiple topics. Let me identify the primary communicative purpose.

Content:
1. Named internal program: "information security governance policy (the 'ISG Policy')" - named with unique identifier
2. Management roles: CTO and Head of Technology Infrastructure ("Blue Owl IT Management") reporting to COO
3. Process descriptions: monitoring, alert response, vulnerability management, encryption, DLP, authentication, access control, anti-virus, etc.
4. Framework: NIST CSF

The paragraph's primary content is about the cybersecurity program - what it does, what it protects against, what tools/processes it uses.

Now I'm testing whether the management attribution is essential to the core message. If I remove the references to the CTO and Head of Technology Infrastructure, the description of the program's processes and controls still stands on its own. So the focus is really on the program's design and operational controls, not on who oversees it. The CTO title does appear on the information security list, but it's mentioned here as attribution rather than as the main subject. The paragraph is fundamentally describing the program's architecture and security measures.

Looking at what qualifies as verifiable facts: I've got the ISG Policy as a named internal program, the CTO and Head of Technology Infrastructure as cybersecurity-specific titles, and NIST as a named framework. But none of these reach the threshold for quantifiable verification—no dates, financial figures, headcounts, third-party vendors, or certifications that would push this into that category. The COO is just generic executive hierarchy, not information security-specific. With multiple information security facts but nothing that meets the quantifiable verification standard, this lands as Firm-Specific.

fact: Chief Technology Officer

fact: Head of Technology Infrastructure

fact: NIST Cybersecurity Framework

type: framework


content_category: None/Other

reasoning: This paragraph is generic risk warning language — 'could have a material adverse effect' is boilerplate speculation present in virtually every 10-K, not a materiality assessment. The company (a SPAC based on its name) describes no cybersecurity program, governance structure, or processes; it only acknowledges that cybersecurity threats exist and could be harmful. No substantive disclosure content is present.

thinking:
Let me analyze this paragraph.

Company is OceanTech Acquisitions I Corp - sounds like a SPAC.

Content: Generic risk language about cybersecurity threats. "Could have a material adverse effect" - this is generic risk warning, NOT a materiality assessment. No actual program described, no governance, no processes.

This is boilerplate risk language. "Could have a material adverse effect" is speculation, not an assessment per the codebook.

Category: None/Other - this is generic risk warning language with no substantive disclosure. No program, no governance structure, no processes described.

The language lacks any specificity—no named entities, frameworks, roles, or dates to anchor it in reality.


category_confidence: medium

reasoning: The first two sentences name the ISO and note 'over a decade of experience,' but the bulk of the paragraph describes program activities — simulations, tabletop exercises, annual employee training, role-based specialized training. Applying the person-removal test: deleting the ISO references leaves a coherent process description, so the paragraph is fundamentally about the program, not the person. The ISO title (cybersecurity-specific per the IS list) pushes specificity to Firm-Specific, but 'over a decade' is too vague to count as a hard verifiable fact, and no second QV-eligible fact is present.

thinking:
Let me analyze this paragraph carefully.

Category: The paragraph starts with the Information Security Officer's responsibility and experience, then shifts to describing the program (simulations, tabletop exercises, training). Let me apply the three-step decision chain for MR vs RMP.

Step 1 — Subject test: "The Corporation's Information Security Officer" is the subject of the first two sentences. Person as subject → signal, continue to Step 2.

Step 2 — Person-removal test: Remove "The Corporation's Information Security Officer is responsible for... Our Information Security Officer has over a decade of experience leading cyber security oversight, and others on our IT security team have cybersecurity experience or certifications." The remaining text: "We view cybersecurity as a shared responsibility, and we periodically perform simulations and tabletop exercises at a management level and incorporate external resources and advisors as needed.

All employees are required to complete cybersecurity trainings on an annual basis..." — yes, this is still a coherent cybersecurity disclosure about processes. But the first two sentences ARE about the person.

This is borderline. The paragraph has two parts: (1) ISO identification + experience, (2) program activities (simulations, training). The program description dominates with roughly three to four sentences compared to two about the ISO. But the disclosure does include years of experience — "over a decade" — and mentions certifications for team members, even if generically. So I'm weighing whether the person-focused content is substantial enough to trigger MR, or if the program activities are dominant enough to keep it as RMP.

The person-removal test helps here: if I strip out the ISO references, the paragraph still reads as a coherent program description. That suggests RMP is primary. The ISO mention with experience is really just context for who runs the program, not the main focus. The bulk of the text describes what the program actually does — training, simulations, exercises. So RMP seems right, even though there's meaningful MR content woven in.

Now I'm checking the specificity of the program details to see how much concrete information is actually provided. I need the next thinking to rewrite. You've provided my current rewritten thinking and the guidelines, but I don't see the "next thinking" content that I should be rewriting.

Could you share the next thinking chunk that needs to be rewritten?

fact: Information Security Officer


reasoning: Applying the person-removal test: removing the named roles (Global IT Director, System Infrastructure Manager, Network Infrastructure Manager) and their experience, the paragraph still coherently describes what the CIRT does — policy management, detection, assessment, classification, escalation, and documentation. The bulk of the paragraph (sentences 2–5) describes internal cybersecurity processes, making the role attributions introductory rather than the primary content. Specificity is Firm-Specific: the named internal program 'CIRT' with a unique abbreviation qualifies as an IS fact, along with 'over 20 years of experience,' but only one QV-eligible hard fact (the years figure) prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the CIRT team, names specific roles (Global IT Director, System Infrastructure Manager, Network Infrastructure Manager), mentions "over 20 years of experience," and then describes what the CIRT does (manages cybersecurity policy, detection, assessment, classification, documentation).

**Category Analysis:**

Step 1 — Subject test: The CIRT (a team) is the subject. But it starts by naming specific roles and their experience.

Step 2 — Person-removal test: If I remove "led by the Global IT Director, System Infrastructure Manager and the Network Infrastructure Manager, each with over 20 years of experience in IT" — the paragraph still describes what CIRT does: manages cybersecurity policy, detection, assessment, classification, escalation, documentation.

That's coherent as a process description. But the opening does identify who leads the program and their qualifications. The bulk of the content focuses on what the CIRT does rather than who's running it, though the experience credentials are definitely present. This feels like it's leaning toward RMP since the functional description stands independently, but the named roles and their experience pull it toward MR signals. It's borderline between the two categories.

Let me reconsider the specific titles mentioned. "Global IT Director" is general IT rather than cybersecurity-specific, and "System Infrastructure Manager" and "Network Infrastructure Manager" are also broad IT roles, not the specialized security titles on the IS list. The program name itself — Cyber Incident Response Team — is distinctive, but the leadership roles aren't particularly security-focused. Given that the majority of the paragraph describes processes and functions with role attribution as context, I'm leaning toward RMP as the dominant classification. The roles mentioned—Global IT Director, System Infrastructure Manager, Network Infrastructure Manager—aren't cybersecurity-specific according to the IS criteria, so they don't qualify. That leaves just the specific experience number as QV-eligible, making this Firm-Specific classification with the CIRT as the IS fact.

fact: Cyber Incident Response Team (CIRT)

fact: over 20 years of experience in IT (for each named leader)

type: quantified


reasoning: The paragraph lists management's cybersecurity responsibilities (setting objectives, resource allocation, policy development, risk management, incident response, compliance), but all content describes generic program activities and functions. Applying the person-removal test: removing 'management team' leaves a fully coherent description of cybersecurity processes — no names, credentials, qualifications, or career history are provided, so this is about the function, not the person. No named frameworks, specific dates, named tools, or firm-specific facts are present; every bullet point could be pasted into any company's filing unchanged.

thinking:
Let me analyze this paragraph.

