reasoning: The paragraph centrally addresses vendor oversight, due diligence, and monitoring of third-party cybersecurity risks, fitting the Third-Party Risk category. However, it employs generic enterprise risk management terminology ('due diligence,' 'safeguards,' 'continually monitor') that would apply equally to financial or operational risk without demonstrating cybersecurity domain expertise, and lacks any firm-specific details or verifiable facts.


content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the board's delegation of cybersecurity oversight to the audit committee, which is classic governance structure content (Board Governance). The language is generic risk oversight terminology ('considers cybersecurity risk as part of its risk oversight function,' 'oversight of management's implementation') that would apply to any risk type and contains no domain-specific cybersecurity practices, firm-specific details, or verifiable facts, resulting in Generic Boilerplate specificity.

provider: moonshotai

stage: benchmark


content_category: Third-Party Risk

fact: Our Town (named third-party hotel manager/vendor)

reasoning: The paragraph centrally addresses vendor oversight by describing the company's lack of control over third-party information systems, specifically naming their hotel manager 'Our Town' and franchisors as distinct entities for which the company sets cybersecurity expectations but relies upon for risk management. The naming of the specific vendor 'Our Town' constitutes an externally verifiable fact, driving the specificity to Level 4 despite the absence of quantified metrics like insurance coverage amounts.


fact: In February 2024

fact: Interim Chief Financial Officer

fact: Chief Legal Officer

reasoning: The paragraph answers how the board oversees cybersecurity by describing the February 2024 delegation of oversight to the Audit Committee, the committee's supervision of management's program implementation, and the specific reporting lines from the Interim CFO and Chief Legal Officer to the board. Specificity reaches Level 4 due to the verifiable date 'February 2024' and firm-specific executive titles.


content_category: Risk Management Process

fact: ransomware attacks

fact: phishing attacks

fact: insider threats

fact: computer viruses or other malicious codes

fact: unauthorized access attempts

fact: disaster recovery process

reasoning: The paragraph primarily describes the company's cybersecurity activities: monitoring systems against specific threat types, adjusting strategy, and exercising a disaster recovery process. While it includes a materiality statement about past incidents, the bulk of the content addresses operational risk management activities. Specificity is Domain-Adapted because the paragraph uses cybersecurity-specific threat terminology (ransomware, phishing, insider threats) that would not naturally appear in non-cybersecurity enterprise risk management contexts.


fact: SVP of IT Security (VP-level cybersecurity leadership role)

reasoning: Paragraph primarily describes Board oversight structure, detailing how the Audit Committee receives cybersecurity briefings and incident reports from management. The mention of 'SVP of IT Security' as the specific management role reporting to the Board provides a firm-specific detail (VP-level security title) that elevates specificity to Level 3.


content_category: Management Role

fact: Chief Technology and Digital Officer (VP-level+ title with technology scope)

fact: Senior Vice President, Technology (VP-level+ title)

fact: over 10 years of networking and information technology management or executive experience

fact: over 25 years of networking and information technology management or executive experience

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

fact: committee comprised of representatives from accounting, finance, legal, internal audit, and information technology

fact: Cybersecurity Committee meets monthly

reasoning: The paragraph answers how management is organized to handle cybersecurity by detailing specific leadership roles (CTDO, SVP Technology), their quantified experience (10+ and 25 years), and the structure of the Cybersecurity Committee including its departmental composition. While it lists committee activities (risk assessments, monitoring KRIs), these are framed as the committee's responsibilities within the management hierarchy, not as a standalone program description. The specificity is driven by externally verifiable claims regarding years of experience and firm-specific organizational details (VP titles, named committee, specific departments).


reasoning: The paragraph primarily describes Board and Audit Committee oversight responsibilities for cyber risk management, fitting Board Governance. It contains only generic governance descriptions ('risk identification,' 'mitigation strategy,' 'dedicated resources') without specific cybersecurity domain terminology, firm-unique organizational details, or quantifiable facts.


content_category: Strategy Integration

reasoning: The paragraph primarily answers whether cybersecurity risks have materially affected or are likely to materially affect the business, containing the backward-looking assessment ('have not had a material impact') and forward-looking SEC Item 106(b)(2) language ('not reasonably likely to materially affect') that define Strategy Integration under Rule 5. It contains no specific facts, numbers, named roles, certifications, or domain-specific cybersecurity terminology that would elevate it above Generic Boilerplate.


reasoning: The paragraph primarily makes materiality assessments regarding past impacts ('have not... materially affected') and forward-looking risks ('reasonably likely to materially affect'), which squarely fits Strategy Integration under Rule 5. The text lacks specific domain terminology (terms like 'resiliency' and 'internal controls' are standard ERM language), firm-specific details, or quantified/verifiable facts, resulting in Generic Boilerplate specificity.


fact: Chief Information Consultant (cybersecurity leadership role)

reasoning: Paragraph describes specific management positions (Chief Information Consultant and CFO) and their cybersecurity responsibilities, fitting Management Role. The distinctive title 'Chief Information Consultant'—an unusual role designation compared to standard CISO/CIO titles—provides a firm-specific detail that elevates specificity to Level 3.


reasoning: The paragraph describes Board-level oversight through the Audit Committee's responsibility for reviewing cybersecurity risk management policies, fitting the Board Governance category. It contains only generic enterprise risk management language ('risk assessment,' 'risk management') and standard governance structures without specific cybersecurity practices, firm-unique organizational details, or verifiable facts.


fact: security questionnaires

fact: Information Systems and Data

specificity_confidence: medium

reasoning: The paragraph answers how third-party cyber risks are managed by describing vendor assessment processes including security questionnaires and contractual obligations imposed on providers, which falls under Third-Party Risk. Specificity is Domain-Adapted (Level 2) because terms like 'security questionnaires' and 'contractual obligations related to cybersecurity' demonstrate specific cybersecurity domain knowledge beyond generic risk management language.


fact: cybersecurity controls

fact: reviews of cybersecurity controls of third-party service providers

fact: nature of Trust's information processed by the vendor

reasoning: The paragraph centrally addresses how third-party cyber risks are managed through a vendor oversight program, including reviews of vendor cybersecurity controls and risk-based frequency criteria, which classifies as Third-Party Risk. It demonstrates domain expertise (Level 2) through specific cybersecurity terminology like 'cybersecurity controls' and data-handling concepts that would not naturally appear in generic ERM language, but lacks firm-specific organizational details (e.g., named committees, specific cadences, or VP-level roles) or verifiable quantitative claims needed for higher specificity levels.


fact: penetration testing

fact: CIS Critical Security Controls

reasoning: The paragraph primarily answers what the cybersecurity program does, describing specific activities like penetration testing, annual assessments, and incident response simulations. While it includes materiality assessments (Strategy Integration) and third-party oversight (Third-Party Risk), the majority of the text details operational security activities. Specificity is Domain-Adapted because the paragraph uses specific cybersecurity domain terminology including 'penetration testing' and 'CIS Critical Security Controls' that demonstrate expertise beyond generic risk management language.


fact: Lead IT Systems Specialist

fact: Directors of Banking and Mortgage

fact: Legal/Compliance

fact: Corporate Security

fact: Internal Audit

fact: Human Resources

fact: Corporate Communications

reasoning: The paragraph describes the organizational structure of incident response teams by enumerating specific management roles and departments (e.g., Directors of Banking and Mortgage, Legal/Compliance, Lead IT Systems Specialist) that may be included based on incident type, which addresses how management is organized to handle cybersecurity. The specificity is Firm-Specific because it provides a concrete team composition by department rather than generic descriptions like 'cross-functional teams,' distinguishing this company's incident response structure.


content_category: None/Other

reasoning: The paragraph contains only generic aspirational language about cybersecurity commitment and operational strategy without describing any specific governance structures, management roles, risk management processes, third-party oversight, incidents, or business/materiality assessments. As it lacks substantive cybersecurity disclosure and merely states the importance of cybersecurity, it is classified as None/Other with Generic Boilerplate specificity.


reasoning: This paragraph is a pure cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk descriptions, containing no substantive disclosure about the company's actual cybersecurity governance, management, processes, or incidents. It lacks any specific facts, names, dates, quantities, or verifiable claims, consisting entirely of generic forward-looking risk language and filing references.


