reasoning: The paragraph is centered on board/audit committee reporting and update duties for cybersecurity matters, making board governance the primary category. However, it uses generic descriptions without firm-unique details, dates, roles, systems, or quantified metrics.


content_category: Strategy Integration

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph provides a standalone materiality/disclosure conclusion about the absence of material cybersecurity incidents and immaterial related expenses, without describing any actual incident narrative or internal process details.

provider: openai


content_category: Board Governance

category_confidence: high

specificity_confidence: medium

reasoning: The paragraph is explicitly about the Board receiving cybersecurity-related updates, with the Audit Committee and Cybersecurity team named as sources of those briefings.


content_category: Management Role

reasoning: The paragraph is centered on named management roles (CIO and VP of Information Security) and their responsibility for cybersecurity risk management and supervision of internal and external cyber resources.


content_category: Risk Management Process

category_confidence: low

reasoning: The paragraph describes general cybersecurity risk management and safeguarding objectives, but it does not detail the company’s specific processes, roles, frameworks, or any verifiable facts.


reasoning: The paragraph is a standalone materiality conclusion about cybersecurity incidents (no incident narrative), with a specific date reference, so it fits Strategy Integration rather than Incident Disclosure.


reasoning: The paragraph describes the company’s internal cybersecurity training and phishing simulation activities (awareness, incident training) as part of its own risk management practices.


reasoning: The paragraph centers on the responsibilities and reporting line of a specific management role (“internal cybersecurity coordinator”) and its collaboration with the IT team, indicating management ownership rather than a broader process or incident.


specificity_confidence: low

reasoning: This paragraph discusses cyber insurance and its purpose of mitigating potential financial losses, which is a standalone strategy/financial impact integration rather than an incident narrative or internal risk process.


reasoning: The paragraph describes the company’s internal processes for identifying, assessing, and managing cybersecurity-related material risks across its own systems and data. It contains no named roles, dates, frameworks, or other firm-unique specifics.


reasoning: The paragraph describes the company’s internal cybersecurity risk assessment and management activities (monitoring tools and user training) but provides no company-specific details, named frameworks, dates, or verifiable facts.


reasoning: The paragraph describes the responsibilities of generic cybersecurity professionals (policy, protections, monitoring, incident response) without naming a specific role, committee, person, system, framework, or any company-specific fact.


reasoning: The paragraph assigns cybersecurity-related responsibilities to specific management roles (CFO, COO, CEO), describing their governance functions in managing cyber risk and approving communications.


reasoning: The paragraph states that the Board provides oversight of the cybersecurity program and mentions quarterly updates and annual discussion within enterprise risk management, but uses generic terms without NOV-specific or verifiable details beyond common disclosure language.


reasoning: The paragraph describes the company’s internal cybersecurity training practice (training employees/contractors on threats and communicating policies/processes), but it contains no firm-specific identifiers, named frameworks, or verifiable details beyond generic policy language.


reasoning: The paragraph describes an internal organizational program/team and its responsibilities for cybersecurity awareness, learning, and training, which is part of the company’s internal risk management approach rather than board oversight, a management role, or a specific incident.


reasoning: The paragraph describes general objectives for responding to a potential cyber incident (business continuity, protecting proprietary tech, safeguarding data), but it provides no company-specific details, frameworks, roles, or incident facts.


reasoning: The paragraph describes an intended cybersecurity risk identification/assessment/management process integrated into broader risk management, but it contains no named roles, dates, systems, frameworks, or other firm-specific verifiable details.


reasoning: The paragraph describes the company’s internal risk management process, including training and due diligence/periodic monitoring for critical third-party providers. Although vendors are mentioned, the focus is on the company’s own process rather than imposing security requirements as the central topic.


reasoning: The paragraph describes who handles day-to-day cybersecurity responsibilities (IT staff) and addresses the lack of specialized cybersecurity training, which is management-role content.


reasoning: The paragraph describes the company’s internal cybersecurity program and incident response plan as part of its risk management processes, but it does not provide any firm-specific details, named systems/roles/frameworks, or verifiable facts.


reasoning: The paragraph describes the company’s internal incident response plan (IRP) and how it is tested (annual tabletop exercises) to improve preparedness, which is a risk management process rather than an actual incident or board/management oversight.


reasoning: The paragraph describes the company’s own cybersecurity risk management system and its internal purposes (identify/assess/mitigate risks and protect CIA of information assets), which fits Risk Management Process. It does not name specific tools, dates, or detailed roles, so specificity is limited to sector-adapted framework-style language.


reasoning: The paragraph describes the company’s internal cybersecurity program components (policies, procedures, assessments, monitoring, response plans, and testing) to ensure controls are effective, which is an internal risk management/process description rather than an incident or board/management role.


reasoning: The grammatical subject is a named management/security role (CTO and senior director) and describes their reporting relationship to the Audit Committee, along with the individual's certifications.


reasoning: The paragraph is a standalone materiality conclusion about cybersecurity threats not having a material impact on business strategy, results of operations, or financial condition, with a cross-reference to Item 1A. It does not describe an incident or internal risk-management process.


reasoning: The paragraph is a standalone materiality conclusion about financial impact, without any incident narrative or company-specific operational details.


content_category: Incident Disclosure

reasoning: The paragraph describes active forensic analysis and ongoing investigation of a cybersecurity incident, which constitutes incident disclosure even though it provides no incident-specific facts (dates, systems, scope, or named parties).


reasoning: This paragraph is a standalone materiality conclusion using generic SEC language and does not describe any incident facts, processes, roles, or named entities.


reasoning: The paragraph discusses material disruption and potential financial impacts from an incident, but it provides no incident specifics, dates, amounts, or named systems, making it general materiality/risk language rather than a concrete incident narrative.


reasoning: The paragraph discusses financial impact handling via cyber insurance reimbursements rather than describing the incident itself or internal risk processes. It names VF and cybersecurity insurers but provides no verifiable amounts or specific insurer names/dates.


reasoning: This is a standalone materiality-style statement about whether the incident is reasonably likely to materially impact financial condition/results, without any incident narrative, named entities, frameworks, or operational details.


reasoning: This paragraph is standalone materiality/business impact language (no incident narrative beyond an ongoing investigation, and no specific dates, systems, or amounts). It states the incident is not reasonably likely to materially impact operations or financial condition, which maps to Strategy Integration.


reasoning: The paragraph is focused on cybersecurity insurance coverage and the types of costs it supports (incident response, forensics, business interruption, regulatory fines), which is part of the company’s financial/strategic handling of cyber risk.


reasoning: The paragraph discusses an ongoing cybersecurity incident’s potential material financial impact and ongoing forensic investigation actions, but it provides no firm-specific identifiers, dates, or concrete incident details.


reasoning: This paragraph describes an actual cybersecurity incident (threat actor access and exfiltration of limited data) and associated response actions (continuing notifications to affected parties and regulators). It includes incident-specific details, though it lacks dates, dollar amounts, or named entities beyond generic parties/agencies.


reasoning: This paragraph references an ongoing disruption/incident and provides access to an incident updates status page, indicating incident-related operational impact and where to obtain incident information.


reasoning: The paragraph describes incident-response actions typically associated with an actual cybersecurity matter (notifying law enforcement and regulatory/consumer protection agencies), but it contains no company-specific, dated, or named details.


reasoning: This paragraph is a generic risk/impact statement tied to a prior cybersecurity incident (e.g., potential litigation, regulatory scrutiny, and cyber insurance costs) without describing an incident or naming specific processes, roles, dates, or measurable facts.


reasoning: The paragraph is limited to a materiality assessment (no material impact; not reasonably likely to materially impact financial condition/results) without describing an incident event or company-specific details.


reasoning: This paragraph is a standalone materiality assessment (“not had a material impact” and “not reasonably likely to materially impact financial condition/results”) with no incident details or other substantive specifics.


reasoning: This paragraph is a standalone materiality conclusion about the incident’s impact on operations and the likelihood of material impact to financial condition/results, without describing incident specifics or any named entities, dates, or frameworks.


reasoning: The paragraph describes the company’s internal cybersecurity risk assessment and management processes and assigns responsibility for maintaining them to specific management roles (Senior Director of IT and CFO/Treasurer).


reasoning: This paragraph is standalone materiality language concluding the incident is not reasonably likely to materially impact the Company; it contains no incident narrative or company-specific details.


content_category: None/Other

reasoning: This is contract/legal boilerplate about a Waiver Period under a Credit Agreement and Lease Agreement, with no substantive cybersecurity content or incident/process disclosure.


reasoning: The paragraph describes incident response actions (notifying law enforcement and regulators/consumer protection agencies). However, it is generic, with no specific incident details, dates, parties, or systems.


reasoning: This paragraph is a standalone materiality assessment (no material operational impact; not yet determined to be reasonably likely to materially impact financial condition/results) without describing incident details or internal controls.


reasoning: This paragraph discusses financial impact/coverage expectations via cyber insurance recoveries rather than describing incident events or internal processes.


reasoning: The paragraph discusses the status/impact of a cybersecurity incident (no material disruption) and ongoing evaluation of impacts and remediation costs, which fits incident disclosure. However, it provides no firm-specific details, dates, figures, or named entities, so it is largely boilerplate.


reasoning: The paragraph describes current status of an actual cybersecurity incident (contained, core IT restored, restoring normal business operations), which is characteristic incident disclosure. It contains no firm-unique entities, dates, products, or quantified facts.