Content: Describes management team's role in cybersecurity with a bulleted list of responsibilities (setting security objectives, resource allocation, policy development, risk management, incident response, compliance).

Category analysis:
- Subject is "the management team" - person/role as subject → signal, continue to Step 2
- Person-removal test: Remove "management team" references. The remaining content describes generic cybersecurity program activities (setting objectives, allocating resources, developing policies, risk management, incident response, compliance). YES, it's coherent without the person → Risk Management Process
- But wait - this is describing what management DOES, not who they ARE.

Now looking at the specifics: there are no credentials, names, or qualifications mentioned. The paragraph is really about management responsibilities and functions rather than the people themselves. Applying the person-versus-function test confirms this is about processes and activities, not personal attributes. There are no named frameworks, specific roles beyond "management team," dates, or other concrete details that would anchor this to particular individuals. This is clearly a Risk Management Process category.


reasoning: Applying the person-removal test: removing the CISO attribution and reporting line, the paragraph still coherently describes the Adviser's information security program — its design to oversee risk, ensure CIA triad, implement controls aligned with industry guidelines. The CISO mention is incidental attribution; the substantive content is process description. 'Extensive experience' is vague (no years, no certifications), so it does not pull toward Management Role. The CISO title is a firm-specific fact (cybersecurity-specific role on the IS list), but there is only one QV-eligible fact, keeping specificity at Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph step by step.

First, let me identify what's being discussed. The paragraph mentions a CISO who reports to the GCSO, then describes the information security program's design and controls.

**Category Analysis:**

Step 1 (Subject test): The grammatical subjects are "Our Adviser's information security program" (twice) and the CISO. Mixed.

Step 2 (Person-removal test): Remove "led by its Chief Information Security Officer ("CISO") who reports directly to the GCSO and has extensive experience in specializing in information security and risk management." The remaining text: "Our Adviser's information security program is designed to oversee all aspects of information security risk and seeks to ensure the confidentiality, integrity and availability of information assets, including the implementation of controls aligned with industry guidelines and applicable statutes and regulations to identify threats, detect attacks and protect its and our information assets." — This is a coherent process description. YES → Risk Management Process.

The first sentence does contain substantial person-related content about the CISO's role and reporting structure, though the experience description is vague without specific years or certifications. The second sentence focuses entirely on process. Even with this split, the lack of concrete credentials or background details points toward Risk Management Process rather than personnel information.

Looking at specificity, I can identify CISO as a cybersecurity-specific title that belongs on the IS list, and GCSO appears to be a firm-specific role title, likely Global Chief Security Officer. CISO is the only firm-specific fact here, so this falls into the Firm-Specific category.

fact: Chief Information Security Officer (CISO)


content_category: Board Governance

reasoning: The paragraph describes the escalation/notification structure for cybersecurity incidents (severity thresholds triggering notification to management, Audit Committee, and Board), the process by which management and the Audit Committee would review incidents for 8-K disclosure, and a board member's IT experience. The primary purpose is describing how information flows upward through the governance chain — classic Board Governance. The materiality language ('materially affects, or is reasonably likely to materially affect') is procedural/conditional (describing WHEN they would review), not a company conclusion about whether cyber has affected the business, so it does not trigger Strategy Integration. No IS-list facts are present: 'Audit Committee,' 'Board of Directors,' and company self-references are all on the NOT list, and the board member's experience is described without a cybersecurity-specific title or verifiable detail.

thinking:
Let me analyze this paragraph carefully.

The paragraph has three distinct parts:
1. Notification/escalation procedures within the Cybersecurity Program with severity thresholds
2. Materiality assessment process for incidents (review with Audit Committee for 8-K disclosure)
3. A board member's IT experience

The first part describes the program's notification structure - different severity levels trigger different notifications up to board. This is about the governance/oversight structure - how information flows upward.

The second part describes the process for evaluating whether an incident requires disclosure - management reviews with Audit Committee. This is governance structure.

The third part mentions board-level expertise.

So the core here is really about the escalation pathway and the disclosure decision-making process. The materiality language isn't making a judgment about whether cyber has actually impacted the business - it's just the trigger for when they'd evaluate it for disclosure purposes. That's a procedural threshold, not a substantive assessment.

Looking at the specificity angle, there's nothing particularly concrete here - no named frameworks, no CISO or CTO titles, no dates or numbers. The board member's IT experience is mentioned but without any cybersecurity-specific designation. And the company references and form citations are all generic boilerplate that wouldn't count anyway.


reasoning: This paragraph is generic risk-acknowledgment language listing reasons the company faces cybersecurity risks (scope, complexity, threat actors, third parties) without describing any process, governance structure, incident, or making a materiality assessment. It contains no substantive cybersecurity disclosure content — it could appear in virtually any company's filing unchanged. No named standards, roles, dates, or firm-specific facts are present.

thinking:
This paragraph describes cybersecurity risk factors in general terms. Let me classify it.

Content: Lists reasons why the company faces cybersecurity risks - scope of operations, complexity of systems, attractiveness to threat actors, use of third parties. No materiality assessment, no process description, no governance structure, no incident.

This is generic risk language. No materiality assessment (no "materially affected" conclusion). No process described. It's essentially saying "we face cyber risks because..." which is general business language about why cyber risk exists.

Category: None/Other - this is generic risk acknowledgment language, not substantive disclosure. It doesn't describe any program, governance, incident, or make a materiality assessment.

The mention of third-party products and state-sponsored organizations doesn't elevate this beyond a general risk statement - there's no materiality assessment or description of any actual strategy or governance response. This is just boilerplate language acknowledging that cybersecurity risks exist.

Specificity: Generic Boilerplate.


content_category: Strategy Integration

reasoning: The opening clause 'we have not yet experienced any material impacts from a cyber-attack' is a backward-looking negative materiality assertion, which per Rule 6 triggers Strategy Integration. The remainder is generic risk speculation ('could materially adversely impact') and cost language, but the materiality assessment is the substantive disclosure content. No firm-specific facts, named frameworks, roles, or verifiable details are present — entirely boilerplate language.

thinking:
Let me analyze this paragraph.

Content: "While we have not yet experienced any material impacts from a cyber-attack" — this is a negative assertion about materiality. Then it goes into generic risk warnings about what "could" happen, and mentions evolving market dynamics driving costs.