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

fact: HIPAA

fact: Service Organization Control Type 2 (SOC 2 Type II)

fact: Sarbanes-Oxley IT General Controls (SOX ITGC)

fact: confidentiality, integrity, and availability

reasoning: The paragraph describes the company's cybersecurity risk management program activities and methodology, including the specific named frameworks (NIST CSF, SOC 2 Type II, HIPAA, SOX ITGC) and security objectives (CIA triad) used to guide risk assessment, which demonstrates domain expertise beyond generic risk management language. No firm-specific organizational details or quantifiable metrics are present to elevate to Level 3 or 4.


fact: NIST CSF core functions: Identify, Protect, Detect, Respond, and Recover

reasoning: The paragraph describes the company's cybersecurity program and its alignment with the NIST CSF framework and its five specific core functions, demonstrating domain expertise (Level 2). It primarily answers what the program does (risk assessment and management using a named framework), placing it in Risk Management Process.


fact: attack vectors

reasoning: The paragraph states a negative conclusion regarding material cybersecurity incidents ('have not experienced any material cybersecurity events to date'), which per Rule 5 qualifies as a Strategy Integration assessment. The use of 'attack vectors'—a technical cybersecurity concept unlikely to be used naturally by a non-security ERM professional—demonstrates domain expertise, elevating specificity to Level 2.


fact: uses Ontrack software solution to monitor and track all aspects of risk assessment

fact: Ontrack serves as tool to track cybersecurity incidents and remediation tasks

reasoning: The paragraph describes the company's ongoing risk monitoring activities and the specific tools used to execute them, fitting Risk Management Process. The explicit naming of 'Ontrack' as the specific software solution used for tracking assessments and incidents constitutes a verifiable claim about the company's technology stack (analogous to the Level 4 example of 'uses CrowdStrike Falcon'), warranting Quantified-Verifiable specificity.


reasoning: The paragraph describes Board-level oversight mechanisms, including quarterly reporting, escalation processes for incidents, and Board-engaged third-party testing, which aligns with Board Governance. Specificity remains at Level 1 because the text contains only generic governance terms (escalation process, quarterly updates, unnamed third-party experts) without domain-specific cybersecurity terminology, firm-unique details, or externally verifiable facts; the title 'Director of IT' lacks a security qualifier and does not qualify as firm-specific under the annotation rules.


fact: Breach Response Team (specific named team responsible for conducting exercises and breach response)

reasoning: The paragraph describes specific risk management activities (tabletop exercises, incident simulation, and strategy development) rather than governance structure or management roles. The reference to the 'Breach Response Team' constitutes a firm-specific organizational detail that distinguishes this company's program structure, elevating specificity to Level 3.


reasoning: The paragraph describes the Board and Audit Committee's oversight structure for cybersecurity risks, including the designation of the Audit Committee to oversee these risks and the flow of information from the CFO and management to the Board and Committee, which falls under Board Governance. The language is entirely generic governance terminology ('oversight,' 'regular updates,' 'at least an annual basis') that could apply to any risk domain without modification, and contains no domain-specific cybersecurity practices, firm-specific organizational details, or verifiable facts.


reasoning: The paragraph describes the Board's receipt of annual reports on cybersecurity risks and ad hoc updates regarding incidents, which directly addresses how the board oversees cybersecurity risks (Board Governance). The terminology ('annual reports', 'management updates', 'material incidents') is generic governance language that could apply to any risk domain and fails the ERM test for domain expertise; it contains no firm-specific details, named roles, or verifiable facts (Generic Boilerplate).


reasoning: The paragraph describes the organizational structure and qualifications of Helios' information systems management team responsible for cybersecurity policies, which falls under Management Role. The content is generic boilerplate—describing 'management team,' 'formal education,' and 'periodic training' without specific titles (e.g., CISO), named certifications, domain-specific practices, or verifiable details that would elevate it above Level 1.


fact: Mr. Lee (named individual responsible for providing cybersecurity updates to the Board)

reasoning: The paragraph describes the information flow from management to the Board and Audit Committee regarding cybersecurity incidents, answering how the board oversees cybersecurity (Board Governance). The naming of 'Mr. Lee' as the specific individual responsible for these updates constitutes a firm-specific fact (Level 3), as this identifies a particular person in a cybersecurity reporting role distinct from generic 'management' references.


reasoning: The paragraph primarily answers whether cybersecurity incidents have materially affected or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which is a materiality assessment falling under Strategy Integration per Rule 5. It contains no firm-specific details (no roles, committees, or programs unique to the company), no verifiable facts (negative assertions about not having experienced incidents are not externally verifiable), and no domain expertise (generic risk language that any ERM professional could write), resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the board's delegation of cybersecurity oversight to the Audit Committee, answering how the board governs cyber risk. The language consists entirely of generic governance descriptions (board oversight, Audit Committee responsibilities) that contain no domain-specific cybersecurity practices, firm-specific organizational details, or verifiable facts.


fact: Chief Technology Officer

reasoning: The paragraph describes Board and Audit Committee oversight activities, including reporting structures and the receipt of briefings from management on cyber risk, which aligns with Board Governance. The specificity is Firm-Specific because it identifies the Chief Technology Officer—a C-level leadership role—as the source of cybersecurity presentations to the Board, distinguishing this company's governance structure from generic descriptions.


reasoning: This paragraph is a cross-reference pointing to Item 1A Risk Factors for cybersecurity information and contains no substantive disclosure about the company's actual cybersecurity program, governance structure, or risk management activities. As a cross-reference with no specific facts regarding cybersecurity posture, it is classified as None/Other with Generic Boilerplate specificity.


reasoning: The paragraph states a backward-looking materiality assessment conclusion that cybersecurity threats have not materially affected business outcomes, which classifies as Strategy Integration per Rule 5. However, it contains no specific facts—no verifiable claims (negative assertions about absence of incidents are not externally verifiable), no firm-specific roles/programs, and no domain-adapted terminology demonstrating cybersecurity expertise beyond generic ERM risk disclosure language.


reasoning: The paragraph focuses centrally on how the company manages risks from IT suppliers who handle sensitive data, which falls squarely under Third-Party Risk. The language consists of generic process descriptions ('periodic basis', 'due diligence procedures') that fail the ERM test—an enterprise risk professional could use identical phrasing for non-cyber vendor assessments—and contains no domain-specific security controls, firm-unique organizational details, or verifiable facts.


fact: ISO 27001 framework

fact: NIST 800-53 framework

fact: GDPR framework

fact: countermeasures

fact: mitigation strategies

reasoning: The paragraph describes the company's cybersecurity program activities, including the frameworks it uses (ISO 27001, NIST 800-53, GDPR) and its processes for threat identification and response, which directly answers 'What does the cybersecurity program do?' (Risk Management Process). Specificity is Domain-Adapted because it cites specific cybersecurity frameworks and practices (countermeasures) that demonstrate domain expertise beyond generic risk management language, but contains no firm-specific organizational details or quantifiable metrics that would elevate it to Level 3 or 4.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risk management processes, fitting the Board Governance category. The language consists of generic enterprise risk management terminology ('processes for assessing and managing risk,' 'identify and mitigate') that could apply to any risk type without demonstrating cybersecurity domain expertise, and contains no firm-specific details or verifiable facts.


fact: obtained our second ISO 27001 certification

reasoning: The paragraph primarily answers what the cybersecurity program does by describing control testing, employee training, and third-party assessments, placing it in Risk Management Process (third parties are assessors hired to serve the company, not vendors under oversight). Specificity is Quantified-Verifiable because the claim of holding an ISO 27001 certification is an externally auditable fact that can be verified through certification body registries.


fact: certificate in Cybersecurity Oversight from the Carnegie Mellon University Software Engineering Institute

fact: CISO

fact: served many years in our corporate information security organization

fact: security engineering

fact: cyber threat detection and response

reasoning: The paragraph primarily describes the company's cybersecurity program activities including security engineering, threat detection/response, and enterprise security structure, passing the person-removal test for Risk Management Process. Specificity reaches Level 4 due to the externally verifiable claim that the CISO holds a specific certificate from Carnegie Mellon University, alongside firm-specific details regarding the CISO role and tenure.


reasoning: The paragraph describes the board's ultimate oversight of risk management and the executive team's role in presenting cyber risks to the board, constituting a governance-chain description (BG). The language consists entirely of generic enterprise risk management terminology without specific cybersecurity domain expertise, firm-unique organizational details, or quantifiable facts, resulting in Level 1 specificity.


fact: NIST Framework

reasoning: The paragraph describes the company's cybersecurity risk management activities, including framework adoption (NIST) and operational processes for vulnerability management and incident response (prevent, identify, escalate, investigate, resolve, recover). The mention of the NIST Framework demonstrates cybersecurity domain expertise beyond generic enterprise risk management language, establishing Domain-Adapted specificity.


reasoning: The paragraph primarily answers whether cybersecurity risks have materially affected the business by stating that no material incidents occurred in the last three fiscal years, which is a materiality assessment falling under Strategy Integration per Rule 5. Specificity is Generic Boilerplate because the text contains no domain-adapted security terminology (passes the ERM test), no firm-unique organizational details (e.g., named officers, specific team structures), and no verifiable quantitative claims—only generic temporal references and negative assertions about material effects.