reasoning: The paragraph is specifically about executive leadership changes and identifies named management roles and the individual acting as interim CEO for a subsidiary.


reasoning: The paragraph discusses an ongoing incident and states it is reasonably likely to have a material impact, along with continuing forensic investigation and analysis—both incident-specific disclosure elements. However, it provides no verifiable company-specific details (no dates, dollar amounts, systems, or named entities), making it generic boilerplate.


reasoning: The paragraph describes a real cybersecurity incident involving exposure of customer information, including notification and confirmation dates and scope (some customer information exposed).


reasoning: The paragraph describes active restoration efforts and includes incident-response actions (retaining experts, coordinating with law enforcement, and notifying regulatory authorities), which are characteristic of cybersecurity incident disclosures. It contains no firm-unique identifiers, dates, amounts, or named systems.


reasoning: This describes an ongoing cybersecurity investigation and remediation related activities (including data scope still being determined and involvement of a cyber insurance provider), which is consistent with incident disclosure, but it lacks concrete incident details (dates, systems, amounts, named parties).


reasoning: This paragraph describes the status of an ongoing cybersecurity incident investigation and mentions exfiltrated personal information and planned notifications. However, it provides no incident timing, scope details, named systems, or concrete actions beyond generic notification intent.


reasoning: The paragraph provides a standalone materiality/financial impact assessment of a cybersecurity incident without describing incident facts; it focuses on whether the incident is reasonably likely to materially impact financial condition/results, which aligns with Strategy Integration.


reasoning: The paragraph describes an ongoing investigation/forensic analysis related to whether PII was taken by threat actors, which is incident-related narrative rather than process framework or generic risk language.


reasoning: The paragraph describes an ongoing cybersecurity incident posture (contained incident) and response actions (restoring access and resuming operations), but provides no verifiable details such as dates, systems, scope, or named parties.


reasoning: This paragraph describes an ongoing investigation, engagement of cybersecurity experts, and notification of law enforcement, which are standard elements of incident disclosure. It also includes a materiality/financial-impact disclaimer, but provides no firm-specific or verifiable details (dates, amounts, systems, or named parties).


reasoning: This paragraph is a standalone materiality statement about whether the cybersecurity incident may materially impact financial condition/results, without describing the incident or any firm-specific details.


reasoning: The paragraph refers to monitoring an ongoing cybersecurity incident and tracking its timing and materiality, which is incident-related disclosure. However, it contains no firm-specific details, dates, or quantified facts.


reasoning: The paragraph describes incident-related response actions (mailing notification letters) tied to an investigation and potential exposure of personal information, but provides no specific facts such as dates, scope, systems, or named entities.


reasoning: The paragraph discusses assessing whether an incident could have a material impact on financial condition and results of operations, but it provides no incident details (what happened, when, scope) or measurable facts.


reasoning: The paragraph describes an ongoing real operational disruption affecting online ordering in the United States, which is characteristic of incident-style disclosures even though it lacks technical cyber details.


reasoning: The paragraph describes response actions taken in relation to an actual cybersecurity incident (closing off the unlawful access point) and includes customer notification intent.


reasoning: This describes an actual incident’s operational impact (shipping/receiving, manufacturing, back office) and restoration actions, but provides no firm-specific details (no dates, systems, quantities, or named parties).


reasoning: The paragraph describes an actual cybersecurity incident (unauthorized access to systems) and provides a specific awareness date (August 21, 2024), which is typical incident disclosure content for Item 1.05.


reasoning: The paragraph describes a real cybersecurity event (systems outage) with a specific date and includes incident response actions taken after discovery.


reasoning: The paragraph describes the status and outcome of an actual cyber incident (systems/data restored, investigation closed, source unable to be identified), which is characteristic of incident disclosure under Item 1.05.


reasoning: This paragraph provides incident-related disclosure by describing website disruption and directing readers to a company-specific incident communications site (www.firstamupdate.com).


reasoning: The paragraph describes an actual cybersecurity-related event (a system outage) with a specific date and incident response actions taken after discovery, which fits Incident Disclosure.


reasoning: This paragraph describes an actual cybersecurity incident (threat actor access and exposure of sensitive personal information) and includes response actions related to notifications, which are characteristic of incident disclosures.


reasoning: The paragraph is a standalone materiality/financial impact conclusion about an incident (“not had a material impact… will not materially impact financial condition or results of operations”) without any incident narrative or operational details.


reasoning: The paragraph describes an ongoing cybersecurity incident and the actions attributed to the perpetrator (access, data exfiltration, and encryption). It does not provide firm-unique identifiers such as dates, named systems, or third-party firms, so specificity remains generic.


reasoning: The paragraph provides a materiality/impact assessment and evaluation of potential financial effects, without describing any incident details or management/board/process specifics.


reasoning: This paragraph describes a real cybersecurity incident and its impact on access to financial/operating reporting systems for approximately six weeks, which is incident disclosure with a quantified duration.


reasoning: This paragraph provides a standalone materiality conclusion about financial impact (timing and whether it affects financial condition/ongoing operations) rather than describing incident details or internal processes.


reasoning: This paragraph is standalone materiality/financial-impact language about assessing whether an incident will materially affect financial condition or results of operations, without describing incident details or internal/process specifics.


reasoning: The paragraph describes an actual cybersecurity incident and the company’s response (“immediately activated its response process”) including the cause (“fourth-party vendor … had been compromised”).


reasoning: The paragraph describes the company’s assessment of the impacts/cost components of an existing cyber incident (rebuilding the website on a new server/hosting platform and enhancing security). It does not provide enough verifiable details (e.g., dates/amounts or named systems) to reach Quantified-Verifiable.


reasoning: The paragraph describes actions taken in connection with an unauthorized access event, including notifying regulators and working with law enforcement, which is incident-response disclosure. It references the specific party 'Targus' and thus is more than generic boilerplate.


reasoning: The paragraph describes an actual cybersecurity-related incident (unknown persons attempting fraudulent fund access) and provides the detection date and entity reporting it.


reasoning: The paragraph describes a real cybersecurity event (unauthorized activity) with a specific notice date and incident response actions (investigate, contain, remediate), which fits incident disclosure.


reasoning: The paragraph describes response actions (manual transaction processing and alternative distribution channels) taken while systems are being restored, which is indicative of an ongoing or recently occurred disruption. However, it does not provide incident specifics (e.g., date, scope), so confidence is only medium and specificity confidence is low due to lack of uniquely verifiable company facts.


reasoning: The paragraph is primarily generic risk language about IT dependence and potential cyber threats, plus a vague statement that the company monitors and develops its networks to prevent/detect/mitigate unauthorized access. No board/management role is specified and there is no incident narrative, dates, frameworks, or named entities.


reasoning: The paragraph describes S&T’s own incident response and business continuity processes (evaluation criteria, IR program components, training/testing, and continuity restoration). Although it references third-party incidents/vendors, the central focus is the company’s internal risk/incident management program, not vendor-only oversight.


reasoning: The paragraph describes the company’s own cybersecurity processes (threat assessment, layered security, training, standards, penetration testing cadence, monitoring, patching) and how they are adjusted, including governance reporting. While it mentions third parties (penetration testing and SOC-1/SOC-2), the central topic is Black Stone Minerals’ internal risk management program rather than vendor oversight as the primary subject.


reasoning: The paragraph primarily describes BEL FUSE's own cybersecurity and risk-management activities (monitoring, penetration testing, asset protection, access reviews) rather than an incident or standalone strategy disclosure. Although it includes vendor SOC report requirements and limited access, these are incorporated as part of BEL's internal risk-management controls, not vendor oversight as the central topic.


reasoning: The paragraph points to incident-related restoration progress and a timeline for specific systems (Change Healthcare), with a concrete date and exhibit reference. However, it itself does not describe the incident details, so specificity is not fully quantifiable/verifiable beyond the referenced items.


reasoning: The paragraph describes the company’s internal cybersecurity risk management approach, including roles (CISO/CTO), risk assessment/mitigation responsibilities, and how monitoring and incident-response activities are performed within its organization.


reasoning: The paragraph describes Wendy’s own cybersecurity risk management strategy and its operating components (controls framework, assessments, training, and technical protections), which squarely fits Risk Management Process rather than incident disclosure or third-party oversight.


reasoning: The paragraph is centered on Energy Recovery’s internal management structure and responsibilities (named executives/roles and their activities) for informing the Audit Committee and conducting cybersecurity risk monitoring.


reasoning: The paragraph describes the company’s own Cybersecurity Program, including its incident response plan and how roles/committees administer and oversee cyber risk processes. It contains multiple firm-specific entities and quantified experience details (e.g., named executives, IT Steering Committee, IT Manager, General Counsel experience), making it Firm-Specific rather than generic boilerplate.


reasoning: The paragraph describes the company’s own cybersecurity program elements (governance/ERM interaction, incident response planning, training, and risk-based management of cybersecurity risks), which is internal risk management rather than a standalone incident or pure third-party oversight.


reasoning: The paragraph makes a standalone materiality/disclosure statement about fiscal 2024 cybersecurity risks not materially affecting Oracle’s strategy, operations, or financial condition, and discusses potential financial/brand impacts. That aligns best with Strategy Integration rather than incident description or internal risk processes.


reasoning: The paragraph is centered on the Board and its Risk Committee performing cybersecurity oversight, including meeting cadence and reporting processes within the company’s ERM program.