Category analysis:
- "have not yet experienced any material impacts from a cyber-attack" — This is a negative materiality assertion → Strategy Integration per Rule 6
- But wait, the rest is generic risk warning ("could materially adversely impact") which is NOT an assessment per the rules
- The opening clause IS a materiality assessment (backward-looking negative assertion)

- The substantive disclosure is that negative materiality assertion in the opening clause, while everything else is just consequence language and cost speculation. Since there are no named roles, dates, amounts, frameworks, tools, or firms—just generic language throughout—this falls under generic boilerplate with a Specificity 1 rating.


reasoning: This is a governance-chain paragraph describing how cybersecurity risk information flows upward: management-level cybersecurity risk committees → Non-Financial Risk Committee → Firm Risk Committee/BOTC/MS Board → Company's Board. The CIO and Head of Operational Risk are mentioned as intermediaries reporting to the board, not as the focus of the paragraph. The communicative purpose is describing the oversight structure, making this Board Governance. Multiple named non-generic committees (Non-Financial Risk Committee, Firm Risk Committee, BOTC) and a cybersecurity-specific role (CIO) provide firm-specific detail, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named third-party firms) are present.

thinking:
Let me analyze this paragraph carefully.

This describes a governance chain: management-level cybersecurity risk committees → Non-Financial Risk Committee → Firm Risk Committee/BOTC/MS Board → Company's Board. The CIO and Head of Operational Risk report upward. The purpose is describing the oversight structure and how information flows.

Category: This is a governance-chain paragraph. The purpose is describing how cybersecurity risk information flows from management committees up to the board. Per Rule 2, governance-chain paragraphs are almost always Board Governance. The CIO and Head of Operational Risk are mentioned as intermediaries in the reporting chain, not as the focus. → **Board Governance**

Now I'm checking the specificity of the facts mentioned. The paragraph includes several named committees like the dedicated cybersecurity risk committees, Non-Financial Risk Committee, Firm Risk Committee, and BOTC, along with cybersecurity-specific titles like CIO. These are firm-specific facts that appear on the IS list, suggesting this paragraph contains multiple concrete details rather than generic governance language.

However, none of these facts qualify as QV-eligible since they lack the specific quantitative markers like dates, dollar amounts, headcounts, percentages, or named third-party firms. Named roles and committees alone don't meet that threshold. So this comes down to Firm-Specific facts only.

fact: dedicated management-level cybersecurity risk committees

fact: Non-Financial Risk Committee

fact: CIO

fact: Firm Risk Committee

fact: BOTC (Board-level committee)


reasoning: The paragraph spans multiple topics but its primary communicative purpose is describing the governance and oversight structure: the board adopted a named policy, the CTO reports to the CEO and briefs the audit committee/board, directors have relevant experience, and the audit committee oversees ERM including cyber. The CTO's 25 years of experience is a Management Role element but is subordinate to the overall governance-chain description. Specificity is Firm-Specific: the named policy, CTO role, and 25 years of experience are IS-list facts, but only one QV-eligible hard fact (25 years) falls short of the two needed for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

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

1. Board adopted a Cyber Security and Personal Data Breach Policy
2. CTO oversees cybersecurity program, reports to CEO, briefs audit committee and board
3. CTO has over 25 years of experience
4. Directors have cybersecurity/technology experience
5. Board receives updates/training from management, experts, legal advisors
6. Audit committee oversees ERM including cyber risks
7. Audit committee receives assessments from outside advisors

8. The core focus is the governance structure—how oversight flows from the board through the CTO to the audit committee, with relevant expertise embedded throughout. The CTO's experience and director qualifications support this structure but aren't the main point. This is fundamentally about Board Governance.

Now I'm checking which facts qualify as QV-eligible by reviewing the criteria: specific dates, dollar amounts, headcounts, percentages, named third-party firms, named products, named certifications, years of experience as a specific number, and named universities. The "over 25 years" of professional experience meets the threshold as a specific number, while the named policy itself is an IS fact but doesn't qualify for QV purposes.

Since I only have one QV-eligible fact and need at least two for QV classification, this falls into the Firm-Specific category instead—I've identified multiple IS facts including the CTO title, the named policy, and the years of experience.

fact: Cyber Security and Personal Data Breach Policy (named internal policy)

fact: Chief Technology Officer oversees cybersecurity program

fact: Over 25 years of professional experience (CTO)


reasoning: Applying the person-removal test: removing 'The CIO leads' and 'The CIO implements and oversees,' the paragraph still coherently describes cybersecurity processes — ongoing education, monitoring, advanced security measures, system audits, penetration testing, and incident response planning. The CIO is incidental attribution; the substantive content is about what the program does. CIO is a cybersecurity-specific title on the IS list, providing one firm-specific fact, but no second QV-eligible hard fact exists.

thinking:
Let me analyze this paragraph.

Content category: The paragraph mentions the CIO leading the cybersecurity team and describes what the program does - monitoring, security measures, audits, penetration testing, incident response plan. Apply the MR vs RMP decision chain:

Step 1: CIO is the grammatical subject in some sentences, but process/program elements are also subjects.
Step 2: Remove "The CIO leads" and "The CIO implements and oversees" - the remaining text describes monitoring, security measures, audits, penetration testing, incident response plan. It's a coherent cybersecurity disclosure. → Risk Management Process.

Step 3: The CIO is a cybersecurity-specific title on the IS list, making this Firm-Specific, but there's only one hard verifiable fact here, so no Quantified Value applies.

fact: CIO leads cybersecurity team


reasoning: The paragraph's primary purpose is describing the oversight/reporting structure — how information flows from management to the Board of Directors via monthly reports, what those reports cover, and how evaluation results are reported upward. The Board is the ultimate recipient of oversight information, making this a governance-chain paragraph. No IS-list facts are present: 'monthly' is a generic cadence, 'Board of Directors' is standard governance, and experts are unnamed.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes how management reports to the Board on cybersecurity matters monthly, what those reports contain, and how the program is evaluated with results reported to senior management and the Board.

**Content Category:**
This is about the reporting/oversight structure - how information flows from management to the Board. The purpose is describing the governance chain: management → Board reporting cadence, report contents, evaluation results flowing to Board. Per Rule 2, governance-chain paragraphs are Board Governance when the purpose is describing oversight structure.

The Board is the recipient of reports. The paragraph describes how oversight works (monthly reports, what's included, evaluation results reported to Board). This is Board Governance.

Looking at the specifics, I'm checking what concrete details are actually present. The paragraph mentions monthly reporting cadence, references to the Board of Directors, internal and external experts, and senior management, but none of these are named or specific—they're all generic references. There are no named frameworks, no identified roles like a CISO, no specific dates, no named third-party firms, and no numerical metrics. This is generic boilerplate language without substantive detail.


reasoning: The paragraph describes the reporting structure through which cybersecurity information flows to the Audit Committee and full Board — the CISO reports threats/incidents, senior management escalates significant incidents. The purpose is describing the oversight/reporting structure (governance chain), making it Board Governance. The CISO title is a cybersecurity-specific role (one IS-list fact), but there are no second hard verifiable facts for QV; Audit Committee and generic cadences like 'quarterly' are on the NOT list.

thinking:
Board Governance - describes reporting structure to the Audit Committee and Board.