reasoning: The paragraph states a conclusion about whether cybersecurity threats have materially affected or are reasonably likely to materially affect business outcomes (business strategy, results of operations, financial condition), which falls squarely under Strategy Integration per Rule 5. The paragraph contains only generic risk disclaimers, negative assertions about material incidents (which are not externally verifiable), and references to internal controls and insurance without specific details, resulting in Generic Boilerplate specificity.


fact: Global Director of IT has over 30 years of experience in various information technology roles

fact: over 20 years of experience as an IT Director

fact: CFO has over 10 years of experience in risk management at the Company and at similar companies

reasoning: The paragraph answers how management is organized to handle cybersecurity by identifying specific leadership roles (Global Director of IT, CEO, CFO) and their responsibilities, along with quantifiable experience claims (over 30, 20, and 10 years respectively) that are externally verifiable. The specific years of experience elevate the paragraph to Quantified-Verifiable specificity.


reasoning: The paragraph primarily provides a materiality assessment regarding whether cybersecurity has affected or is likely to affect business outcomes, fitting Strategy Integration under Rule 5 (specifically the backward-looking negative assertion). It contains only generic regulatory boilerplate language and unverifiable negative assertions without domain-specific terminology, firm-unique organizational details, or quantifiable facts, resulting in Generic Boilerplate specificity.


reasoning: This paragraph contains only a generic commitment to protecting against cyber threats without disclosing specific governance structures, management roles, risk processes, or strategic assessments. No specific facts, domain expertise, firm-unique details, or verifiable claims are present.


fact: CISO (cybersecurity leadership role at VP level or above)

fact: ISO reports incident to Chief Executive Officer, Chief Financial Officer, CISO and Senior Vice President, General Counsel & Compliance Officer (specific incident escalation structure)

fact: Audit committee receives regular reports regarding material cybersecurity developments (specific oversight mechanism)

reasoning: Paragraph primarily answers how the board oversees cybersecurity, describing audit committee assistance, regular reporting to the board, and the governance chain for incident escalation (ISO → Executives → Audit Committee), which is Board Governance. Specificity is Firm-Specific due to identification of the CISO role and the detailed, company-specific reporting structure involving the ISO and named executive positions.


reasoning: As a blank check company with no operations, CEPO explicitly states it maintains no cybersecurity personnel or internal processes, relying solely on third parties for protection. This constitutes no substantive cybersecurity disclosure, warranting the None/Other category and Generic Boilerplate specificity.


reasoning: The paragraph primarily answers whether cybersecurity risks have materially affected or are reasonably likely to affect the business, which is Strategy Integration per Rule 5. It contains no specific facts: 'ongoing basis' and 'reporting period' are generic temporal references, and the negative materiality assertion is a self-reported conclusion that is not externally verifiable. No domain-specific practices or firm-unique organizational details are present.


reasoning: The paragraph provides biographical details about Mr. Tao's background in marketing and business consultation without referencing cybersecurity roles, responsibilities, risk management, or governance, thus answering none of the six substantive cybersecurity disclosure questions. Per the classification rules, None/Other paragraphs are automatically assigned Generic Boilerplate specificity regardless of other factual content.


reasoning: The paragraph answers how the Board oversees cybersecurity, describing oversight of frameworks and delegation to committees/officers, which fits Board Governance. It contains only generic governance language ('risk management framework', 'policies', 'strategies') that fails the ERM test for domain expertise and lacks any firm-specific details or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the governance chain and information flow from the Global Director of IT through the CEO/CFO to the audit committee and board of directors, addressing how the board oversees cybersecurity risks. It contains only generic descriptions of reporting relationships and cadences ('weekly briefings,' 'periodic updates') without domain-specific cybersecurity terminology, firm-unique role specifications (e.g., the 'Global Director of IT' lacks a security qualifier and is not a VP-or-above title), or externally verifiable facts.


fact: Chief Operating Officer responsible for assessing and managing cybersecurity risk

reasoning: The paragraph primarily describes the governance chain and oversight structure: the Audit Committee's responsibility for overseeing cybersecurity procedures, review of management presentations, and the reporting relationship between the Board, Audit Committee, and management. This aligns with Board Governance. For specificity, the paragraph identifies the Chief Operating Officer (a C-suite/VP-level role) as the executive specifically responsible for cybersecurity risk management, which is a firm-specific organizational fact distinguishing this company's structure from others. No quantifiable or externally verifiable facts (Level 4) are present, and while domain terminology appears, the identifying fact is the specific leadership role.


fact: Chief Financial Officer serves on the cybersecurity incident response team

reasoning: The paragraph primarily describes incident response activities including escalation procedures, mitigation, and remediation processes (RMP), not merely organizational structure. The inclusion of the Chief Financial Officer as a member of the response team constitutes a firm-specific fact about cybersecurity leadership roles (Level 3), as it identifies which specific C-suite executive participates in cyber incident response.


fact: Company's CCO (Chief Compliance Officer) is responsible for assessing and managing material risks from cybersecurity threats

fact: Communications with risk management, legal, information technology, and/or compliance personnel of the Adviser

fact: Management possesses advanced degrees in business administration and legal studies

reasoning: The paragraph primarily describes management's organizational structure for cybersecurity, specifically assigning responsibility to the CCO (a C-level executive) and detailing the qualifications of management team members (degrees, certifications) and their communication channels with specific departments of the Adviser. This focuses on WHO is responsible and HOW they are organized, not WHAT the program does. The specificity is Firm-Specific (Level 3) because it identifies the CCO as the responsible senior executive and names specific functional departments (risk management, legal, IT, compliance) involved in the governance chain, distinguishing this company's structure from generic descriptions.


reasoning: This paragraph explicitly states a materiality assessment conclusion—that no cybersecurity incident has or is likely to materially affect business strategy, results of operations, or financial condition—triggering Rule 5 for Strategy Integration. The language is generic boilerplate containing no specific facts: it offers no quantified metrics, named roles, specific dates, or verifiable certifications, and the references to 'vendors and government agencies' are incidental to the materiality assertion rather than a description of third-party risk management processes.


reasoning: This paragraph is a risk factor header or cross-reference using speculative forward-looking language ('Could...') without describing actual cybersecurity governance, processes, or measures. It contains no specific domain terminology, firm-specific organizational details, or verifiable facts.


fact: over 15 years' experience in the information technology and cybersecurity field

fact: over 15 years' experience in auditing information security

fact: BA in math and computer science from Ohio Wesleyan University

fact: holds an Information Systems Auditor certification

fact: Senior Director - Information Security

reasoning: The paragraph exclusively describes the qualifications, career history, and credentials of the Senior Director - Information Security, fitting Management Role. Specificity is Quantified-Verifiable due to multiple externally verifiable claims: over 15 years of experience (lower-bound threshold), a specific university degree, and a professional certification.


reasoning: The paragraph describes engaging a third party to assess the company's cybersecurity risk management processes, which answers what the program does (Risk Management Process). The language is entirely generic—stating the company has 'processes and practices' and uses a 'third party' without naming the party, specifying assessment types (e.g., penetration testing, audits), or providing any firm-specific or quantifiable details—resulting in Generic Boilerplate specificity.


reasoning: This paragraph provides the SEC Item 106(b)(2) materiality assessment, stating that cybersecurity risks have not materially affected and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition. It contains no specific facts—only a generic negative assertion about material impacts that is not externally verifiable, with no domain-specific cybersecurity terminology or firm-specific details.


reasoning: The paragraph states a conclusion about whether cybersecurity threats have materially affected or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which is a classic Strategy Integration assessment under Rule 5. The paragraph contains no specific facts—only generic materiality assertions and a cross-reference to Risk Factors—resulting in Generic Boilerplate specificity.


fact: National Institute of Standards and Technology (NIST)

fact: International Organization for Standardization (ISO)

fact: confidentiality, security and availability

reasoning: The paragraph primarily answers what the cybersecurity program does by describing its integration with ERM, adoption of recognized frameworks, and approach to threat management. While it mentions Board oversight, the substantive content focuses on program activities and methodology. Specificity is Domain-Adapted due to explicit references to NIST and ISO frameworks and use of information security domain terminology (confidentiality, security, availability), which demonstrate cybersecurity expertise beyond generic risk management language.


fact: cybersecurity threats and incidents

fact: cybersecurity insurance coverage

reasoning: Paragraph centers on vendor oversight, contractual security requirements, and third-party risk management, making Third-Party Risk the clear category. Specificity is Domain-Adapted because the text uses cybersecurity-specific terminology ('cybersecurity threats and incidents', 'cybersecurity insurance coverage') that demonstrates domain expertise beyond generic enterprise risk management language.