reasoning: The paragraph describes the company’s internal cybersecurity risk management program and related policies/processes to mitigate cybersecurity threats and meet regulatory requirements. It does not recount an actual incident, but it focuses on the firm’s own risk management approach with specific regulators named.


reasoning: The paragraph describes the company’s internal, multi-layered cybersecurity risk management program (controls, training, monitoring, resiliency, continuous improvement) integrated into its risk management processes, rather than focusing on an actual incident or standalone board/management roles.


reasoning: The paragraph describes the company’s own cybersecurity risk management processes (controls, testing, monitoring, training) and how they manage/manage risks using an internal team. It only broadly mentions third parties as part of the overall process, not as the central focus.


reasoning: The paragraph describes the company’s internal cybersecurity risk management program (controls, vulnerability assessments, incident response/BCDR planning, and employee training). Although it mentions third parties, vendor oversight is presented as one component of the company’s overall risk management process rather than as the central focus.


reasoning: This paragraph is forward-looking and generic risk-factor language describing potential cyber threats and impacts without discussing Omnitek-specific programs, roles, dates, frameworks, or a real incident. It contains no substantive disclosure beyond broad possibilities (and uses conditional language like “may” and “could”).


reasoning: The paragraph is centered on the Chief Information Officer’s responsibilities, qualifications, reporting/review cadence, and role in managing cybersecurity risk through the Information Security Program and Risk Report.


reasoning: This paragraph is general risk-factor language about cybersecurity threats and potential impacts, with no described incident, dates, named roles, named systems/products, frameworks, or quantified/externally verifiable facts. It primarily cross-references a risk factor for more detail rather than providing substantive disclosure.


reasoning: The paragraph describes the company’s own cybersecurity risk management program (monitoring, vulnerability/threat-intel based refinement, policies, training, and internal/external assessment activities), rather than a board role or a described incident.


content_category: Third-Party Risk

reasoning: The paragraph’s central topic is outsourcing primary cybersecurity governance/operations to a third-party IT and cybersecurity firm (including a vCISO and other team members). It also provides multiple verifiable specifics (e.g., “over 30 years” experience and named certifications), supporting Quantified-Verifiable specificity.


reasoning: The paragraph describes the company’s internal cyber risk identification, mitigation, monitoring, response/recovery planning, and enterprise risk assessment processes. It also references a board share-out but the grammatical subject is the Company’s risk management activities, not board governance.


reasoning: The paragraph describes Riot’s own cybersecurity controls and internal processes (tools like EDR/SIEM, quarantine, backup/recovery, Zero Trust, ransomware defense, and employee notification timelines). Although it mentions third-party services, the central topic is Riot’s internal risk management and security program.


reasoning: The paragraph describes AGM’s internal cybersecurity program and ERM-aligned processes (governance, technical safeguards, vulnerability/threat intelligence evaluation, incident response planning, training, and risk-based third-party risk management) rather than a specific incident or stand-alone materiality conclusion.


reasoning: This paragraph describes FIRST CAPITAL INC’s internal cybersecurity incident response and oversight mechanisms (Agility Plan, CMT, CIO participation, training, audits/vulnerability testing), which are core elements of its risk management process. While it mentions third-party consultants, the central subject is the company’s internal program and processes rather than vendor security oversight.


reasoning: The paragraph describes the Company’s own technological dependencies and susceptibility of its systems to various cyber threats, but it does not describe a distinct internal risk-management program, framework, or incident/event. It is best categorized as risk management process context (threats to systems) rather than incident disclosure or third-party risk.


reasoning: The paragraph describes the company’s own cybersecurity risk management activities (controls, safeguards, incident response/recovery planning, and training), rather than an actual incident or board/management role. While it mentions third parties, vendor oversight is presented as part of the company’s internal risk management process, not as the central focus.


reasoning: The paragraph is primarily forward-looking risk and impact language and discusses maintaining processes to manage cybersecurity threats, but it does not describe actual incidents or any company-specific programs, roles, frameworks, or named systems. Its broad internal-process phrasing most closely fits Risk Management Process, though it is largely generic.


reasoning: The paragraph discusses use of an incident response plan (IRP) and general types of cybersecurity incidents (directed attacks, misuse/unauthorized disclosure, account takeovers) but provides no firm-specific details, dates, named systems, or named frameworks. It is primarily about internal response/process at a high level, not an actual incident disclosure.


reasoning: The paragraph describes oversight responsibilities of the Board of Directors and the Audit Committee for reviewing and assessing cybersecurity risks, which is board/committee governance content.


reasoning: The paragraph describes Bowman’s own cybersecurity monitoring, incident response planning, and vulnerability/threat-related practices, i.e., internal risk management processes. Although it mentions third-party services and experts, they are supporting elements within the company’s risk management program rather than the central topic.


reasoning: The paragraph primarily describes the company’s internal cybersecurity and risk management processes (training, monitoring, incident response, escalation, ERM integration, and supplier risk management). While board/Audit Committee oversight is included, it is supporting context for the overall program processes rather than being the sole focus.


reasoning: The paragraph centers on how cybersecurity responsibilities are owned and described within management (technology group leadership, CISO existence/credentials, and operational team coverage), rather than on an external incident or vendor oversight.


reasoning: The paragraph describes the company’s internal cybersecurity and risk-management processes (monitoring, encryption, access controls, vulnerability scanning, penetration testing, disaster recovery) and related governance mechanisms like a third-party risk register, rather than a discrete incident or board/management role.


reasoning: The paragraph primarily describes the company’s internal governance and incident response planning processes (risk assessment, committee cadence/updates, and an incident response plan). While it includes the CTO’s role/credentials, the central topic is the organization’s internal security governance and risk-management functions.


reasoning: This paragraph describes the company’s own internal cybersecurity risk assessment and management program (processes/technology to manage and maintain security). It also contains largely standard materiality disclaimer language without firm-unique operational details beyond generic threat categories.


reasoning: The paragraph describes USCF’s own information security program and recurring risk evaluation plus mitigation activities (due diligence) as part of cybersecurity risk management, rather than being centered on a standalone incident or purely vendor-contract requirements.


reasoning: The paragraph describes Northern Trust’s internal cybersecurity/technology risk management program, policies, governance processes, and how risk is managed (including integration with ERM). Vendor controls are mentioned only as part of the company’s broader risk management program, not as the central third-party oversight topic.


reasoning: The paragraph describes the company’s internal cybersecurity risk management approach (policies, processes, assessing and managing risks, investing resources) rather than an actual incident or board oversight details as the central topic. It uses generic language with no company-specific systems, roles, dates, metrics, or named external standards.


reasoning: The paragraph describes Cohen & Steers’ internal cybersecurity safeguards and how they manage and mitigate cyber risk (monitoring, encryption, incident response, training, risk assessments, vendor risk management, continuity, and cyber insurance). It is not centered on a specific third-party oversight activity or an actual incident event.


reasoning: The paragraph identifies cybersecurity leadership roles (CISO, Information Security Team, and the Company’s CCO) and describes their responsibilities and qualifications, including quantified tenure/experience and specific certifications/education.


reasoning: The paragraph centers on named management roles (CTO/CIO/CISO), their responsibilities, and their experience qualifications, with detailed operational elements (e.g., a 24/7 third-party SOC). Although it also mentions Board reporting, the grammatical and substantive focus is the management roles and their qualifications.


reasoning: The paragraph primarily describes Embecta’s own cybersecurity monitoring, control assessment, penetration testing, and risk management/committee governance processes. While it mentions vendors, third-party risk is presented as part of Embecta’s internal risk management program rather than as the central standalone topic.


reasoning: The paragraph describes the company’s own cybersecurity risk management approach (policies, standards, processes, resources, investments) and oversight, without describing a specific incident or naming particular roles, systems, dates, or frameworks.


reasoning: The paragraph defines information security risk and describes having implemented processes to identify, assess, and manage cybersecurity risks impacting business strategy and financial condition, which is characteristic of internal risk management.


reasoning: The paragraph primarily describes Schwab’s internal cybersecurity and risk-management program elements (ERM integration, monitoring, authentication, training, external assessment). Although it starts with board oversight and a named Risk Committee, the bulk of the content focuses on management processes and the company’s own cybersecurity risk controls.


reasoning: The paragraph describes the Company’s internal cybersecurity program, including risk assessment, controls, monitoring, employee reporting, metrics, and periodic review by specific internal leaders (CIO/CISO). It is not an incident narrative and third-party/vendor oversight is not the central topic.


reasoning: The paragraph describes the company’s own cybersecurity risk assessment, monitoring, incident management, remediation, and how executives/audit committee evaluate material risks—i.e., internal risk management processes. Third-party diligence is included only as part of those internal steps, not as the central focus.


reasoning: The paragraph describes MEG’s own incident response planning and execution (IRP, responsibilities, escalation and reporting procedures, and supporting internal/process steps), which is a risk management process. While it mentions third parties, the central topic is how MEG organizes and runs incident response within its program.


reasoning: The paragraph describes the company’s internal cybersecurity risk management activities (information security program, governance committee, monitoring/detection controls, and due diligence/risk management). Although it references third-party risk, the central topic is the company’s overall cybersecurity risk management program rather than vendor oversight alone.