Specificity: CISO is a cybersecurity-specific title → Firm-Specific. No second hard verifiable fact for QV.

fact: CISO


reasoning: The paragraph's primary communicative purpose is describing the governance/oversight reporting chain: the Risk Management Steering Committee monitors cybersecurity threats and reports to the Audit Committee. This is a governance-chain paragraph where management actors (CFO, GC, committee) serve as intermediaries flowing information upward to the board-level Audit Committee. The qualifications mention ('substantial experience') is generic and subordinate to the reporting structure description. The named non-generic committee (Risk Management Steering Committee) is a firm-specific fact, but no QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph carefully.

The paragraph discusses the Risk Management Steering Committee members' experience, and how the CFO, GC, and the committee monitor cybersecurity and report to the Audit Committee.

Category analysis:
- This spans multiple layers: management committee experience + reporting to Audit Committee
- The purpose test: Is this about oversight structure (BG), about who people are (MR), or about processes (RMP)?
- The paragraph describes: (1) committee members' experience, (2) monitoring activities, (3) reporting to Audit Committee
- The governance chain runs from committee → Audit Committee.

So the core purpose here is the oversight and reporting structure—how the Risk Management Steering Committee monitors threats and feeds information up to the Audit Committee through the CFO and GC. While the paragraph mentions the committee members have substantial experience managing risks, the dominant focus is on the governance chain and how information flows to the board, which makes this a Board Governance category.

Looking at specificity, the Risk Management Steering Committee is the only named, non-generic element here. The CFO, GC, Audit Committee, and references to business unit representatives are all generic titles and roles. There are no dates, numbers, named external firms, or specific frameworks mentioned. So this lands as Firm-Specific based on that one named committee, but it's not QV-eligible since the committee name itself doesn't constitute a quantifiable fact.

fact: Risk Management Steering Committee


reasoning: The paragraph describes the reporting structure from management to the board on cybersecurity matters — its purpose is explaining how information flows upward to the board, making it a governance-chain paragraph (Board Governance). 'Vice President of Corporate Development & Administration' is not a cybersecurity-specific title (not CISO/CTO/CIO/VP of IT/Security), 'board of directors' is generic, and 'regular basis' is a vague cadence, so no IS-list facts remain after validation.

thinking:
Let me analyze this paragraph.

The paragraph describes a reporting structure where the VP of Corporate Development & Administration reports to the board on cybersecurity matters. The purpose is describing the oversight/reporting structure - how information flows to the board.

Category: This is a governance-chain paragraph. The purpose is describing oversight structure (who reports to the board, what they report on). Per Rule 2, governance-chain paragraphs are almost always Board Governance. The board is the recipient of reports. → Board Governance

Specificity:
- "Vice President of Corporate Development & Administration" — this is not a cybersecurity-specific title (CISO, CTO, CIO, VP of IT/Security).

It's a general corporate title, so it doesn't match the IS list. The board reference is generic, the reporting cadence is vague, and there are no named frameworks, specific dates, or tools mentioned. That leaves no concrete details to extract. → Generic Boilerplate

So the classification is Board Governance, Generic Boilerplate.


content_category: Management Role

reasoning: The paragraph describes management committees responsible for cybersecurity — the IT Operating Committee and IT Steering Committee — including their specific compositions, meeting cadences, and review responsibilities. The codebook's Management Role definition explicitly includes 'management committees responsible for cybersecurity.' While process elements appear (reviews, ERM coordination), the primary purpose is describing the organizational structure of WHO oversees cybersecurity at the management level. Multiple IS-list facts (CISO, two named non-generic committees, specific team compositions) establish Firm-Specific, but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms/tools) reach the two-fact QV threshold.

thinking:
Let me analyze this paragraph from Texas Pacific Land Corp's 10-K filing.

**Content Category Analysis:**

This paragraph describes management-level committees and their oversight structure. Let me apply the decision rules:

- The grammatical subject is "The Director of Information Technology" — a person/role
- The paragraph describes two committees (IT Operating Committee, IT Steering Committee), their composition, meeting cadence, and responsibilities
- It describes governance structure — how oversight works, who is on which committee, what they review

Applying the board-line test (Rule 2): This is about management-level committees, not the board. The Audit Committee is mentioned at the end but only as a coordination point.

Now I'm working through whether this is really about the individual role or the organizational structure itself. If I strip away the person's title, what remains is a description of committee compositions, meeting frequencies, and governance processes — the infrastructure of how IT oversight actually functions rather than what any single person brings to the role. I'm going back and forth on whether this is about management structure or process. The committees themselves are the organizational structure — the Director of IT, CISO, and department heads arranged into specific oversight bodies. Even if I remove the titles, I'm left with descriptions of committee compositions and their review activities, which points toward Risk Management Process. But the core content is really about WHO oversees cybersecurity and HOW they're organized, which feels more like Management Role. I think the organizational structure angle is stronger here — this is describing the management hierarchy and committee framework for cybersecurity oversight. Looking at the specificity now — CISO is a named cybersecurity role, and both the IT Operating Committee and IT Steering Committee are named non-generic committees, so that puts us at Firm-Specific level. But for Quality Verification, I need hard verifiable facts like dates, dollar amounts, headcounts, or named certifications, and I'm not finding any of those here — just the committee names and titles themselves.

fact: IT Operating Committee

fact: IT Steering Committee

fact: Committee composition: Director of IT, CISO, department heads (Operating) and executives (Steering)


reasoning: Despite the heading 'Management's Role Managing Risk,' the paragraph's communicative purpose is describing how management reports TO the audit committee — briefing cadence, topics covered, and information flow upward. The board committee is the recipient and the oversight structure is the focus, making this Board Governance per the governance-chain rule. No IS-list facts are present: 'Audit Committee' is generic, 'quarterly' is a generic cadence, and 'management' is unspecified.

thinking:
Let me analyze this paragraph.

The paragraph is titled "Management's Role Managing Risk" but the content describes quarterly briefings provided by management TO the audit committee. Let me apply the decision rules.

Category: The paragraph describes management providing briefings to the audit committee. The purpose is describing the reporting/oversight structure - how information flows from management to the board committee. Per Rule 2, governance-chain paragraphs where the purpose is describing oversight/reporting structure → Board Governance.

The bullet points describe what topics are covered in these briefings to the audit committee. The board/committee is the recipient of these reports, and the paragraph describes how oversight works.

Now checking the specificity - there are no named roles, no specific frameworks or standards referenced, no particular dates, and no named tools. The audit committee and quarterly briefings are just generic governance language without concrete details, so this falls into generic boilerplate territory.


reasoning: The paragraph describes the internal escalation process for cybersecurity incidents — monitoring, evaluation by the cybersecurity organization, and escalation to the CISO and senior leadership. Applying the person-removal test, removing the CISO reference leaves a coherent process description ('incidents are evaluated by the cybersecurity organization, which escalates information to senior leadership'), confirming this is about the process, not the person. The CISO is a cybersecurity-specific title on the IS list, yielding Firm-Specific, but there is only one qualifying fact so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes how cybersecurity incidents are monitored, escalated through the organization to the CISO and then to senior leadership. This is about the escalation/reporting process.