fact: Enterprise Risk Management Committee ("ERMC")

fact: TISC

fact: the Program

fact: Chief Risk Officer

fact: Director of Enterprise Risk Management

reasoning: Paragraph describes a management-level committee's (ERMC) structure, membership, and reporting lines to the Board, fitting Management Role. Specificity is Firm-Specific due to named internal committees (ERMC, TISC), capitalized reference to 'the Program,' and identification of specific leadership titles including Chief Risk Officer and Director of Enterprise Risk Management.


reasoning: This paragraph is a forward-looking disclaimer about the unpredictability of future incidents and a cross-reference to Item 1A Risk Factors, containing no substantive cybersecurity disclosure. It lacks any specific facts, domain terminology, or verifiable claims, consisting entirely of generic boilerplate language.


fact: Principal Accounting Officer receives regular reports on cybersecurity measures and assesses materiality for reporting purposes

reasoning: Paragraph describes the specific organizational responsibilities of the Principal Accounting Officer in cybersecurity governance (escalation recipient, report reviewer, materiality assessor), answering how management is structured to handle cybersecurity (MR). Identifying this specific executive role as having cybersecurity oversight duties provides a firm-specific fact (Level 3), as it distinguishes the company's governance chain from generic structures.


reasoning: The paragraph describes the governance chain and information flow from the executive team to the Board/Audit Committee, answering how the Board oversees cybersecurity. It contains no firm-specific details (only generic references to 'executive team' and 'audit committee'), no domain-adapted terminology demonstrating cybersecurity expertise (only generic 'industry standards' and 'risks, threats or incidents'), and no quantifiable or verifiable facts.


fact: Deputy Chief Executive Officer and Chief Financial Officer manages cybersecurity program (C-level role with cybersecurity responsibility)

fact: external IT team (firm-specific team structure)

fact: more than seven years of operational responsibility for IT (quantified experience threshold)

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by identifying the specific C-level executive (Deputy CEO/CFO) responsible for the program, his quantified experience threshold ('more than seven years'), and the use of an external IT team rather than an internal function. While it mentions board oversight, the substantive content focuses on management structure, responsibilities, and qualifications.


fact: Chief Information Officer

fact: cybersecurity governance committee

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, describing the IT team structure led by the Chief Information Officer and the composition of the management-level cybersecurity governance committee (CFO, CLO, CIO, Head of Internal Audit). Specificity is driven by firm-specific details including the named 'Chief Information Officer' role and the 'cybersecurity governance committee'.


reasoning: The paragraph describes engaging third-party consultants for cybersecurity testing and advisory services, which constitutes risk management activities (RMP) under Rule 3 (third parties hired as assessors/pen testers to serve the company rather than vendor oversight). The content lacks specific domain terminology that would fail the ERM test, firm-specific organizational details, or quantifiable facts, consisting only of generic descriptions of engaging external consultants for risk assessment.


fact: Senior Director, Information Technology has over twenty years of experience operating in the information technology, security and cybersecurity space

reasoning: The paragraph primarily answers how management is organized for cybersecurity by identifying specific leadership roles (Senior Director, Information Technology), detailing the Incident Response Team's cross-functional composition (including SVP Finance and General Counsel), describing reporting responsibilities, and stating the Senior Director's qualifications. This organizational and role-focused content falls under Management Role. Specificity is Level 4 due to the externally verifiable claim of 'over twenty years of experience,' which provides a quantified, checkable threshold.


content_category: Incident Disclosure

fact: January 18, 2023

fact: fewer than 300 restaurants

fact: one day

fact: one market

reasoning: The paragraph describes a specific ransomware attack that occurred on January 18, 2023, answering what happened in the incident with concrete details including the date and quantified impact (fewer than 300 restaurants closed for one day in one market). The presence of a specific date tied to a real event and hard numerical scope (fewer than 300) makes this Quantified-Verifiable.


reasoning: The paragraph constitutes a materiality assessment required by SEC Item 106(b)(2), stating that cybersecurity risks have not materially affected and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition. The text contains no firm-specific details, verifiable facts, or domain-adapted terminology beyond generic risk disclosure language, resulting in Generic Boilerplate specificity.


reasoning: The paragraph states negative conclusions regarding material cybersecurity incidents and their lack of business impact ('has not experienced any material cybersecurity events,' 'have not resulted in a material impact'), which per Rule 5 explicitly falls under Strategy Integration. It contains no specific facts, domain terminology passing the ERM test, or verifiable claims—only generic assertions about the absence of material events—resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a cross-reference directing readers to Item 1A for risk factor disclosures rather than providing any substantive cybersecurity governance, management, or process information. As a pointer containing no specific facts about the company's cybersecurity posture, it warrants the None/Other category and Generic Boilerplate specificity.


fact: Director of Information Security and Privacy (firm-specific leadership role)

fact: CISSP (Certified Information Systems Security Professional) certification (externally verifiable)

fact: CCSP (Certified Cloud Security Professional) certification (externally verifiable)

fact: penetration testing (cybersecurity domain practice)

fact: real-time vulnerability scanning (cybersecurity domain practice)

fact: intrusion detection (cybersecurity domain practice)

fact: email phishing test campaigns (cybersecurity domain practice)

fact: email security monitoring (cybersecurity domain practice)

reasoning: The paragraph primarily answers what the cybersecurity program does (risk assessments, penetration testing, vulnerability scanning, incident response planning, etc.), placing it in Risk Management Process under Rule 2 (person-removal test leaves substantial program description). Specificity is Level 4 because the paragraph cites externally verifiable professional certifications (CISSP and CCSP) held by the Director of Information Security.


reasoning: This paragraph consists of generic introductory statements regarding the company's commitment to cybersecurity and the intended purpose of its security measures ('designed to safeguard'), without describing specific governance structures, management roles, risk processes, or any verifiable facts. It does not substantively answer any of the six disclosure questions and functions as preamble language, warranting a None/Other classification with Generic Boilerplate specificity.


reasoning: The paragraph is centrally focused on vendor oversight and third-party risk management, describing assessments conducted on service providers to ensure alignment with internal standards, which falls under Third-Party Risk per Rule 3. The content provides only generic descriptions of vendor assessment activities ('rigorous cybersecurity risk assessments') without specifying methodologies (e.g., SOC 2 reviews, penetration testing), naming standards, or providing quantifiable details, resulting in Generic Boilerplate specificity.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party service providers, including onboarding assessments and contractual security obligations, which fits Third-Party Risk. However, it employs generic process descriptions ('various inputs,' 'various levels of assessment,' 'contractual obligations') without specific security practices, firm-unique program details, or quantifiable metrics, failing to rise above Generic Boilerplate.


fact: management team holds CISSP certification

fact: management team holds CISM certification

fact: management team holds CISA certification

fact: decades of experience as part of our IT team

fact: previous cybersecurity leadership positions at various Fortune 500 companies and U.S. Defense contractors

reasoning: The paragraph primarily answers how management is organized for cybersecurity (primary responsibility, supervising internal/external personnel) and what qualifies them (certifications, experience), fitting Management Role. Specificity is Level 4 because the named industry certifications (CISSP, CISM, CISA) are independently verifiable claims, even though the specific individuals aren't named.


reasoning: The paragraph provides the mandated SEC Item 106(b)(2) backward- and forward-looking materiality assessments regarding whether cybersecurity threats and previous incidents have affected or are likely to affect the company's business strategy, results of operations, and financial condition, which falls under Strategy Integration per Rule 5. It contains no specific facts, verifiable claims, numbers, dates, named roles, or domain-specific terminology—only generic materiality boilerplate applicable to any company.


fact: information security risk committee (management-level)

reasoning: The paragraph describes the company's cybersecurity risk management process, including monthly internal reporting mechanisms and the establishment of a management-level committee to coordinate program governance and direction. Specificity is Firm-Specific due to the identification of a Chief Information Security Officer (CISO) role and a named information security risk committee, which are firm-unique organizational details.


reasoning: The paragraph describes the company's cybersecurity program activities—assessing risks and maintaining policies/controls subject to review—which falls under Risk Management Process. However, it employs only generic ERM language ('assess, identify, and manage risks,' 'policies and controls,' 'regularly reviewed') that any risk management professional could write without cybersecurity domain expertise, and contains no firm-specific details or verifiable facts.


reasoning: The paragraph describes the company's risk assessment activities (identifying threats, evaluating likelihood/damage, assessing safeguards), which falls under Risk Management Process. However, the language is entirely generic—using terms like 'risk assessments,' 'policies, procedures, and safeguards,' and 'likelihood and potential damage' that would apply to any enterprise risk management context (financial, operational, etc.) and fail the ERM test for domain expertise. No specific cybersecurity practices, tools, standards, firm-specific details, or verifiable facts are present.