reasoning: The paragraph primarily describes Ardent’s own internal process and controls (IT review/approval, cybersecurity team assessments, use of FAIR, response plan updated annually, incident response team escalation), i.e., a risk management process. While it references third parties, vendor oversight is presented as one component of Ardent’s internal risk management.


reasoning: The paragraph centers on named individuals (Luca Fabbri and Christine Garrison) describing their responsibilities and qualifications for overseeing cybersecurity risk management and incident reporting, plus concrete experience dates.


reasoning: The paragraph describes WTW’s own cybersecurity risk management strategy and operational processes (incident response planning, technical safeguards, training, third-party risk process, and threat intelligence). It is not an incident narrative or a standalone materiality conclusion, and third-party security is addressed as part of WTW’s internal risk management.


reasoning: This paragraph describes the company’s own incident response and testing/escalation procedures as part of its cybersecurity risk management program, not an actual incident or vendor oversight.


reasoning: The paragraph provides a standalone materiality conclusion about not experiencing material cybersecurity incidents and not being aware of reasonably likely material effects, along with generic forward-looking references to possible impacts and insurance coverage without incident narrative or named entities.


reasoning: The paragraph describes the company’s internal cyber security governance and operational processes (security programs, monitoring, incident reporting/severity classification, incident response escalation, and risk/materiality assessment). It does not center on an actual incident event or third-party/vendor requirements, so it best fits Risk Management Process.


reasoning: The paragraph centers on the Audit Committee and how Kroger’s Board is briefed and oversees cybersecurity (cadence, reporting, independent reporting, outside counsel). It includes Kroger-specific roles (CIO/CISO) and a named artifact (NIST Cybersecurity Framework Scorecard), making it firm-specific.


reasoning: The paragraph’s grammatical subject is board oversight and the Audit Committee’s delegated responsibility for cybersecurity risk management, with ongoing board-committee reporting cadence. It also includes company-specific roles (Director of IT, cybersecurity team) and quarterly reporting to the Audit Committee.


reasoning: The paragraph’s central focus is oversight of cybersecurity risks posed by third-party providers via a vendor management program with audits and contractual cybersecurity obligations, which fits Third-Party Risk. It does not name specific tools, dates, vendors, or quantitative measures, so specificity is limited despite being relatively detailed.


reasoning: The paragraph is purely forward-looking safe-harbor and disclaimer language referencing general concepts like future recovery timing and the presence of “Risk Factors,” without describing any specific cybersecurity incident facts or internal process details.


reasoning: The paragraph describes the company’s internal incident response/disaster recovery process, including escalation to a Crisis Management Team and oversight/assurance activities (audits, vulnerability assessments, penetration testing). It also identifies the CIO and information security/technology teams, making it firm-specific, but it does not provide enough independently verifiable metrics (dates, amounts, named vendors/tools) for quantified-verifiable specificity.


reasoning: The paragraph is centered on the Board and specifically the Audit Committee’s oversight activities, including annual reviews and what they cover (cyber program, insurance, and advisor reporting). It includes firm-specific roles and named entities (Audit Committee, Advisor, and CTO for Cohen & Steers).


reasoning: This paragraph describes Grindr’s internal cybersecurity risk management measures (e.g., incident response plan, vulnerability management, audits, DR/BC, training, red/blue team, vendor risk management program) rather than an actual incident or board/management role. It is not firm-unique at the level required for Firm-Specific/Quantified-Verifiable because there are no named roles, dates, products, vendors, or uniquely identifiable organizational details beyond generic program elements.


reasoning: The paragraph discusses the company’s current approach (no formal cybersecurity policies/training and no dedicated personnel) and intent to develop a framework, but it provides no firm-specific names, dates, or frameworks.


reasoning: The paragraph primarily describes Alternus’s internal cybersecurity program processes (assessment, prevention/detection/response/recovery, asset identification, and risk management). While it references third-party controls (SOC 2 reports and provider risk assessments), those are integrated as part of the company’s overall risk management approach rather than being the central oversight function.


reasoning: The paragraph describes a real cybersecurity incident (defaced website), includes concrete actions taken (restoring, taking site down), names the affected domain (wytecintl.com), provides a specific cancellation date, and reports engagement with forensic specialists and the FBI—hallmarks of incident disclosure.


reasoning: The paragraph is a materiality/impact statement about cybersecurity incidents not identified as materially affecting the company, with no description of an actual incident. It references third-party vendors only as general possibility, not as a specific vendor-risk oversight program.


reasoning: The paragraph describes the company’s internal cybersecurity/risk control assessment and review workflow (audit/risk assessments, remediation plans, ongoing quarterly review) and names company executives/committee involved. Although it references external firms and an MSSP, the central focus is the company’s own assessment and remediation process.


reasoning: The paragraph describes a specific, actual cybersecurity incident (unauthorized third-party access and file exfiltration) and includes response/impact details such as system shutdowns, reporting-system disruption, restoration, and intended notifications/regulatory reporting.


reasoning: This paragraph describes a specific cybersecurity incident update with concrete details about perpetrator status, scale of affected accounts, data handling outcome, and quantified customer compensation (amounts, dates, and accounting treatment).


reasoning: This paragraph describes a specific cybersecurity incident, including a dated threat-actor email, alleged data accessed/exfiltrated from specific systems, extortion demand, and concrete response actions (termination, fraud monitoring, customer warnings, law-enforcement cooperation).


reasoning: The paragraph describes a real cybersecurity incident, including the date detected, the nature of unauthorized access and encryption, third-party exfiltration, business/application impacts, and concrete response actions (IR plan activation, system shutdowns, law enforcement notification, investigation with external experts).


reasoning: The paragraph is focused on cybersecurity risk assessment and potential costs/impacts, but it does not describe AFG-specific processes (e.g., controls, frameworks, or reporting structures) beyond generic acknowledgments and conditional language.


reasoning: The paragraph is centered on oversight and reporting lines between the Board/Audit Committee and executive roles (CISO/CIO/CTO) regarding the cybersecurity program, which is board governance content.


reasoning: The paragraph centers on oversight/approval by the Board of Directors (risk appetite metrics for cybersecurity), which is board governance. However, it contains no firm-unique roles, names, dates, or frameworks, so it is largely generic boilerplate.


reasoning: The paragraph describes the company’s internal handling of a cybersecurity threat (triage/investigation, potential system isolation, and escalation to the ISC), which is part of its risk management/incident assessment process rather than an actual incident or third-party oversight as the central topic.


reasoning: The paragraph describes an internal information security training program as part of cybersecurity risk management, but it contains no firm-specific details, named roles/systems, dates, or frameworks—making it generic.


reasoning: The paragraph describes the company’s internal cybersecurity safeguards, vulnerability/threat-intelligence activities, and its incident response plan and testing cadence, which are core risk management process elements.


reasoning: The paragraph describes JetBlue’s overall cybersecurity strategy and emphasizes detection/analysis/response, cyber risk management, and resilience, which fits an internal risk management process. However, it contains no named roles, frameworks, systems, dates, or other firm-specific verifiable details beyond generic statements.


reasoning: The paragraph describes the company’s internal procedures and policies for identifying, preventing, detecting, and mitigating cybersecurity risks as part of its enterprise risk management. While it mentions supplier/customer relationships, the emphasis is on ENDRA’s own risk management processes rather than vendor security oversight as the central topic.


reasoning: The paragraph is centered on CORPAY’s oversight and assessment of cybersecurity risk from third-party service providers (selection questionnaires and annual third-party risk assessments tied to contractual obligations). It does not describe the company’s board or management roles or an internal ERM process beyond third-party oversight.


reasoning: The paragraph describes the company’s internal cybersecurity program and how it is integrated into its enterprise risk management framework, including assessments, testing, training, and monitoring. Although it mentions third-party involvement, the central focus is the company’s own risk management process rather than vendor oversight as a standalone topic.


reasoning: The paragraph centers on using third-party service providers to support cybersecurity risk identification, assessment, and management, and explicitly lists types of vendors/services involved.


reasoning: The grammatical subject is the CISO and VP of Information Security, describing their experience and security-related responsibilities, which is management-role disclosure rather than a risk process or incident description.


reasoning: The paragraph describes the company’s incident response plan and what it includes (immediate mitigation, remediation, prevention). It does not narrate a specific past incident, nor does it provide firm-unique details beyond generic references to the CEO and long-term remediation.


reasoning: The paragraph addresses the absence of internal processes for assessing and managing material cybersecurity risks, including risks involving third parties. However, it contains no firm-specific details, named frameworks, or verifiable facts.


reasoning: The paragraph describes the company’s internal processes and team involvement in onboarding new products/projects and vendors via its own Project Management Office and Vendor Management Office, which fits risk management process oversight rather than a stand-alone third-party risk focus.


reasoning: This paragraph is explicitly about the board-level Risk Committee’s oversight responsibilities for cybersecurity and its interaction with management, including engagement under the Cybersecurity Incident Response Plan.


reasoning: The paragraph describes the company’s internal cybersecurity practices (awareness training, phishing testing, mandatory training, and newsletters) and mentions cyber insurance as part of risk management, but it includes no firm-specific details, named frameworks, or verifiable facts.


reasoning: The paragraph centers on who (specific management roles including the CISO and other named executives) oversees and participates in the company’s cybersecurity risk management.


reasoning: The paragraph is centered on how the board of directors conducts meetings and reviews cybersecurity risk with management, describing oversight cadence (annual/periodic) and review activities. It contains no Lipocine-specific named roles, systems, dates, metrics, or frameworks beyond generic references to KPIs and enterprise risk profile.