Category analysis:
- It describes internal processes for monitoring and escalating incidents
- The CISO is mentioned as part of the escalation chain, not described personally
- Person-removal test: Remove "CISO" references → "incidents are evaluated by the company's cybersecurity organization, which escalates information about incidents... to senior leadership" — still coherent as a process description
- This is Risk Management Process

- The only specific fact here is the mention of "CISO" as a cybersecurity-specific title, which makes this a firm-specific detail, while everything else is generic process description.

fact: CISO (Chief Information Security Officer)


reasoning: This is a governance-chain paragraph describing oversight structure: management-level committees (ISMS Governance Committee, Data Protection Governance Committee) with named co-chairs (interim CSO, DPO), their responsibilities (oversight, resource allocation, risk review/treatment/monitoring), and reporting lines to the audit committee. Per the purpose test, the communicative purpose is describing the oversight/reporting structure and how information flows to the board, making this Board Governance rather than RMP — the activities described (review risks, evaluate treatments) serve the governance narrative, not a process description. Firm-Specific due to named cybersecurity-specific roles (CSO, DPO) and uniquely named committees (ISMS Governance Committee, Data Protection Governance Committee), but no QV-eligible hard facts (no dates, amounts, named firms, or tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph is titled "Management Oversight" and describes a governance structure. Let me apply the decision rules.

Content Category Analysis:
- Describes ISMS governance committee structure
- Names interim CSO and interim DPO as co-chairs
- Describes committee responsibilities (oversight, resource allocation, capabilities, planning)
- Describes what committee members do (review risks, evaluate treatments, monitor remediation)
- Reports to audit committee

This spans multiple categories. Let me apply the tiebreakers.

Board vs Management vs RMP:
- The paragraph describes governance committees and their structure/responsibilities
- The interim CSO and DPO co-chair the committee - this is about organizational structure

- The last sentence mentions reporting to audit committee

Applying the person-vs-function test: The subjects are committees and roles, but when I remove the role titles, the remaining content about what committees do—reviewing risks, evaluating treatments, monitoring remediation, and reporting to audit committee—still makes sense. There's no mention of qualifications or experience, so this isn't about Management Roles. The paragraph focuses on management-level committee operations and oversight structure rather than the audit reporting relationship, so this falls under Board Governance. The audit committee mention is really just the endpoint of the reporting chain. What's actually being described here is how management structures itself to handle cybersecurity oversight—the committees, their composition, and what they actually do day-to-day like reviewing risks and monitoring remediation. That's the substance of the paragraph, which points more toward Risk Management Process than Board Governance. The governance structure itself is the mechanism for how the company manages cyber risk internally, not primarily about board-level oversight. The grammatical subjects performing actions are management-level roles and committees—the interim CSO, DPO, and ISMS committees—not the board itself. The paragraph's primary focus is describing how these management committees conduct risk management activities like reviewing and monitoring remediation, with audit committee reporting mentioned only briefly. This points toward Risk Management Process rather than Board Governance, since the core purpose is explaining the management-level governance structure and risk oversight activities, not the board's oversight role. be Board Governance. But these are management-level committees, not board committees, so that doesn't quite fit either. The paragraph is really about what management committees do and how they manage cybersecurity risk—the audit committee reporting is just the connection point to the board. I think Risk Management Process is the right call here, since the focus is on the internal management structure and activities, not the board's oversight role itself.

Actually, let me reconsider once more. The paragraph lays out a governance structure with specific committees, their composition, responsibilities, and reporting lines. That's fundamentally about how oversight is organized. Looking at the key signals—management committees doing risk work, reporting to the board—I'm leaning toward Risk Management Process because the substance is about the management-level activities and risk evaluation, not about board governance per se. I'm reconsidering whether this is actually Board Governance rather than Risk Management Process. The paragraph describes an oversight structure that connects management committees up to the audit committee at the board level, which fits the governance-chain pattern better. Now I need to identify the specific facts: the interim CSO and interim Data Privacy Officer are cybersecurity-specific roles, and both the ISMS Governance Committee and Data Protection Governance Committee are named, non-generic committees that should count as IS facts, whereas "audit committee" is too generic to include.

For the QV check, I don't have two or more hard verifiable facts—the roles and committees aren't QV-eligible without dates, dollar amounts, or named external firms—so this lands in Firm-Specific.

fact: interim CSO

fact: interim Data Privacy Officer (DPO)

fact: ISMS Governance Committee

fact: Data Protection Governance Committee


reasoning: This is a governance-chain paragraph: it opens with the Board's cyber risk oversight responsibility, then describes the Risk Committee (a senior management committee) and its role in identifying, assessing, and managing enterprise risks including cyber, plus materiality determination. The purpose is describing the oversight structure, not the person or the process details, making it Board Governance. The named 'Risk Committee' is a non-generic committee per the IS list, yielding Firm-Specific; no second QV-eligible hard fact is present.

thinking:
Let me analyze this paragraph.

Content Category: The paragraph starts with board oversight, then describes a Risk Committee of senior management. The Risk Committee is a management-level committee (comprised of senior management), not a board committee. It describes the committee's responsibilities including risk identification and materiality determination.

The primary purpose is describing the governance/oversight structure - how cyber risk is overseen. The Board is mentioned first as responsible for oversight, then the Risk Committee (senior management) is described as the body that identifies, assesses, and manages risks including cyber. This is a governance-chain paragraph (board → management committee → responsibilities).

Per Rule 2, governance-chain paragraphs describing oversight structure → Board Governance.

The board carries the oversight responsibility while the Risk Committee, composed of senior management, operates as the operational layer handling risk identification and assessment. This is clearly a Board Governance category since it's mapping out the oversight structure from board level down through the management committee.

Specificity: The Risk Committee is a named committee with defined composition and responsibilities around materiality determination, making it a specific fact rather than generic governance language.

So this is Firm-Specific (3) — just the one IS fact about the Risk Committee itself, with no quantifiable hard facts like dates or dollar amounts.

fact: Risk Committee (named non-generic management committee with defined cybersecurity oversight responsibilities)


reasoning: This introductory paragraph describes the organizational structure for managing cybersecurity risks — committees and management positions responsible for assessing, identifying, and managing risks, with the ERM Committee named. The primary content is about the risk management organizational structure (ERM integration), not about who specific people are (MR) or board-level oversight (BG). The person-removal test confirms: removing 'individual management positions' leaves a coherent statement about committees managing risks. The named 'Enterprise Risk Management Committee' is a non-generic committee on the IS list, elevating specificity to Firm-Specific.

thinking:
Let me analyze this paragraph.

This is a brief paragraph that mentions committees and management positions responsible for cybersecurity risks, followed by what appears to be a header "Enterprise Risk Management Committee."

Category: This mentions committees and management positions responsible for cybersecurity risks. It's describing organizational structure for risk management. The "Enterprise Risk Management Committee" at the end appears to be a header/label for the next section.

The paragraph is about the governance/management structure. It mentions "several committees and individual management positions" - this is describing the oversight structure. It's borderline between Board Governance, Management Role, and Risk Management Process.