reasoning: The paragraph constitutes a materiality assessment required by SEC Item 106(b)(2), stating that cybersecurity threats have not materially affected the business and are not reasonably likely to do so, which falls under Strategy Integration per Rule 5. It contains no specific facts—only generic materiality assertions that are not externally verifiable, no domain-specific cybersecurity terminology, and no firm-specific details, resulting in Generic Boilerplate specificity.


reasoning: The paragraph exclusively addresses how the company manages cybersecurity risks from third-party service providers, including risk assessments, remediation requirements, and contractual security provisions, which aligns with the Third-Party Risk category. For specificity, the language consists of generic process descriptions ('periodic security risk assessment,' 'reasonable security controls') that any enterprise risk management professional could use without demonstrating cybersecurity domain expertise (no specific technical standards, tools, or controls mentioned) and contains no firm-specific details or verifiable facts.


reasoning: The paragraph describes the board's oversight structure and its delegation of cybersecurity risk oversight to the audit committee, directly answering how the board governs cybersecurity risks (Board Governance). It contains only generic governance language ('informed oversight,' 'strategic risk exposure,' 'day-to-day management') applicable to any risk domain without cybersecurity-specific practices, firm-specific organizational details, or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph centers entirely on vendor oversight—describing a Third-Party Risk Management program that assesses vendors, imposes security requirements, and monitors compliance—making Third-Party Risk the clear category. The text contains only generic process descriptions ('periodic risk assessments,' 'appropriate cybersecurity controls') that any ERM professional could write about vendor management without demonstrating cybersecurity domain expertise; no firm-specific details (named programs, leadership roles, team composition) or verifiable facts (specific standards, dates, numbers, named vendors) are present.


reasoning: The paragraph centrally addresses reliance on third-party service providers and the cyber risks they pose, fitting the Third-Party Risk category. It contains only generic statements ('continuously monitors', 'variety of products and services') without specific cybersecurity domain terminology, firm-unique organizational details, or quantifiable/verifiable facts that would elevate it above Level 1.


reasoning: The paragraph describes the reporting of material findings and weaknesses to a board-level committee (Enterprise Risk and Compliance Committee), addressing how the board oversees cybersecurity risks. The language consists entirely of generic governance terminology ('material findings,' 'notable weaknesses') and references a standard enterprise risk committee without domain-specific cybersecurity details, firm-unique identifiers, or quantifiable facts, warranting Generic Boilerplate classification.


fact: December 2021

fact: March 2024

fact: approximately two weeks

fact: one week

fact: Canadian subsidiary

reasoning: The paragraph primarily describes two actual cybersecurity incidents, providing specific dates (December 2021, March 2024), affected entities (Canadian subsidiary), and quantified durations (approximately two weeks, one week), which satisfies the Incident Disclosure category. The presence of specific dates and hard-number timeframes for system restoration makes this Quantified-Verifiable (Level 4).


category_confidence: medium

reasoning: The paragraph primarily describes the existence of processes to assess and manage cybersecurity risks and notes that a cybersecurity program has been implemented, which aligns with Risk Management Process (RMP). While it mentions the Investment Adviser, it does so to explain the source of the program rather than detailing management structure, qualifications, or reporting lines that would characterize Management Role (MR). For specificity, the paragraph contains only generic ERM language ('processes to assess, identify, and manage risks') that any non-security risk professional could write, with no domain-specific cybersecurity terminology, firm-specific details, or verifiable facts.


fact: Chief Risk Officer designated as Chief Privacy Officer with oversight for managing cybersecurity risk

fact: Chief Privacy Officer coordinates with Chief Information Security Officer

fact: Chief Privacy Officer provides reports to Board's Risk Oversight Committee

fact: Chief Information Security Officer responsible for day-to-day management of Information Security Program and Security Incident Response Policy and Plan

fact: Chief Privacy Officer held over 13 years previously serving as the Company's Chief Financial Officer

fact: Chief Information Security Officer has over 20 years of work experience in cybersecurity at financial institutions

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by detailing specific leadership roles (Chief Privacy Officer, Chief Information Security Officer), their responsibilities, reporting lines to the Board's Risk Oversight Committee, and verifiable qualifications including specific tenure claims ('over 13 years' as CFO and 'over 20 years' of cybersecurity experience). The presence of these quantified, externally verifiable experience claims establishes Quantified-Verifiable specificity.


fact: VP Security (VP-level cybersecurity leadership role)

fact: IT Risk and Compliance Team (specific cybersecurity organizational unit)

fact: IT Risk and Compliance Team reports to VP Security (management reporting line)

reasoning: The paragraph describes management organizational structure and reporting lines, specifically that the IT Risk and Compliance Team monitors controls and reports to the VP Security. The inclusion of the 'VP Security' title—a VP-level cybersecurity leadership role—and the specific team name provide firm-specific organizational details that establish Level 3 specificity.


reasoning: The paragraph describes procedural activities of the cybersecurity program (asset identification, assessment, monitoring, and classification), answering what the program does, which falls under Risk Management Process. The language consists of generic process descriptions ('assessment', 'monitoring', 'classification') that fail the ERM test—an enterprise risk professional could use identical terminology for financial or operational asset management—resulting in Generic Boilerplate specificity.


fact: Vice President of Information Systems

fact: reporting directly to the Company's Chief Financial Officer

reasoning: Paragraph primarily describes the governance chain and oversight structure: Board ultimate oversight → Audit Committee responsibility → VP of Information Systems reporting → Board updates, which is Board Governance. Specificity is Firm-Specific due to identification of a VP-level cybersecurity leadership role (Vice President of Information Systems) and the specific management reporting line to the CFO.


fact: regularly scanning our environment for vulnerabilities

fact: performing penetration testing

reasoning: The paragraph describes specific cybersecurity program activities—vulnerability scanning and penetration testing—which are core risk management processes rather than governance or organizational structure. Specificity is Domain-Adapted because it employs cybersecurity-specific practices (vulnerability scanning, penetration testing) that demonstrate domain expertise and would not appear in generic ERM language, but it lacks firm-specific details like named roles or quantifiable metrics such as team size or budget.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from vendors/service providers through oversight mechanisms like contractual obligations, security assessments, and questionnaires, which falls squarely under Third-Party Risk. The specificity remains Generic Boilerplate because the described activities (reviews, inspections, questionnaires, annual re-assessments) are generic vendor risk management procedures that any ERM professional could write; the text lacks specific cybersecurity domain terminology (e.g., SOC 2, penetration testing, encryption standards), firm-specific details (named roles, specific team compositions), or externally verifiable facts.


reasoning: The paragraph states a conclusion about whether cybersecurity risks have materially affected or are reasonably likely to materially affect business outcomes, which per Rule 5 is Strategy Integration. It contains no specific facts—only generic materiality language and a cross-reference—with no domain-specific practices, firm-unique organizational details, or externally verifiable claims (negative assertions about material impact are not independently verifiable).


fact: CCO (Chief Compliance Officer) responsible for assessing and managing material cybersecurity risks

fact: Investment Advisor engages third-party IT provider for cybersecurity resources

fact: Management monitors through communications with risk management, legal, information technology, and compliance personnel of the Investment Advisor

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by identifying the CCO as the responsible executive and describing the reliance on an external Investment Advisor and third-party IT provider for security resources. Specificity is Firm-Specific due to the identification of the CCO role and the specific Investment Advisor relationship, which distinguishes this company's organizational structure from generic disclosures.


fact: Chief Information Officer (CIO) - VP-level cybersecurity leadership role

reasoning: The paragraph primarily describes Board oversight of cybersecurity risks, including regular reviews of policies and periodic executive sessions with the CIO, answering how the board oversees cybersecurity. Specificity is Firm-Specific (Level 3) due to the identification of the Chief Information Officer, which is a VP-level leadership role with cybersecurity responsibility.


reasoning: The paragraph primarily addresses how the company manages cybersecurity risks associated with third parties, describing established oversight processes. It contains only generic language ('processes and procedures,' 'risk assessment') that fails the ERM test for domain expertise, and lacks any firm-specific details or verifiable facts.


reasoning: The paragraph describes applicable regulatory requirements (federal banking agency oversight, SEC disclosure rules effective December 18, 2023) and provides a cross-reference to another section, rather than describing the company's specific cybersecurity governance structures, management organization, risk management processes, or strategic integration. As regulatory context and cross-reference material without substantive cybersecurity program disclosure, it falls under None/Other and receives Generic Boilerplate specificity.


reasoning: The paragraph contains a backward-looking negative assertion about cybersecurity incidents ('We have not encountered any cybersecurity incidents since our Initial Public Offering'), which Rule 5 explicitly classifies as Strategy Integration. It also discusses potential material adverse consequences and financial loss, fitting the business/financial impact frame. For specificity, the paragraph contains no firm-specific details, domain-specific cybersecurity terminology, or verifiable facts—only generic statements about lacking resources and protection capabilities typical of early-stage SPACs without operations.