reasoning: The paragraph is explicitly about the Board of Directors’ oversight, review cadence, and discussions with management regarding cybersecurity and breach response. It contains no company-specific named roles, dates, systems, or external frameworks, making it generic boilerplate.


reasoning: The paragraph is explicitly about the Audit Committee’s role and oversight of cybersecurity risks, including receiving updates and ensuring incident communication, which fits Board Governance.


reasoning: This paragraph is a generic description of the company’s business status and risk stance, with no board/management role, incident narrative, or described internal risk management processes or standards beyond blanket statements; it does not disclose substantive cybersecurity actions or specific events.


reasoning: The paragraph describes the company’s internal security and vulnerability/patching approach plus its incident response and disaster recovery planning, which are core risk management processes. It contains no firm-specific roles, named systems, dates, tools, or frameworks beyond generic “industry best practices.”


reasoning: The paragraph provides a materiality conclusion about no currently known cybersecurity incidents that are required to be reported, and includes forward-looking discussion linking cyber risk to business strategy/results/financial condition without describing an actual incident.


reasoning: The paragraph describes the company’s internal cybersecurity risk management objectives and improvement initiatives, including review and oversight of the processes. While it includes some specific organizational details (Technology Leadership Centre and supervision by the Chief Technology Officer), it does not provide enough independently verifiable quantitative details for Quantified-Verifiable.


reasoning: The paragraph primarily describes who is responsible for cybersecurity (management led by the IT department) and the role of a Software Engineer in executing the cybersecurity strategy. While it also mentions internal activities like vulnerability assessments and monitoring, the main grammatical focus is organizational responsibility and roles.


reasoning: This is a standalone materiality/likelihood statement about cybersecurity threats’ potential impact on business strategy, results of operations, and financial condition, with no incident narrative or firm-specific details.


reasoning: This paragraph is generalized risk-factor boilerplate with conditional language and a cross-reference to Item 1A; it does not describe specific internal processes or an actual incident, nor does it name a management role, board committee, framework, date, system, or third-party security standard.


reasoning: The paragraph discusses general limitations and describes a risk-based approach to selecting security controls, but it does not include any incident description or firm-specific details. It is best treated as a generic statement about the company’s internal security risk management approach.


reasoning: The paragraph describes general limitations of the company’s security controls and mentions a risk-based approach to selecting controls, but it provides no specific program, framework, dates, roles, or measurable facts.


reasoning: The paragraph describes the company’s internal cybersecurity risk assessment and mitigation activities (monitoring, assessments, testing, policy, training, and insurance), which fits the Risk Management Process category. It references external standards/laws (CIS and FERPA) but does not include firm-unique or independently verifiable details like named roles, dates, systems, or dollar amounts.


reasoning: The paragraph identifies specific management roles (CIO, CTO, and Information Security Officer) and assigns them accountability for information security and related activities.


reasoning: The paragraph describes the company’s internal cybersecurity program activities (e.g., evaluating effectiveness via table-top exercises), with third-party providers mentioned only as support. However, it contains no firm-specific names, dates, roles, tools, or measurable facts.


reasoning: The paragraph describes Arrow’s internal cybersecurity risk management program governance and roles, including an enterprise risk management group, rather than an actual incident or vendor oversight.


reasoning: The paragraph describes the company’s internal incident response and vulnerability management escalation and reporting process, including who is engaged and how incidents are handled. It is not an incident narrative or a third-party/vendor oversight topic.


reasoning: The paragraph describes EMCOR’s own cybersecurity program and internal governance/teams for prevention, detection, remediation, and incident response—core elements of its risk management processes, not an actual incident or third-party oversight.


reasoning: The paragraph describes BlackRock’s internal cybersecurity program and processes (governance, safeguards, incident response/recovery planning, and ERM-integrated third-party risk management). Although it mentions third-party risk, the central topic is the company’s own risk management program and controls rather than vendor oversight as the stand-alone focus.


reasoning: The paragraph describes governance and reporting to the Audit Committee and full Board of Directors regarding cybersecurity incidents, including who informs them (CFO and General Counsel). It clearly contains company-specific roles and reporting relationships.


reasoning: The paragraph describes the company’s own cybersecurity monitoring and testing approach (audits, regulatory exams, vulnerability/penetration testing, patching, and SOC log monitoring), which are internal risk management processes. Third parties are mentioned as components supporting those internal programs rather than as the central subject (e.g., no vendor security requirements are the main focus).


reasoning: The paragraph is explicitly about the Audit Committee’s role and reporting/oversight cadence for cybersecurity risk, including receiving reports from the CISO and aligning with a named Cybersecurity Incident Response Plan.


reasoning: The paragraph’s main focus is PSCM’s controls imposed on vendors (due diligence plus contractual encryption in transit/at rest and user access controls), which is central to third-party risk. It also includes a standalone materiality statement, but the vendor requirements drive the categorization.


reasoning: The paragraph identifies specific management roles (SVP/IT Manager and ISO) as responsible for day-to-day coverage and describes the ISO’s qualifications and experience, which is management/role-focused rather than a process or incident narrative.


reasoning: The paragraph describes Teladoc Health’s internal cybersecurity program and how it is reviewed/assessed, along with the frameworks it uses for managing cyber risks. While it includes firm-relevant certification/compliance statements, it does not provide multiple uniquely verifiable factual details like dates, dollar amounts, or specific external issuer names.


reasoning: The paragraph describes the company’s own technical safeguards and how they are intended to protect information systems, which fits internal risk management activities rather than board oversight or an incident narrative.


reasoning: The paragraph primarily describes the company’s internal risk management processes (assessing material risks, controls, and mitigation) and includes third-party risk as part of that broader program. It does not focus solely on vendor oversight requirements, and it contains no firm-unique roles, dates, or quantified facts.


reasoning: The paragraph is a standalone materiality/impact statement about whether cyber-attacks have materially affected the company’s strategy, operations, or financial condition, with no incident narrative. It also includes a cross-reference to Item 1A, but no specific company facts, roles, dates, frameworks, or metrics.


reasoning: The paragraph describes the company’s internal enterprise risk management approach for cybersecurity risk (identification/assessment/monitoring and mitigation measures), rather than an incident or third-party oversight.


reasoning: The paragraph describes general due diligence and contract provisions during third-party procurement, but does not name any specific third parties, frameworks/standards, roles, or company-specific details. It reads as generic risk management language rather than a central third-party risk oversight disclosure.


reasoning: The paragraph focuses on Berkshire’s dependence on third-party service providers and the risks arising from cyber-attacks at those providers, plus monitoring of service-provider risk. It contains no firm-specific identifiers, dates, tools, or metrics, making it generic.


reasoning: The paragraph’s main focus is oversight of cybersecurity practices for vendors, including reviewing service organization controls reports and using third-party testing. This is vendor/supplier security management rather than the company’s internal risk processes.


reasoning: The paragraph centers on the individuals and roles responsible for cyber risk (CCO and CISO), including qualifications and reporting/assistance relationships. It also provides verifiable facts such as the CISO start date (May 2024) and experience durations (over thirty years, three years, sixteen years).


reasoning: The paragraph describes the company’s own cybersecurity program and risk management practices (controls such as segmentation, access controls, monitoring, patch management, and use of managed security services) rather than an actual incident or purely board oversight.


reasoning: The paragraph is centered on the CISO’s qualifications, responsibilities, reporting line to the COO, and accountability for a security Program, plus the COO’s board committee involvement.


reasoning: The paragraph describes general security program activities (penetration testing, measuring a program, and incident response preparedness) rather than an incident or a board/management role. References to third parties (assessors, incident response experts, counsel) are part of implementing the company’s overall risk management process, not the central focus as a third-party risk program.


reasoning: The paragraph focuses on a named board-level subcommittee (Cyber Security Subcommittee) and its governance/assessment and escalation process to executive leadership upon a likely incident.


reasoning: The paragraph describes the company’s internal incident response planning, assignment/escalation flow, and decision-making on reporting/notification—i.e., an internal risk/incident management process rather than an actual disclosed incident or vendor oversight.


reasoning: The paragraph centers on oversight and review activities by the Audit Committee (including annual review of internal audit results) and annual reporting to the CEO/CFO, which is board governance rather than a process description.


reasoning: The paragraph identifies the CIO as leader of the Information Security Department and describes reporting lines and responsibilities, which are management-role disclosures. It includes firm-specific organizational details (CIO, President/CEO reporting and security-program leadership).


reasoning: The paragraph is generic conditional risk/disclaimer language about not experiencing attacks and potential adverse effects, without describing a real incident, named entities, frameworks, roles, dates, or verifiable specifics.


reasoning: The paragraph is explicitly about a named board committee (Technology Committee), its meeting cadence, and its oversight responsibilities for cyber and related security and resiliency planning.


reasoning: The paragraph describes the company’s own cybersecurity risk management activities (policies, monitoring, training, and risk assessment) rather than a board role or an actual incident. It contains no uniquely identifying company facts (e.g., named roles, dates, systems) or external verifiable details, but it is more than pure boilerplate.


reasoning: The paragraph identifies a specific management role (VP of IT and Facilities) and describes its responsibilities related to budgeting and cybersecurity incident preparation, processes, and reporting. It is not board oversight, an internal risk process description generally, or a standalone incident narrative.