Looking at the specific language here, the focus is on management positions and committees that are responsible for assessing, identifying, and managing cybersecurity risks. This is clearly describing the organizational structure and roles involved in risk management, with the Enterprise Risk Management Committee serving as a header for what comes next. is governance structure. The paragraph describes who's responsible for cybersecurity oversight—both committees and management positions—which points toward Risk Management Process since it focuses on the activities of assessing, identifying, and managing risks rather than just naming governance bodies. The Enterprise Risk Management Committee is a specific named entity from the IS list, so this should be classified as Firm-Specific. I'm also noting that "material cybersecurity risks" uses "material" as a descriptor rather than indicating a formal materiality assessment.

fact: Enterprise Risk Management Committee


reasoning: Applying the person-removal test: removing the CISO and VP Internal Audit titles, the paragraph still coherently describes a risk council's purpose, composition, meeting cadence, and ERM integration function — the process stands on its own. The paragraph's primary communicative purpose is describing how cybersecurity risk is managed through the Enterprise Risk Council (ERM integration), not who the individuals are or their qualifications. Specificity is Firm-Specific based on the cybersecurity-specific CISO title and the named non-generic Enterprise Risk Council committee, but neither fact is QV-eligible.

thinking:
Let me analyze this paragraph.

The paragraph describes the Enterprise Risk Council - its composition, meeting cadence, and purpose. The CISO is mentioned as a member, and the VP Internal Audit chairs it. The focus is on a management committee structure.

Category: This is about a management committee (Enterprise Risk Council) and its role in risk management. The CISO is mentioned as a member, the VP Internal Audit chairs it. This is describing organizational structure for risk oversight at the management level.

Is this Board Governance? No - this is a management-level council, not board/committee oversight.

Is this Management Role? The Enterprise Risk Council fits the definition of a management committee responsible for cybersecurity, though the paragraph emphasizes the committee's structure and purpose rather than individual qualifications.

Is this Risk Management Process? The council's function is clearly risk management, but the focus is on the organizational structure itself—who sits on it, how often it meets, what it does—rather than describing a specific process or methodology.

The person-removal test is tricky here. Even without naming the CISO and VP Internal Audit, the paragraph still describes a standing committee structure for managing enterprise risk. That suggests it's more about the management committee itself than about individual roles. But I keep coming back to the fact that this is fundamentally describing a management-level committee responsible for cybersecurity oversight, which is exactly what Management Role covers. The Enterprise Risk Council functions as a management committee for ERM, and while the CISO title is cybersecurity-specific, the paragraph's focus on committee structure and quarterly cadence makes this firm-specific rather than a standardized process. The named committee and role references aren't generalizable across organizations, so this falls under Risk Management Process with firm-specific details.

fact: CISO is a standing member of the council

fact: Enterprise Risk Council (named management committee)


reasoning: The paragraph describes the company's internal process of re-examining systems after risk assessments and continuously evaluating cybersecurity risks. The 'head of our IT department' and 'CFO' are generic titles (not cybersecurity-specific per the IS list), and applying the person-removal test, the remaining content still describes a process. No named frameworks, specific dates, or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes re-examining systems after risk assessments, and mentions the head of IT department reporting to CFO, working with management to evaluate cybersecurity risks.

Category analysis:
- Subject test: "we re-examine our systems and processes" - process description. Second sentence: "head of our IT department... works with management to continuously evaluate and address cybersecurity risks"
- Person-removal test: Remove "The head of our IT department, who reports to our Chief Financial Officer" → "works with management to continuously evaluate and address cybersecurity risks in alignment with our business objectives and operational needs." Still coherent as process description.

- No qualifications or credentials mentioned, just a risk management process. The titles used—head of IT department and Chief Financial Officer—are generic C-suite positions not tied to any specific industry standards or frameworks. This is generic boilerplate language without named standards or specific facts.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach and a management-level Cybersecurity Steering Committee with its specific charges (policy review, risk oversight, investment direction). While the CSO and interim Chief Legal Officer are named as co-chairs, the person-removal test shows the substantive content is about what the committee does — its processes and responsibilities — not about who these individuals are (no credentials, experience, or background). This is a management-level committee, not a board committee, so Board Governance does not apply. Two IS-list facts (CSO as cybersecurity-specific title, named Cybersecurity Steering Committee) establish Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes a risk-based approach to cybersecurity and a Cybersecurity Steering Committee. Let me apply the decision rules.

The paragraph starts with internal processes ("risk-based approach", "cybersecurity policies"), then describes a Steering Committee co-chaired by the interim Chief Legal Officer and CSO. The bulk of the paragraph describes what the Steering Committee does - its charges/responsibilities.

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

- The Steering Committee is a management-level committee, not a board committee.

Now I'm working through the decision chain to distinguish between Management Role and Risk Management Process. The committee itself is the subject here, not primarily the individuals. Even if I remove the named roles like the interim Chief Legal Officer and CSO, the description of what the committee does—overseeing policies, providing strategic direction, and reviewing cybersecurity matters—stands independently as a process. There's no mention of specific qualifications or certifications for the roles either.

Looking at the specificity markers: while "CSO" is cybersecurity-specific and the "Cybersecurity Steering Committee" is a named committee, the paragraph focuses on the governance process and committee structure rather than the individuals' credentials or management responsibilities. This points toward Risk Management Process rather than Management Role.

Now checking for QV-eligible facts—there are no dates, financial figures, headcounts, third-party vendors, tools, certifications, or years of experience mentioned. The CSO title and committee name are firm-specific identifiers, but without any quantifiable data points, this falls into the Firm-Specific category.

fact: CSO co-chairs the committee

fact: Cybersecurity Steering Committee (named, non-generic committee)


reasoning: The paragraph describes the governance/oversight structure: the Board authorizes the Audit Committee, a Risk Committee (chaired by the CISO) determines materiality, and the CISO reports quarterly to the Audit Committee. This is a governance-chain paragraph whose purpose is describing how oversight flows from Board → Audit Committee → Risk Committee/CISO, making it Board Governance. The Risk Committee (non-generic named committee) and CISO (cybersecurity-specific title) are firm-specific facts, but no QV-eligible hard facts (dates, amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes the governance/oversight structure. It mentions the Audit Committee's authorization by the Board, a Risk Committee chaired by the CISO, and reporting lines (CISO reports to Audit Committee quarterly).

The purpose is describing the oversight STRUCTURE — how the board exercises oversight through the Audit Committee, how the Risk Committee fits in, and how information flows upward (CISO → Audit Committee). This is a governance-chain paragraph (Board → Audit Committee → Risk Committee/CISO).

Per Rule 2, governance-chain paragraphs are almost always Board Governance.