reasoning: This paragraph provides the mandatory SEC Item 106(b) materiality assessment, stating that cybersecurity threats have not materially affected the company (backward-looking) and are reasonably likely to materially affect the company if realized (forward-looking). It contains no specific facts, numbers, dates, named individuals, or domain-specific technical terminology—only generic materiality conclusions and cross-references to Risk Factors.


reasoning: The paragraph describes the company's high-level approach to cybersecurity (identifying and mitigating threats), which falls under Risk Management Process as it answers what the program does. The language is entirely generic ('places high importance,' 'identifying and mitigating,' 'potential cybersecurity threats') and fails the ERM test for domain expertise; it contains no firm-specific details, quantified metrics, or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph centrally addresses how cyber risks from vendors are managed through contract review and amendment processes, fitting Third-Party Risk (TP) under Rule 3. Specificity remains Level 1 because the description uses generic risk management and contractual language ('reviewing and updating contracts upon renewal,' 'security, confidentiality, and recourse') that would apply to any risk domain; it lacks specific cybersecurity controls (e.g., encryption, penetration testing), firm-unique program identifiers, or quantifiable facts.


reasoning: This paragraph consists of generic forward-looking speculation about potential cyber risks and a cross-reference to Item 1A for substantive discussion, containing no actual cybersecurity governance, management, process, or assessment disclosures (Rule 6 and Rule 5 cross-reference guidance). As a None/Other paragraph with no domain terms, firm-specific details, or verifiable facts, it receives Generic Boilerplate specificity.


reasoning: The paragraph describes technology infrastructure dependencies and general threat categories (ransomware, insider risk) but does not address board oversight, management organization, specific risk management activities, third-party oversight, actual incidents, or strategic business impact. As background/context without substantive cybersecurity governance or process disclosure, it is classified as None/Other and receives Generic Boilerplate specificity per the mandatory rule for this category.


reasoning: The paragraph is a cross-reference to Item 1A Risk Factors and contains generic forward-looking speculation ('may be materially affected') about potential cybersecurity threats without describing any actual governance structures, management roles, risk management processes, or third-party oversight programs. It lacks any domain-specific terminology, firm-specific details, or verifiable facts, constituting pure boilerplate language.


reasoning: The paragraph contains a negative materiality assessment ('has not experienced a cybersecurity threat that has materially affected the company'), which Rule 5 explicitly classifies as Strategy Integration. For specificity, the paragraph contains no domain-specific terminology (only generic references to 'cybersecurity threats'), no firm-specific details (no roles, names, or organizational structures), and no verifiable facts (negative assertions about incident absence are not externally verifiable per Level 4 guidelines).


fact: Senior Vice President – Technology Solutions (VP-level leadership role)

fact: reports directly to our President

fact: served in this role for over four years

fact: more than 25 years of experience in the aggregate

fact: more than ten years with the Company

reasoning: The paragraph primarily describes the audit committee's oversight responsibilities and the governance chain for cybersecurity risk management (Board → Committee → Officer), which is Board Governance content. It contains multiple verifiable, quantified claims about the Senior Vice President's tenure and experience (over four years in role, over 25 years total experience, over ten years with the Company), establishing Quantified-Verifiable specificity.


reasoning: The paragraph describes the Board's oversight responsibilities and governance role regarding cybersecurity risks, clearly falling under Board Governance. It contains no firm-specific details, domain-specific terminology demonstrating expertise, or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily presents a materiality assessment regarding the lack of impact from cybersecurity incidents on business strategy and financial condition, which falls squarely under Strategy Integration per Rule 5 (materiality assessment). The specificity is Generic Boilerplate because the text contains only standard SEC disclosure language, negative self-assertions about policy absence, and generic activities (keeping systems updated, educating personnel) that lack domain-specific terminology, firm-unique organizational structure, or quantifiable facts.


reasoning: The paragraph describes program activities—maintaining an incident response plan and conducting employee training—placing it in Risk Management Process. However, it uses generic boilerplate language ('incident response plan', 'annual training') explicitly listed as failing the ERM test, with no firm-specific details or verifiable facts.


reasoning: The paragraph primarily answers whether cybersecurity incidents have affected business outcomes by stating that no incidents during the reporting period materially impacted operations or financial condition, which is a backward-looking materiality assessment falling under Strategy Integration per Rule 5. It lacks domain-specific cybersecurity practices, firm-unique organizational details, or externally verifiable quantitative claims—containing only generic assertions about past attacks and forward-looking disclaimers—resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily describes cybersecurity program activities—risk assessments, safeguards implementation, monitoring, testing, and employee training—making it Risk Management Process. While it mentions 'IT leadership' reporting to the CEO and collaboration with HR/IT/management, these references lack specific VP-or-above titles with security portfolios or named committees required for Firm-Specific (Level 3). The language consists of generic risk management terms ('safeguards,' 'mitigate risks,' 'monitor and test') that pass the ERM test and do not demonstrate cybersecurity domain expertise (Level 2), nor does it contain any quantifiable or verifiable facts (Level 4).


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors rather than providing substantive cybersecurity disclosure about governance, management, processes, or incidents. It contains no firm-specific details, domain terminology demonstrating security expertise, or verifiable facts—only generic risk language and a pointer to another section.


fact: Technology Committee (named non-generic board committee responsible for cybersecurity oversight)

reasoning: The paragraph answers how the board oversees cybersecurity by describing the delegation of oversight from the full Board to the Technology Committee, which is a Board-level governance structure (Board Governance). The specificity is elevated to Firm-Specific by the identification of the 'Technology Committee'—a non-generic committee name that distinguishes this company's governance structure from the standard Audit Committee found at every public company.


fact: external and internal penetration testing

fact: emulate the common tactics and techniques of cyber threat actors

fact: remediate identified vulnerabilities across a wide range of severities

fact: onboarding risk assessments for third-party service providers

fact: cybersecurity-related contractual terms

fact: periodic risk assessments throughout the life cycle of the third-party relationship

reasoning: The paragraph primarily answers how third-party cyber risks are managed, detailing vendor onboarding assessments, contractual security requirements, and lifecycle risk monitoring, which places it in Third-Party Risk despite brief mentions of penetration testing (RMP) and insurance (SI). Specificity is Domain-Adapted because the text demonstrates cybersecurity expertise through technical practices like external/internal penetration testing, emulation of threat actor tactics, and vulnerability severity management, but contains no firm-specific details (e.g., named officers, committees) or externally verifiable claims (e.g., specific dates, numbers, named vendors).


reasoning: The paragraph primarily answers how third-party cyber risks are managed by describing contractual security requirements imposed on vendors (certification of security capabilities, breach reporting obligations), placing it in the Third-Party Risk category. It contains no firm-specific details (no named roles, committees, or organizational structures), no quantifiable metrics, and lacks specific cybersecurity domain terminology beyond generic references to 'security measures' and 'safeguards,' resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes operational activities of the cybersecurity program—engaging external assessors and utilizing detection technologies—which falls under Risk Management Process. However, the language is generic risk management terminology (engaging experts, conducting audits/assessments) that would apply equally to financial or operational risk management, with no firm-specific details, quantifiable metrics, or specific cybersecurity practices (e.g., penetration testing, named frameworks) that would elevate it beyond Level 1.


reasoning: This paragraph provides generic risk disclosure describing potential threats (viruses, hackers) and hypothetical impacts (operational disruption, data breach) without addressing any of the six substantive categories—it does not describe board oversight, management structure, specific program activities, third-party oversight, actual incidents, or materiality assessments. The language is entirely boilerplate speculation ('could materially and adversely affect') that could apply to any public company, containing no domain-specific terminology, firm-unique organizational details, or verifiable facts.


fact: phishing attempt

fact: phishing security test

fact: email that mimics a potentially harmful phishing attempt

reasoning: The paragraph describes specific cybersecurity program activities—employee security awareness training and phishing simulation testing—which demonstrate domain expertise through precise terminology (phishing threats, simulated attacks) rather than generic risk management language. It lacks firm-specific details (named vendors, specific roles) or quantifiable metrics (headcount, dates, certification numbers) that would elevate it to higher specificity levels.


fact: third quarter of fiscal year 2023 (timing of material incident)

fact: zero-day vulnerability

fact: file transfer application

reasoning: The paragraph primarily answers what happened in a past cybersecurity incident by specifying the timing (Q3 FY2023), attack vector (zero-day vulnerability), and affected system (file transfer application), making it Incident Disclosure. The specificity reaches Level 4 because the fiscal quarter of the incident is a hard, verifiable fact, and the description includes domain-specific terminology (zero-day vulnerability, file transfer application) demonstrating cybersecurity expertise.