reasoning: The paragraph is centered on the Audit Committee’s oversight, reporting, and notification cadence to the Board, which is board-governance content. However, it contains no firm-specific details beyond generic committee oversight language, and it uses conditional phrasing ('if any'), so it fits the Generic Boilerplate specificity level.


reasoning: The paragraph describes executive management’s responsibility for overseeing cybersecurity strategy, but it provides no named roles, committees, frameworks, dates, systems, or other firm-unique details beyond generic statements.


reasoning: The paragraph describes (hypothetically) what a risk assessment policy/process would include and states no such integrated process currently exists. It does not mention any company-specific roles, dates, systems, tools, or external standards, making the content generic.


reasoning: The paragraph centers on the CISO’s reporting/interaction responsibilities (cybersecurity updates to the IOC and executive sessions) and the internal team that supports day-to-day cybersecurity operations, which is management-role content rather than board oversight or a described risk process alone.


reasoning: The paragraph describes the company’s own cybersecurity risk management program and how it operates (annual risk assessments, controls, monitoring, testing, and program effectiveness). Although it includes third-party risk components, the central focus is internal risk management processes rather than vendor oversight alone.


reasoning: This paragraph describes a named governance body (Cybersecurity Council) chaired by the CISO with defined meeting frequency, reporting/escalation mechanisms to senior management and the Board, and specific council composition.


reasoning: The paragraph describes internal activities for monitoring threats and mitigating vulnerabilities, which fits the company’s risk management process, but it contains no firm-specific names, roles, dates, systems, or verifiable details beyond general description.


reasoning: The paragraph describes the company’s internal security program (a dedicated cyber security center and monitoring/detection/response capabilities) and ongoing processes. Mentions of third-party consultants and external organizations are supportive rather than the central focus, so it is best categorized as internal risk management/process.


reasoning: The paragraph describes the company’s internal cybersecurity risk management activities (awareness/training, policy updates, and testing of security controls). It contains no named roles, dates, products, frameworks, or uniquely verifiable company-specific facts, so it is treated as generic boilerplate despite being process-focused.


reasoning: The paragraph describes the company’s internal security and oversight processes (monitoring, flaw correction, backups, physical protection, and IT security department review) to manage cybersecurity risk.


reasoning: The paragraph describes the company’s internal incident detection/triage/escalation workflow and links it to its IT Security Incident Response Policy and leadership team, which is an internal risk management process rather than a disclosed incident or vendor-focused topic.


reasoning: The paragraph describes general cybersecurity risks, potential impacts, and a standalone materiality conclusion that threats have not materially affected the company, aligning with Strategy Integration. It contains no named entities, frameworks, dates, roles, or verifiable facts, making it generic boilerplate.

provider: x-ai


reasoning: This paragraph provides a standalone materiality conclusion stating that cybersecurity risks have not materially affected the company to date, with a cross-reference to risk factors, fitting Strategy Integration per guidelines. No incident narrative or other processes are described, and it lacks any specific facts, frameworks, or unique details.


reasoning: Paragraph describes the company's internal multi-stakeholder team, monitoring methods, and investments for assessing and managing cybersecurity risks, fitting Risk Management Process; vendors are components of internal processes, not central (per tiebreaker). Team's specific departmental composition is a firm-unique fact, qualifying as Firm-Specific with no frameworks or additional verifiable facts.


reasoning: The paragraph focuses on the Audit Committee's oversight of cybersecurity risks, including reports from specific committees and roles, making Board Governance the clear fit as the board/committee is the grammatical subject. Organizational structure with named committees and roles qualifies as Firm-Specific, but lacks two+ externally verifiable facts like dates or amounts for higher specificity.


reasoning: The paragraph describes the company's internal risk management processes, including ERM integration, annual ERA, risk prioritization into 12 categories, mitigations, quarterly monitoring, and reporting, making 'Risk Management Process' the clear fit. It contains multiple verifiable facts like named programs (ERM, ERA), quantified categories (12), and specific cadences (annual, quarterly), exceeding Firm-Specific for Quantified-Verifiable.


reasoning: The paragraph primarily describes the company's own risk management program, integration into ERM, use of frameworks, periodic reviews, and cross-functional approach to cybersecurity, making 'Risk Management Process' the most applicable category. Board oversight and management roles are mentioned but are components of the overall internal processes rather than central subjects.


reasoning: The paragraph centers on the Board's oversight of cybersecurity risks, including briefing cadence, incident reporting thresholds, and annual discussions, with the Board as the grammatical subject throughout. No frameworks, named roles/committees/teams beyond generic titles, dates, or verifiable facts are present, rendering it generic boilerplate.


reasoning: This is a cross-reference to the Risk Factors section (Item 1A) with a quoted generic boilerplate risk statement, providing no substantive cybersecurity disclosure on governance, processes, incidents, or strategy.


reasoning: The paragraph centers on engaging third-party service providers for cybersecurity risk assessment, design, monitoring, and testing, with detailed requirements imposed on them such as certifications for security measures and breach reporting, fitting Third-Party Risk per tiebreaker for requirements on vendors. No incident narrative or other category dominates; the materiality statement is secondary.


reasoning: Paragraph details the company's own processes for risk assessment, identification, management, and ERM integration, with third-party threats as a minor component, fitting Risk Management Process per tiebreakers. 'Material Risks & Integrated Overall Risk Management' appears to be a unique named team or program, qualifying as Firm-Specific, though borderline on whether it's definitively a proper noun.


reasoning: The paragraph centers on the Bank's management roles, specifically identifying the ISO and CRO, their reporting line, qualifications, and oversight responsibilities, matching the Management Role category. It contains firm-unique facts like named roles, reporting structure, and the ISO's experience, qualifying as Firm-Specific but not Quantified-Verifiable due to lacking two externally verifiable metrics like dates or dollar amounts beyond organizational details.


reasoning: The paragraph details the company's own internal Information Security programs, framework adoption (ISO and NIST), and processes for identifying, protecting, detecting, responding, and recovering from risks to IT systems and data, fitting Risk Management Process. It names frameworks but lacks firm-unique facts like roles, committees, dates, or quantifiable details.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risk management, including review cadence and discussions with management like the CIO and CISO, fitting Board Governance as the board committee is the primary subject. It names the Audit Committee and specific roles (CIO, CISO), making it Firm-Specific with no additional verifiable metrics like dates or amounts for higher specificity.


reasoning: The paragraph centers on the Board of Directors' oversight role, assessment of risks, and interactions with the HSE Director, making Board Governance the primary category as the board is repeatedly the grammatical subject. It describes board responsibilities, briefing cadence, and oversight of the cybersecurity program.


reasoning: Paragraph centers on board and Audit Committee oversight of cybersecurity risks, including briefing cadence from named roles, directly matching Board Governance criteria where board/committee is the grammatical subject. Contains unique named committee and roles, qualifying as Firm-Specific per decision test (firm-unique facts present, but not 2+ externally verifiable like dates/amounts).


reasoning: The paragraph describes the company's internal cybersecurity processes including incident response planning, testing, training, mitigation measures, risk assessments, threat modeling, vulnerability scanning, and penetration testing, with the company's own processes as the central topic. No specific frameworks, named roles, committees, dates, systems, or verifiable facts are mentioned, making it generic boilerplate.


reasoning: Paragraph details the company's internal processes for risk identification, assessment, monitoring threat intelligence, evaluating controls, and mitigating third-party risks as one component, aligning with Risk Management Process; vendors are not central. Includes one firm-unique fact: the dedicated InfoSec team.


reasoning: The paragraph details the company's own internal processes for cybersecurity risk management, including framework adoption (NIST), dedicated team, assessments, monitoring, cross-departmental integration, and ERM incorporation, making Risk Management Process the best fit; third-party involvement is a minor component, not central. It includes firm-specific facts like the named policy, team composition, and quarterly reviews, but lacks two+ externally verifiable facts like dates or named firms, so Firm-Specific.


reasoning: This paragraph delivers a standalone materiality conclusion, stating no material impact from prior incidents while noting future risks reasonably likely to have material effects, which aligns with Strategy Integration. It lacks any incident narrative or description of specific processes, governance, or third-party risks.


reasoning: The paragraph details the Trustee's internal cyber risk management program, including identification, assessment, mitigation, protocols like passwords and training, integration into overall risk management, and annual third-party assessment, fitting Risk Management Process as it focuses on the company's own processes with vendors as a minor component. No named frameworks, roles, committees, dates, systems, or quantifiable metrics are present, making it Generic Boilerplate.


reasoning: The paragraph centers on the Audit Committee's oversight of cybersecurity risks, including monitoring via reports and quarterly reporting to the full Board, with the committee and Board as grammatical subjects, fitting Board Governance. It includes the named Audit Committee and specific quarterly cadence as firm-unique facts, making it Firm-Specific.


reasoning: Paragraph describes the company's own internal processes for threat identification, investigation, risk assignment, escalation, and reporting, central to Risk Management Process. Contains multiple firm-unique elements like named roles and committees, but no two+ externally verifiable facts like dates or amounts beyond organizational structure, so Firm-Specific.


reasoning: The paragraph details the company's internal cybersecurity processes, including vulnerability management, 24/7 monitoring via a managed service provider, and an NIST-based incident response plan with escalation paths, centrally focusing on Risk Management Process rather than vendor oversight or board roles. It names the NIST framework (sector-adapted) and Audit Committee (firm-specific), meeting Firm-Specific criteria with at least one unique company fact but lacking two+ verifiable facts like dates or amounts.