The CISO appears here as a structural element within the oversight framework rather than as an individual with specific credentials. Looking at the specificity markers: "Risk Committee" and "CISO" are named entities that qualify as facts, while "cross-functional executive leaders" is too generic. The quarterly reporting cadence and Audit Committee reference are standard governance language, not specific facts. Neither the CISO role nor the Risk Committee would trigger QV eligibility since they're structural positions without dates, amounts, or named external parties attached.

fact: Risk Committee chaired by the CISO


reasoning: The paragraph's primary content describes the cybersecurity team's operational responsibilities, the Incident Response Team's composition and monitoring activities, and the incident reporting workflow. Applying the person-removal test: removing CISO references leaves a coherent description of team structure, incident response processes, and reporting chains — the paragraph is about the function, not the person. The governance-chain reporting (to Disclosure Committee, Strategy Board, Audit Committee, Board) is subordinate to the operational process description that dominates most of the paragraph. Firm-Specific due to CISO, CIO, named Strategy Board, and specific departmental IRT composition, but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the cybersecurity team led by the CISO, the Incident Response Team composition, and their responsibilities including monitoring, prevention, detection, and reporting structure.

**Category Analysis:**

Step 1 - Subject test: The cybersecurity team and Incident Response Team are the grammatical subjects. This describes processes and organizational structure.

Step 2 - Person-removal test: Remove "CISO" mentions and the paragraph still describes the team's responsibilities, the IRT composition, monitoring activities, and reporting chain. The content is about what the team/program does, not who the CISO is personally.

Step 3 - No individual qualifications or certifications are mentioned. The core focus is the company's operational cybersecurity processes—team structure, incident response coordination, and monitoring activities—with the reporting hierarchy to the Disclosure Committee, Strategy Board, Audit Committee, and Board serving as the governance framework rather than the main subject.

Looking at the specifics: the IRT composition is clearly detailed with named functions like information security, technology operations, compliance, legal, and financial reporting. The Strategy Board is identified as a specific internal body with named members (CEO, CFO, General Counsel, CIO), and the CISO and CIO are cybersecurity-specific titles. This all points to Risk Management Process as the classification.

For the quantitative value check—there are no specific dates, dollar amounts, headcounts, third-party firms, tools, or certifications mentioned. But the firm-specific facts are substantial: the named Strategy Board committee and the detailed departmental composition of the IRT. This qualifies as Firm-Specific (3).

fact: CISO leads the cybersecurity team

fact: Incident Response Team composed of cybersecurity (information security and technology operations), compliance, legal, financial reporting and other key business and corporate functions

fact: Strategy Board (consisting of CEO, CFO, General Counsel, CIO and other members of management)

fact: CIO is a member of the Strategy Board

fact: Disclosure Committee coordinates timely reporting


reasoning: The paragraph's dominant content describes the company's internal information security program and its toolset (firewalls, IPS, SIEM, endpoint detection, MFA, etc.). Applying the person-removal test: removing the officer titles leaves a coherent description of the security program and technologies, confirming RMP over Management Role. The second half discusses CCO/CRO reporting channels to the Board (governance), but this is subordinate to the program description by volume. The unique cybersecurity-specific title 'Chief Security & Cash Operations Officer' is an IS-list fact triggering Firm-Specific, but the listed technologies are generic categories (not named products/tools), so there are not two QV-eligible hard facts.

thinking:
Let me analyze this paragraph carefully.

The paragraph has multiple parts:
1. Chief Security & Cash Operations Officer directs the Global Information Security organization, which implements/maintains an info security program
2. Lists various security tools and technologies
3. Mentions Chief Risk Officer and Chief Compliance Officer having channels to the Board
4. Chief Compliance Officer oversees investigations and reports to Board Committees
5. These channels prevent siloing and provide risk picture

This is a mixed paragraph. Let me apply the decision rules.

Primary content: The bulk of the paragraph describes the security program and its tools/technologies (firewalls, IPS, SIEM, etc.).

The second half shifts to governance channels (CCO, CRO reporting to Board).

Applying the person-vs-function test:
- "Chief Security & Cash Operations Officer" is named as directing the org, but the content is about what the program does
- Remove the officer titles and the paragraph still describes the security program and governance channels

The dominant content is the security program description (tools, technologies, protections). The governance channel portion is secondary.

Step 1: Subject = "Global Information Security organization" (a program/org) → leans RMP
Step 2: Remove roles → still have a coherent description of security program and tools → RMP

Category: **Risk Management Process** - the paragraph primarily describes the company's internal security program and how its governance structure ensures oversight reaches the Board without creating information silos.

Looking at specificity now: the Chief Security & Cash Operations Officer title is company-specific and cybersecurity-focused, so that's an IS fact. The Global Information Security organization is a named internal program. The technologies mentioned—firewalls, IPS, SIEM—are generic categories rather than named products. CRO and CCO are standard C-suite titles, not on the IS list, and the Board committees referenced are generic governance structures.

For QV eligibility, I need two or more hard verifiable facts like dates, dollar amounts, headcounts, or named entities. The unique title is firm-specific but doesn't meet QV standards on its own. So this falls under Firm-Specific with one IS fact, but it's not QV-eligible.


reasoning: Person-removal test: removing DPIRC and CISO references leaves a coherent description of cybersecurity program activities — implementing/reviewing policies, overseeing detection/response capabilities, monitoring incidents, managing the Incident Response Plan and Business Continuity Plan, coordinating with IT. The paragraph is about what the program does (functions), not who the people are (no credentials, experience, or career history). The DPIRC and CISO are attributions, not the primary content. Enterprise Risk Committee (non-generic named committee) and CISO (cybersecurity-specific title) are firm-specific facts, but none are QV-eligible hard facts.

thinking:
Let me analyze this paragraph.

Content: Describes DPIRC committee responsibilities - implementing/reviewing cybersecurity policies, overseeing protection/detection/response, promoting cybersecurity risk posture, reviewing best practices, strategic direction, overseeing training, monitoring incidents through cybersecurity risk program, coordinating with IT departments. Also mentions Enterprise Risk Committee receiving quarterly updates from CISO.

Category analysis:
- This describes a management committee (DPIRC) and its responsibilities for cybersecurity
- The DPIRC seems to be a management-level committee responsible for cybersecurity operations
- The last sentence mentions Enterprise Risk Committee receiving updates from CISO - this is governance chain

- The paragraph focuses on what the DPIRC committee does operationally - its specific functions and oversight responsibilities rather than board-level governance
- The DPIRC is a named management committee with defined cybersecurity oversight duties, and it reports up through the CISO to the Enterprise Risk Committee
- This is fundamentally about Management Role - describing the committee structure and responsibilities for managing the cybersecurity program

. The DPIRC is the subject, and the paragraph details what this management body is responsible for overseeing.

Actually, I'm second-guessing myself. When I remove "DPIRC" from the description, what remains are cybersecurity functions and activities - implementing policies, overseeing capabilities, monitoring incidents, managing the risk program. The committee is just the vehicle executing these functions, not the focus itself. This points more toward Risk Management Process, where the emphasis is on the cybersecurity activities being performed rather than the organizational structure performing them.