fact: December 2022

fact: personal data of employees

fact: containment protocols

fact: forensics experts

reasoning: This paragraph describes a specific historical cybersecurity incident (December 2022 data extraction), including the timeline, nature of the incident (unauthorized extraction of employee personal data), response activities (investigation, containment protocols, forensics experts), and impact assessment, fitting Incident Disclosure. The specific date 'December 2022' is a verifiable fact tied to a real event (Level 4), while 'personal data of employees' provides firm-specific scope detail (Level 3), and 'containment protocols' and 'forensics experts' demonstrate domain-adapted cybersecurity vocabulary (Level 2).


fact: In the fourth quarter of fiscal 2025 (specific timeframe when unauthorized activity was detected and the incident occurred)

reasoning: The paragraph describes an actual cybersecurity incident, including when it was detected (fourth quarter of fiscal 2025), the nature of the activity, containment measures taken, and operational/financial impacts, which fits Incident Disclosure. The specific fiscal quarter provides a verifiable timeframe for the incident, satisfying Level 4 specificity despite the absence of monetary figures.


reasoning: The paragraph describes external regulatory requirements (SEC disclosure rules and federal banking agency oversight) and cross-references another section of the filing rather than answering any of the six substantive questions about the company's actual cybersecurity governance, management, processes, or strategy. As a None/Other paragraph, it is assigned Generic Boilerplate specificity.


fact: CISO (Chief Information Security Officer)

fact: DTRC (management committee)

fact: CyTOC (management committee)

fact: threat intelligence briefings

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, detailing the CISO's reporting line to the CEO, the Executive Committee's risk oversight role, and specific management committees (DTRC, CyTOC) involved in incident escalation. Specificity is Firm-Specific due to the identification of the CISO leadership role and named internal committees (DTRC, CyTOC), which distinguish FedEx's organizational structure.


fact: phishing simulations

fact: malware detection

fact: security awareness program

reasoning: The paragraph describes specific activities and components of the cybersecurity program (employee training content, testing methodologies), which directly answers what the program does, making it Risk Management Process. It employs cybersecurity domain terminology including 'phishing simulations' and 'malware detection' that demonstrate expertise beyond generic enterprise risk management vocabulary, but contains no firm-specific organizational details or quantifiable metrics that could be independently verified.


reasoning: The paragraph states a backward-looking materiality assessment that cybersecurity threats 'have not materially affected the company, including our business strategy, results of operations, or financial condition,' which is explicitly classified as Strategy Integration under Rule 5. The text contains no firm-specific details about cybersecurity organization, no domain-specific practices or tools, and no quantifiable or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph focuses centrally on managing cybersecurity risks from third-party service providers through due diligence and contractual requirements, fitting the Third-Party Risk category under Rule 3 (requirements imposed on vendors). For specificity, the language is entirely generic—describing 'due diligence,' 'cybersecurity practices,' and 'contractual commitments' without specifying what standards are reviewed (e.g., SOC 2), what measures are required (e.g., encryption), or any firm-specific details, resulting in Generic Boilerplate.


reasoning: The paragraph states a backward-looking materiality assessment that cybersecurity threats have not materially affected the company's business strategy, results of operations, or financial condition, which falls squarely under Strategy Integration per Rule 5. It contains no domain-specific terminology, firm-unique details, or externally verifiable facts—only a generic negative assertion—resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers whether cybersecurity has materially affected the business by stating that the company has not experienced any material cybersecurity incidents as of the reporting date, which is a negative materiality assessment explicitly classified as Strategy Integration under Rule 5. The paragraph contains no specific cybersecurity domain terminology (failing the ERM test), no firm-specific organizational details (e.g., roles, committees, team composition), and no externally verifiable facts—the specific date is reporting context rather than a cybersecurity fact, and negative assertions about incident absence are explicitly excluded from Level 4 per the guidance.


fact: CIO (VP-level cybersecurity leadership role)

fact: Senior Director, Information Protection & Compliance (Director-level title with security qualifier)

fact: management committee on cybersecurity (named non-generic committee)

reasoning: The paragraph describes the oversight structure and information flow from management to the Board and Audit and Finance Committee regarding cybersecurity risks, which is Board Governance. It reaches Firm-Specific specificity by identifying the specific management roles providing briefings (CIO and Senior Director, Information Protection & Compliance) and referencing a 'management committee on cybersecurity,' all of which distinguish this company's governance structure from others.


reasoning: The paragraph provides a backward-looking materiality assessment stating that no cybersecurity incidents have resulted in material adverse impacts, which falls under Strategy Integration per Rule 5. It contains no specific facts, credentials, dates (other than the filing date context), or domain terminology that would elevate it above boilerplate language.


fact: February 2025

fact: April 2025

fact: Microsoft

fact: Azure environment

fact: nation-state threat actor

reasoning: The paragraph primarily describes an actual cybersecurity incident, including the specific timeline (February and April 2025), the third party that notified the company (Microsoft), the affected system (Azure environment), and the threat actor attribution (nation-state), along with specific response actions taken. This constitutes Incident Disclosure. The specificity is Level 4 due to multiple independently verifiable facts: specific dates, a named third party, a specific platform, and a specific threat actor characterization.


reasoning: The paragraph describes the escalation path for material cybersecurity matters from senior management to the Audit Committee, constituting a board oversight governance structure (BG). The language is entirely generic, referencing standard governance roles (Audit Committee, senior management) without specific titles, reporting frequencies, or cybersecurity domain expertise, resulting in Generic Boilerplate specificity.


reasoning: This paragraph provides a backward-looking materiality assessment stating that no cybersecurity incidents have materially affected the company's strategy, results of operations, or financial condition, which falls under Strategy Integration per Rule 5. It contains no specific facts, domain terminology, firm-specific details, or verifiable claims—only a generic negative assertion—resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a standard forward-looking statements safe harbor disclaimer and section header that contains no substantive cybersecurity disclosure. It lacks any specific cybersecurity measures, governance details, or domain terminology, consisting entirely of generic legal boilerplate about forward-looking statements and risk factors.


fact: 24x7 Security Operations Center (SOC)

fact: Security Information and Event Management (SIEM) systems

fact: continuously monitor our network

reasoning: The paragraph describes specific cybersecurity program activities—maintaining a 24x7 SOC and employing SIEM systems for real-time threat monitoring—answering what the risk management process does. Specificity is Firm-Specific due to the organizational claim of 24x7 security operations and continuous network monitoring, which distinguishes this company's specific operational posture from generic cybersecurity descriptions.


fact: Chief Information Officer

fact: Information Security Officer

reasoning: The paragraph describes specific cybersecurity leadership roles (Chief Information Officer and Information Security Officer) and their organizational responsibilities regarding mandatory training, which falls under management structure and role definition. The specificity is driven by the naming of these C-level and officer-level positions, which are firm-specific facts that distinguish this company's cybersecurity governance structure.


reasoning: The paragraph identifies specific management positions (Senior Director of Information Technology, CEO, General Counsel, CFO), describes their qualifications ('worked in various roles responsible for securing networks'), and details their cybersecurity oversight responsibilities and escalation lines to the Audit Committee, fitting the Management Role category. Despite mentioning cybersecurity processes, the text contains no verifiable facts (no dates, numbers, certifications, or named individuals), no firm-specific details (titles like 'Senior Director of Information Technology' lack the required VP-level or security-specific qualifiers), and no domain-adapted terminology that would exceed generic enterprise risk management language.


reasoning: As a SPAC with no business operations, the company explicitly states it has not adopted any cybersecurity risk management program or formal processes, falling under Rule 6 for None/Other classification. Since this is a None/Other paragraph with no substantive cybersecurity measures, processes, or verifiable facts disclosed, it automatically receives Generic Boilerplate specificity.


reasoning: The paragraph provides generic contextual background about reliance on secure data processing and acknowledges exposure to cyber threats, but does not substantively answer any of the six category questions—it describes neither governance structures, management roles, specific risk management activities, third-party oversight programs, actual incidents, nor business strategy impacts. It contains no firm-specific details, quantifiable metrics, or domain-adapted terminology demonstrating cybersecurity expertise (e.g., specific frameworks, tools, or practices), consisting entirely of generic risk factor language applicable to any company.


fact: August 2020 (specific date of ransomware discovery)

fact: ransomware on a server (specific incident nature)

fact: engaged third-party forensics experts and outside counsel (specific response actions)

fact: did not pay ransom (specific action taken)

fact: no employee data or other personal information was accessed (specific impact assessment)

reasoning: The paragraph describes a specific historical cybersecurity incident (August 2020 ransomware event), including the nature of the attack, response actions, forensic findings, and remediation—fitting Incident Disclosure. Specificity is Level 4 due to the verifiable date, the specific claim that no ransom was paid, and the specific forensic conclusion that no employee data was accessed.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party service providers, including assessment criteria and contractual controls, fitting the Third-Party Risk category. It contains no domain-specific terminology (e.g., specific standards like SOC 2 or ISO 27001, security tools, or architectural concepts), firm-specific details (e.g., named roles, committees, or program identifiers), or verifiable quantitative claims (e.g., headcounts, dates, or certification statuses), remaining at Generic Boilerplate specificity.