reasoning: Paragraph focuses on the identification, qualifications, reporting lines, and team oversight of the company's CDIO/CISO, which directly matches the Management Role category definition.


reasoning: The paragraph details the company's internal policies, procedures, risk assessments, controls, and use of specific security frameworks, which aligns with Risk Management Process; third-party involvement is a component of internal assessments, not the central topic.


reasoning: The paragraph details the company's own internal processes such as incident response plans, tabletop exercises, business continuity plans, employee training, and risk-based security controls, which aligns with Risk Management Process. It contains no named frameworks, roles, committees, dates, systems, or other verifiable firm-specific facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph focuses on the Board's and Audit Committee's oversight of cybersecurity risks, including the formation and charter requirements of a specific Cybersecurity Risk Subcommittee, making Board Governance the clear fit. It contains firm-unique elements like named committees and subcommittee headcount, qualifying as Firm-Specific but not Quantified-Verifiable as it is primarily organizational structure.


reasoning: The paragraph details the company's own internal processes for cybersecurity incident identification, monitoring via tools like SIEM with behavioral analytics, and periodic testing including third-party penetration tests, which aligns with Risk Management Process; third-parties are a component of internal processes, not central. No named frameworks, roles, dates, systems, firms, or quantifiable metrics are present, making it generic boilerplate applicable to any company.


reasoning: The paragraph details specific management roles (VP IT Data Security reporting to CTO), a management Cybersecurity Committee with named team composition, and departmental leadership, aligning most closely with 'Management Role' despite an initial mention of Board oversight. Board responsibility is brief and not the primary focus.


reasoning: The paragraph primarily describes the board of directors and audit committee's oversight responsibilities for cybersecurity risks and incidents, with management roles mentioned in the context of reporting and program leadership to the committee. This fits Board Governance as the board/committee is the key grammatical subject for oversight, though management roles introduce some overlap with Management Role.


reasoning: The paragraph centers on the Board of Directors and Audit Committee as the subjects overseeing cybersecurity risks, receiving quarterly reports, and escalation processes, directly matching Board Governance criteria. Firm-specific facts include the named Audit Committee and reporting to named executive roles CEO and CFO.


reasoning: The paragraph centers on the CIO and senior leaders as grammatical subjects, detailing their review processes, reporting lines to named committees, and leadership of the incident response plan, which matches Management Role. Organizational structure with named roles and committees qualifies as Firm-Specific but not Quantified-Verifiable per guidelines.


reasoning: The paragraph centrally describes oversight of third-party providers, vendors, and consultants, including security assessments, contractual requirements, and penetration studies, making vendor/supplier security the primary focus per category guidelines and tiebreakers for requirements imposed on vendors.


reasoning: The paragraph emphasizes the Board and Audit Committee's active involvement in oversight of the cybersecurity program, making board/committee the grammatical subjects fitting Board Governance. It includes a named committee and NIST framework, qualifying as Firm-Specific per decision test (firm-unique fact present).


reasoning: The paragraph details the IT Department's internal cybersecurity risk management processes, including detection, assessments, penetration testing, vulnerability management, and NIST framework adoption, with third-party due diligence as one component among many, fitting Risk Management Process per tiebreakers. It includes firm-specific elements like OFS Advisor and IT Department, plus a named framework, but lacks two+ externally verifiable facts like dates or amounts, making it Firm-Specific.


reasoning: The paragraph details the company's internal information security program, incident detection/response process, operational plans, reviews, and exercises, which aligns with Risk Management Process as it focuses on their own processes. It names the NIST CSF framework but lacks any firm-specific facts like roles, dates, or unique details, resulting in Sector-Adapted specificity.


reasoning: Paragraph details a real past cybersecurity incident with date, scope (unauthorized access to user data on 23andMe.com), and specific response actions (password resets, 2FA, Security Operations enhancements), matching Incident Disclosure. Contains two verifiable facts (date and named system), qualifying as Quantified-Verifiable.


reasoning: The paragraph describes the Board's and Audit Committee's oversight of cybersecurity risks, including delegation to the named Cybersecurity Subcommittee established in 2023, making Board Governance the clear fit as board/committees are the grammatical subjects. It contains firm-unique facts like the named Cybersecurity Subcommittee and 2023 establishment date, but only one verifiable date without additional quantified metrics, named firms, or products, so Firm-Specific.


reasoning: The paragraph focuses on the identification, qualifications, experience, certifications, and reporting lines of management roles like the CISO, CITO, and CEO, directly matching the 'Management Role' category. It contains multiple firm-unique facts such as named roles (CISO, CITO), quantified experience (17 years), specific degrees, and detailed reporting structure, qualifying as Firm-Specific but not Quantified-Verifiable due to lack of two+ externally verifiable metrics like dates or named third-party engagements.


reasoning: The paragraph begins with the board of directors as the grammatical subject overseeing strategic and operational risks, including cybersecurity via regular reports from consultants, aligning with Board Governance; while it includes generic past immaterial incidents and materiality assessments, these are secondary to the board oversight description.


reasoning: The paragraph focuses on identifying and describing specific management roles (e.g., Director of IT Infrastructure & Security, VP of IT), their qualifications, expertise, and reporting lines to executives and the board, which aligns with Management Role criteria where management roles are the grammatical subjects.


reasoning: The paragraph describes the company's internal training programs for cybersecurity awareness, phishing simulations, tabletop exercises, and incident response testing, which are components of the company's own risk management processes. No board, management roles, vendors, incidents, or strategy integration is mentioned, making Risk Management Process the best fit.


reasoning: The paragraph focuses on the CISO as the primary subject, detailing their qualifications, experience, responsibilities, and team oversight, which aligns with Management Role criteria. It includes firm-unique facts like the CISO's specific experience and education, qualifying as Firm-Specific but lacking two+ externally verifiable facts like dates or named firms for Quantified-Verifiable.


reasoning: The paragraph describes the Board's delegation of cybersecurity risk oversight to the Audit Committee, management's reporting cadence to the Board and committees, and the Audit Committee's role in receiving incident updates, making Board Governance the clear fit as the board/committee is the grammatical subject.


reasoning: The paragraph describes a real past cybersecurity incident with a specific date (August 2020) and assesses its financial impact (not material), fitting Incident Disclosure per tiebreaker for incident narrative + financial impact; cross-references and forward-looking statements are secondary.


reasoning: The paragraph describes the company's internal Enterprise Risk Management Committee (ERM) process for identifying, monitoring, and controlling risks, including quarterly assessments and action plans from the CISO and CDO, which fits Risk Management Process as the company's own processes. It contains firm-specific elements like the named ERM committee and roles (CISO, CDO), but lacks two or more externally verifiable facts like dates or amounts, making it Firm-Specific.


reasoning: Paragraph describes the company's own internal processes for cybersecurity assessments, vulnerability management, monitoring, and maintenance by specific teams, central to Risk Management Process; vendor mention is a minor component. Names specific teams unique to the firm (Longbridge's technology team and operational risk management group), qualifying as Firm-Specific with no frameworks or 2+ verifiable facts.


reasoning: Paragraph provides a standalone materiality conclusion stating no cybersecurity risks materially affected or are anticipated to affect business strategy, results of operations, or financial condition in fiscal 2025, with no incident narrative, fitting Strategy Integration. Contains one firm-unique verifiable fact (fiscal 2025 period), qualifying as Firm-Specific.


reasoning: The paragraph details the company's own cybersecurity risk management program, including framework adoption for identifying, assessing, and managing risks, which aligns with Risk Management Process. It names NIST CSF and Sarbanes Oxley frameworks but lacks any firm-unique facts like roles, dates, or specifics, resulting in Sector-Adapted specificity.


reasoning: This paragraph contains forward-looking disclaimers about general cybersecurity risks and references to Risk Factors, with no substantive disclosure on governance, processes, incidents, or strategies, fitting 'None/Other'.


reasoning: This paragraph provides a standalone materiality assessment, stating no material past incidents, immaterial expenses, and no known risks reasonably likely to materially affect the business, with forward-looking disclaimers, fitting Strategy Integration. No incident narrative or other process details are described.


reasoning: The paragraph details the company's incident response practices, including assessments conducted with the CEO, CFO, and MSP, which qualifies as internal IR planning under Risk Management Process; the preceding materiality statements are a standalone conclusion better fitting Strategy Integration but secondary to the process description.


reasoning: The paragraph details the company's own internal processes for assessing, identifying, and managing cybersecurity risks, including scope for internally managed IT, which aligns with Risk Management Process. It lacks any named frameworks, roles, dates, unique company facts, or verifiable metrics, making it Generic Boilerplate.


reasoning: The paragraph describes the company's own internal cybersecurity program, including risk mitigation processes, framework alignment, controls, monitoring, and incident response, which fits Risk Management Process; third-party retention is a minor component, not central. It names multiple frameworks and states maintenance of ISO 27001 certification, a firm-unique fact, qualifying as Firm-Specific.