But then there's the Enterprise Risk Committee and CISO mentioned at the end - these are specific named entities and titles that appear on the IS list. That specificity might push this toward Organizational Structure after all, since it's identifying particular governance bodies and roles within the organization.

fact: DPIRC (named management committee with cybersecurity oversight responsibilities)

fact: Enterprise Risk Committee

fact: Vista CISO


reasoning: The paragraph describes how the cybersecurity team and Incident Response Team operate — their monitoring activities, incident response coordination, and escalation procedures. Applying the person-removal test: removing the CISO title leaves a coherent description of the program's operational structure, team composition, and incident response process. The Board/Audit Committee mentions at the end describe the escalation chain as part of incident response procedures, not board oversight as the primary purpose. Specificity is Firm-Specific due to CISO, CIO, specific IRT departmental composition, and the named 'Strategy Board' committee, but no two QV-eligible hard facts (no dates, dollar amounts, named firms, or tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes the cybersecurity team led by the CISO, the Incident Response Team composition, their monitoring activities, and reporting structure up to the Board.

**Category Analysis:**

Step 1 - Subject test: The cybersecurity team and Incident Response Team are the grammatical subjects. This describes what the team does - processes, monitoring, incident response coordination.

Step 2 - Person-removal test: Remove "CISO" references and role titles. The remaining text describes: cybersecurity operations, programs, policies, incident response program, monitoring prevention/detection/mitigation, incident response plan, reporting to Disclosure Committee, Strategy Board, Audit Committee, Board.

This holds up as a process and governance description independent of the people involved. The paragraph actually layers multiple dimensions—the cybersecurity team's operational functions, the specific departments making up the Incident Response Team, and the governance chain flowing up through the Disclosure Committee, Strategy Board, Audit Committee, and ultimately the Board. So this is fundamentally a governance-structure paragraph that explains both how cybersecurity operations function and where decision-making authority sits.

Wait, though—the flow goes upward from operations to governance rather than downward from the Board. The core content is really about the cybersecurity program's operational structure and incident management processes, with the board-level reporting as the escalation mechanism at the end. If I strip away the specific roles and titles, the paragraph still coherently describes what the cybersecurity program does and how incidents move through the system.

Looking at Rule 2 more carefully, governance-chain paragraphs typically flow from board level downward, but this one inverts that—it starts with the operational team and traces upward. The dominant purpose is explaining how the cybersecurity program operates and manages incidents, not prescribing board-level governance. The committee mentions function as part of the escalation and reporting structure, not as the primary subject.

So this lands in Risk Management Process. The paragraph covers what the cybersecurity team oversees, how the Incident Response Team collaborates across departments, the team's composition, monitoring activities tied to the incident response plan, and the escalation pathway. Even without the CISO and specific titles, you'd still understand how the cybersecurity program functions and how incidents get reported upward. I'm checking whether this qualifies as a Quantifiable Fact by looking for specific metrics like dates, dollar amounts, or headcounts—there aren't any. The roles mentioned (CISO, CIO) are titles rather than QV-eligible facts. What I do have are firm-specific details: the particular composition of the Incident Response Team, the Strategy Board as a named governance body, and the escalation structure. That gives me three firm-specific facts, which puts this in the Firm-Specific category.


reasoning: The paragraph describes how the Cybersecurity Program is assessed (by IAD, independent third parties, regulators) and how results are reported upward to board-level committees (BAC, BOTC, board of trustees). The communicative purpose is describing the oversight/assurance structure — how governance bodies receive and review program assessments — making this Board Governance. The BOTC is a named non-generic committee (technology-focused board committee), triggering Firm-Specific. Other elements (Audit Committee, unnamed third party, unnamed regulators) are generic.

thinking:
Let me analyze this paragraph.

This is about North Haven Net REIT, which appears to be a Morgan Stanley-managed entity. The paragraph describes how Morgan Stanley's Cybersecurity Program is assessed.

Content Category: The paragraph describes assessment activities - internal audit, third-party review, regulatory examination. The results are reported to various board committees (BAC, BOTC, board of trustees).

The primary content is about how the cybersecurity program is assessed/reviewed and who receives those results. This spans oversight (board committees receiving reports) and process (assessment activities). The purpose seems to be describing the oversight/assurance structure - how the program is evaluated and how results flow to governance bodies.

The key actors here are the assessment bodies—internal audit, third parties, and regulators—and the board committees that receive their findings. This is fundamentally about governance structure, showing how oversight operates through multiple layers of review and reporting mechanisms.

Looking more closely at what's actually firm-specific versus generic: the Audit Committee and board of trustees are standard governance bodies, the third-party reviewer is unnamed, and the regulators are generic. But BOTC—the Board Oversight of Technology Committee—is a named, non-generic committee specific to Morgan Stanley. That's the only concrete firm-specific fact here, so this doesn't quite reach the threshold for a QV classification.

fact: BOTC (Board Oversight of Technology Committee — named non-generic committee)


reasoning: This is a governance-chain paragraph describing management's responsibilities within the oversight structure, including reporting to the Cybersecurity Committee and Board. Per the codebook, governance-chain paragraphs describing how information flows upward (management → Cybersecurity Committee → Board) are Board Governance even when management is the grammatical subject, because the purpose is describing the oversight/reporting structure. The 'Cybersecurity Committee' is a named non-generic committee (IS list), making this Firm-Specific. 'Executive Vice President, Administration' is not a cybersecurity-specific title per the IS list and does not count.

thinking:
Let me analyze this paragraph.

The paragraph describes management's responsibilities under the EVP Administration. Let me apply the decision rules.

Subject test: "management's responsibilities" - but directed by "Executive Vice President, Administration"

Content: Lists four responsibilities of management regarding cybersecurity program. This is describing what management does (functions), not who the person is.

Person-removal test: Remove "Executive Vice President, Administration" - the paragraph still describes responsibilities coherently. But wait - is this about the governance structure (how oversight works) or about the person?

The paragraph describes management's responsibilities and mentions reporting to the Cybersecurity Committee and Board. This is a governance-chain paragraph describing how oversight flows: EVP Administration → management responsibilities → reports to Cybersecurity Committee → Board.

So the core question is whether this is really about the governance structure and oversight chain, or whether it's primarily focused on what management actually does. The paragraph does describe reporting relationships and information flow to the board, which points toward Board Governance. But the grammatical focus is on management's specific responsibilities and actions, not on the board's oversight role. Let me look at what the codebook actually emphasizes - it's about the purpose of describing oversight and reporting structures. This paragraph does that, but it's secondary to describing management's duties.

I think the key insight is that this is fundamentally about the responsibilities of the EVP Administration role in the governance structure. The reporting to the Cybersecurity Committee and Board is part of that role, not the main point. So this leans more toward Management Role - it's defining what that position is accountable for in the cybersecurity governance chain. The EVP Administration title isn't actually cybersecurity-specific, so that doesn't help classify this. But the Cybersecurity Committee is a named governance body on the list, which pulls toward Board Governance. Still, the core content is really about management's responsibilities and reporting structure rather than board-level oversight itself, so Management Role seems like the better fit. I'm identifying the specific committee mentioned here as a firm-specific fact rather than a generic reference, which means this falls under Firm-Specific classification at Specificity level 3, and it doesn't qualify for QV eligibility since named committees don't count toward that metric.

fact: Cybersecurity Committee