reasoning: The paragraph details the company's internal processes for cybersecurity, including engaging external experts for audits, threat assessments, employee training, and refining policies based on results by senior management, fitting Risk Management Process as vendors are a component of internal processes. No named entities, frameworks, dates, roles, or verifiable facts are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph focuses on the CISO's identification, qualifications, reporting lines, and the CEO's relevant experience, making 'Management Role' the clear fit as management roles are the grammatical subjects. It contains multiple verifiable facts including specific dates (2009-2011), named roles, certifications/frameworks, and named entities like Valparaiso University and DoD, exceeding the threshold for Quantified-Verifiable.


reasoning: The paragraph focuses on the CISO's leadership of the ISC, the CISO's extensive experience, and specific certifications, making 'Management Role' the best fit as it details CISO identification and qualifications. No board involvement or incident details; ISC supports internal security but centers on management structure and personnel.


reasoning: The paragraph details internal processes like employee cybersecurity training, third-party provider oversight (assessments, monitoring, charter requirements), and insurance, with vendors as a component of overall risk management rather than the central topic. Tiebreaker assigns internal processes mentioning vendors to Risk Management Process.


reasoning: The paragraph describes the company's internal processes for risk assessment, framework adoption (NIST), integration into ERM, and team coordination for reviewing risks, making 'Risk Management Process' the best fit. It includes a named framework and specific team composition, qualifying as Firm-Specific but lacking two+ externally verifiable facts like dates or amounts.


reasoning: The paragraph describes oversight by the Board of Directors and Audit Committee, including meeting cadences with the CSO, making 'Board Governance' the clear fit as board/committee actions are the grammatical subjects. It includes firm-unique facts like the named CSO role, Audit Committee, and specific annual/quarterly briefing cadences, qualifying as Firm-Specific but not Quantified-Verifiable due to lack of two+ externally verifiable metrics like dates or amounts.


reasoning: The paragraph details the company's intended internal processes for cybersecurity risk identification, assessment, management, vulnerability management, and monitoring, integrated into overall risk management; board oversight and third-party consultant are mentioned as components, not central topics.


reasoning: This paragraph describes a real cybersecurity incident with details on date, affected system (Dropbox Sign), scope of data accessed, response actions, and limitations, clearly fitting Incident Disclosure over others like Strategy Integration.


reasoning: Paragraph describes a real cybersecurity incident with date of determination, unauthorized access details, response actions including containment, disruption, and notifications, clearly fitting Incident Disclosure per criteria. Contains one verifiable firm-specific fact (exact date), qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second fact.


reasoning: The paragraph details a real cybersecurity incident with a specific date of determination, unauthorized access description, response actions including containment and remediation, and business impact, clearly fitting Incident Disclosure over other categories like Strategy Integration.


reasoning: This paragraph details a real cybersecurity incident with date of detection, unauthorized access description, response actions (investigation with external experts, law enforcement notification), and operational impacts, clearly fitting Incident Disclosure. It includes one verifiable firm-specific fact (exact incident date), qualifying as Firm-Specific per decision test.


reasoning: Paragraph describes a real cybersecurity incident with timeline, scope (small percentage of emails including specific functions), actor, and response actions (investigation, law enforcement notification), directly matching Incident Disclosure; financial impact mention is secondary per tiebreaker. Multiple specific dates (three verifiable) plus named teams exceed threshold for Quantified-Verifiable.


reasoning: This paragraph describes a real cybersecurity incident with timeline, scope (email accounts of senior leadership and specific functions), exfiltration, and ongoing access to source code repositories and systems, directly matching Incident Disclosure criteria including incident narrative.


reasoning: The paragraph focuses on the identification, qualifications, responsibilities, reporting lines, and team composition under the VP of IT and other named management roles, aligning with 'Management Role'. It contains multiple verifiable quantified facts (tenure, experience years, headcount) and firm-unique elements like named committees and roles, exceeding Firm-Specific for Quantified-Verifiable.


reasoning: This paragraph describes a real cybersecurity incident with timeline (access starting Feb 4, detected Feb 5), scope (data exfiltration including client PII and admin data), threat actor identification, and response actions (incident response activation, external experts, law enforcement notification), making it a clear Incident Disclosure.


reasoning: Paragraph describes a real cybersecurity incident with timeline, actions (restoration from backups, taking site down), and affected asset (wytecintl.com), matching Incident Disclosure. Contains two verifiable facts (specific date and named website/domain).


reasoning: This paragraph describes a specific cybersecurity incident, including scope (impacted many but not all IT systems, billing and label making functions), response actions (removed third party, restored access, implemented contingency plans), and outcomes (data stolen/destroyed, operations continued), fitting Incident Disclosure. It contains one firm-unique detail on affected business functions, qualifying as Firm-Specific with no frameworks or multiple verifiable facts.


reasoning: This paragraph describes a real cybersecurity incident including unauthorized access, system impacts, operational halts, data exfiltration, and response actions like investigation and notifications, fitting Incident Disclosure. No specific dates, named systems, quantified impacts, roles, or other verifiable facts are present; all details are vague ('certain systems', 'some aspects', 'various locations'), making it Generic Boilerplate.


reasoning: This is a standard forward-looking statement disclaimer and safe harbor provision, with cross-references to risk factors, containing no substantive cybersecurity disclosure.


reasoning: Paragraph describes an actual cybersecurity incident involving data exfiltration by a threat actor, scope (personal information of clients' end-users), and response actions (engaged experts, analyzing impact, notifying clients), clearly fitting Incident Disclosure. No named entities, dates, frameworks, roles, or verifiable facts present, making it Generic Boilerplate.


reasoning: Paragraph details a real cybersecurity incident with unauthorized access, specific data exfiltration (images of meetings/screens), extortion threat, response actions (closing access, bolstering defenses), and operational/financial impact, directly matching Incident Disclosure; tiebreaker prioritizes incident narrative over financial impact.


reasoning: Paragraph details a real cybersecurity incident with detection date, response actions (incident response procedure, external experts, law enforcement notification), and operational impacts to specific systems, fitting Incident Disclosure per guidelines and tiebreakers.


reasoning: The paragraph evaluates the material financial and operational impacts of 'the Incident,' including expected costs, without any incident narrative or response details, aligning with Strategy Integration for materiality assessments. No named entities, dates, frameworks, roles, or verifiable facts are present, making it generic boilerplate.


reasoning: This paragraph describes the scope, content, and specifics of data exposed in a cybersecurity incident, including details on affected customer types and data fields, clearly fitting Incident Disclosure. It contains firm-unique facts about AT&T's wireless network, MVNO customers, and wireline customers, qualifying as Firm-Specific but lacking two+ independently verifiable metrics like dates or amounts for Quantified-Verifiable.


reasoning: This paragraph details a specific cybersecurity incident involving a former employee accessing customer data from up to 33 million accounts, including scope, what was not compromised, ongoing investigation, external experts, and regulatory involvement, fitting Incident Disclosure per tiebreaker for incident narrative with financial impact. It has one verifiable quantified fact (33 million accounts) and Korea-specific regulatory detail, meeting Firm-Specific but not two+ for Quantified-Verifiable.


reasoning: This paragraph details a specific cybersecurity incident at a third-party provider affecting BayFirst customer data, including scope (personal info like name, DOB, SSN/TIN), response actions (investigation, experts, law enforcement notification, customer notifications), and no misuse or quantifiable impact, matching Incident Disclosure per tiebreaker for incident narrative with financial impact. No dates, named providers, systems, roles, frameworks, or other externally verifiable facts qualify as specific, rendering it Generic Boilerplate.


reasoning: Paragraph describes a real cybersecurity incident with date, affected entities, unauthorized access details, response actions, and containment status, clearly fitting Incident Disclosure. Contains multiple verifiable facts including specific date and named firms/subsidiaries, qualifying as Quantified-Verifiable.


reasoning: This paragraph describes a real cybersecurity incident with details on unauthorized access, dates, threat actors, affected systems, scope, and response actions, clearly fitting Incident Disclosure. It contains multiple verifiable facts including two specific dates, named threat actors, and the affected system, meeting Quantified-Verifiable criteria.


reasoning: This paragraph describes a real cybersecurity incident with details on timing, affected systems (website and email), cause (former executive action), and response steps, clearly fitting Incident Disclosure over others like Strategy Integration due to the narrative focus. It includes two specific dates and named systems, meeting Quantified-Verifiable criteria with multiple externally verifiable facts.


reasoning: This paragraph details a specific cybersecurity incident including the date, cause (attack by threat actors accessing network, encrypting applications, exfiltrating files), response (remediation, third-party vendors), and ongoing impacts, fitting Incident Disclosure. It contains two verifiable facts: the incident date and reference to a prior specific SEC filing.


reasoning: This paragraph describes a specific cybersecurity incident including date, detection, scope (IT systems encrypted, data stolen), response actions (investigation, incident response plan, system shutdowns, law enforcement notification), and operational impacts, fitting Incident Disclosure. It contains one firm-unique verifiable fact (exact incident date), qualifying as Firm-Specific but not Quantified-Verifiable due to lack of a second verifiable fact like named firms or quantified metrics.


reasoning: Paragraph focuses on business/financial impacts and materiality assessment of the Incident on Q2 results of operations due to slower vehicle sales, with no incident narrative or response details, fitting Strategy Integration per tiebreakers for standalone materiality conclusions.


reasoning: Paragraph details response actions (restoration, containment, remediation), operational impacts, and financial costs of a specific cybersecurity incident, directly matching Incident Disclosure with tiebreaker for incident narrative plus financial impact. Contains multiple verifiable facts including specific dates and quantified costs, qualifying as Quantified-Verifiable.