reasoning: The paragraph answers how the Board oversees cybersecurity by describing the governance chain: the Board delegates oversight to the Audit Review Committee (ARC), which reviews risks, controls, and incident response capabilities, and receives information through regular management reviews. This is classic governance structure description, not management organization (MR) or process activities (RMP). Specificity remains Level 1 because the language consists entirely of generic enterprise risk management and audit committee terminology ('controls and procedures,' 'mitigate risks,' 'respond to and remediate incidents,' 'internal controls over financial reporting') that any ERM professional would use, with no domain-adapted cybersecurity expertise, firm-specific details (e.g., 'ARC' is simply the company's abbreviation for its standard Audit Committee), or verifiable facts.


reasoning: The paragraph functions solely as a cross-reference to Item 1A, containing no substantive answer to any of the six content questions. It employs generic enterprise risk management language ('subject to various cybersecurity risks') that any business professional could write, fails the ERM test for domain-adapted terminology, and offers no firm-specific details or quantifiable claims.


fact: $54,300 was incorrectly made to an unauthorized payee

fact: April 28, 2023 (date identified)

fact: June 29, 2023 (date recovered)

fact: recovered all of these funds

fact: phishing attack

reasoning: The paragraph answers 'What happened in a cybersecurity incident?' by describing an actual phishing attack with specific dates (April 28 and June 29, 2023), financial scope ($54,300), investigation findings, and recovery outcome, which is the definition of Incident Disclosure. Specificity is Quantified-Verifiable because it contains hard numbers ($54,300), specific calendar dates tied to real events, and an externally checkable claim about fund recovery that could be verified against bank records.


fact: third-party risk monitoring security rating services

reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party technology and services, including diligence, contractual protections, and monitoring tools, which falls squarely under Third-Party Risk. Specificity is Domain-Adapted because the reference to 'security rating services' demonstrates cybersecurity domain expertise (specific tools used to assess vendor security posture), while the paragraph contains no firm-specific details (named providers, team structures) or verifiable quantitative claims.


reasoning: The paragraph's central topic is vendor oversight (third-party risk management), describing activities like risk tiering, due diligence questionnaires, and vendor incident response procedures. While these relate to cybersecurity, the terminology ('risk management program,' 'assessments,' 'incident response procedures,' 'resiliency') consists of standard enterprise risk management language that fails the ERM test for domain expertise—no specific security practices, tools, architectural concepts, or named standards are mentioned. No firm-specific details (titles, named committees, organizational specifics) or quantifiable/verifiable facts (headcounts, dates, certifications, specific numbers) are present.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks related to third-party vendors and technology, describing vendor security assessments and insurance company risk reviews. However, the language is entirely generic—terms like 'security solution,' 'security assessments,' and 'risk assessments' could apply to any enterprise risk management context and fail the ERM test for domain expertise. No firm-specific details (named vendors, specific roles) or verifiable facts (named insurance company, dates, numbers) are present.


reasoning: The paragraph primarily answers whether cybersecurity has materially affected the business, stating explicitly that no material incident has occurred to date (backward-looking assessment per Rule 5 → Strategy Integration). The remainder consists of forward-looking speculation and risk cross-references without describing specific cybersecurity practices, governance structures, or incidents. No firm-specific details (roles, team composition, named programs) or verifiable facts (certifications, specific dates of events, headcounts) are present; the negative assertion regarding material incidents is explicitly excluded from Level 4 per the guidelines.


fact: $14.3 million of costs incurred

fact: July 23, 2023 (date of incident)

reasoning: The paragraph primarily describes a specific past cybersecurity incident, including the exact date (July 23, 2023), scope (affecting data and IT systems), response (forensic investigation), and financial impact, which qualifies as Incident Disclosure. The specificity is Quantified-Verifiable due to the hard dollar amount ($14.3 million) and specific date provided, both of which are externally verifiable claims.


fact: denial of service attacks

fact: unauthorized access, destruction, disclosure, disruption and modification of use

reasoning: The paragraph describes the purpose and scope of the company's Information Security program (protecting against unauthorized access, destruction, etc.), which answers what the cybersecurity program does. It rises to Domain-Adapted by specifying particular threat types (denial of service attacks) and detailed security objectives (the specific list of protections against unauthorized access, destruction, disclosure, disruption, and modification) that demonstrate cybersecurity domain knowledge beyond generic risk management language.


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

reasoning: The paragraph centrally addresses how third-party cyber risks are managed by describing reliance on the Adviser's cross-functional personnel to oversee risks associated with vendors and service providers. The specificity is Firm-Specific (Level 3) because it discloses the specific organizational arrangement of relying on the Adviser's personnel and enumerates the specific departments (risk management, legal, IT, compliance) involved in this oversight, distinguishing this company's approach from generic risk management descriptions.


reasoning: This paragraph contains generic forward-looking risk language acknowledging the importance of cybersecurity and potential impacts, but does not answer any of the six substantive questions (no board oversight, management roles, program activities, third-party oversight, incident details, or materiality assessments). It lacks domain-specific terminology (fails the ERM test), firm-specific details, and verifiable facts, consisting entirely of boilerplate risk disclosure.


fact: over 40 years of experience

fact: IT Security Steering Committee

fact: VP of Software Engineering

fact: Director of Information Systems and Security

fact: test and monitor for vulnerabilities and threats

reasoning: The paragraph describes specific cybersecurity risk management activities including vulnerability testing and employee training, and passes the person-removal test with substantive program content remaining after removing management titles. Specificity is driven by the externally verifiable claim of over 40 years of combined experience, along with firm-specific organizational details including the IT Security Steering Committee and specific leadership titles.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party vendors, including heightened scrutiny for those handling sensitive data types, which falls squarely under Third-Party Risk. However, the disclosure consists entirely of generic process descriptions ('risk-based approach,' 'additional scrutiny') without specifying actual security controls, assessment methodologies, contractual requirements, or domain-specific terminology that would demonstrate cybersecurity expertise; it lacks firm-specific details (named roles, committees, programs) and contains no quantifiable or verifiable facts.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from business partners and imposes standards on them, fitting the Third-Party Risk category. However, it employs generic enterprise risk management language ('comprehensive due diligence,' 'continuous monitoring,' 'stringent standards') that could apply to any type of vendor oversight and lacks specific cybersecurity domain expertise, firm-unique details, or quantifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes high-level oversight responsibilities for cybersecurity policy implementation and promoting corporate commitment, which are governance functions that default to Board Governance under Rule 1. The text contains no domain-specific terminology (e.g., 'policies and procedures' fails the ERM test), firm-specific details (no committees, titles, or organizational specifics mentioned), or quantifiable facts, resulting in Generic Boilerplate specificity.


fact: SOC reports

fact: complementary controls

reasoning: The paragraph primarily answers how third-party cyber risks are managed, focusing on vendor security assessments, SOC report reviews, and complementary controls, making it Third-Party Risk. Specificity is Domain-Adapted due to the use of cybersecurity domain terminology including 'SOC reports' and 'complementary controls' (specific audit/security concepts), with no firm-specific organizational details or externally verifiable claims present.


reasoning: This paragraph is a cross-reference pointer to Item 1A (Risk Factors) and does not provide substantive cybersecurity governance, process, or incident disclosure. It contains no firm-specific or externally verifiable facts—only generic references to IT dependency and risks—warranting Generic Boilerplate specificity.


reasoning: Paragraph describes Board oversight structure and activities (monthly updates, review/approval of risk assessments and policies), clearly answering how the board oversees cybersecurity. No domain-specific cybersecurity terminology (passes ERM test), no firm-specific organizational details beyond generic committee names, and no quantifiable or verifiable facts present.


reasoning: The paragraph states a backward-looking materiality assessment that cybersecurity threats have not materially affected the Company's business strategy, results of operations, or financial condition, which per Rule 5 is Strategy Integration. Specificity is Generic Boilerplate because the paragraph contains only standard SEC filing language and negative assertions about material impacts without any verifiable facts, domain-specific cybersecurity practices, or firm-specific organizational details.


reasoning: The paragraph discloses that Semnur is a SPAC with no business operations and has not adopted any cybersecurity risk management program or formal processes. Per Rule 6, SPACs and no-operations companies with no program are classified as None/Other. The text contains no domain-specific cybersecurity terminology, firm-specific organizational details, or quantifiable facts—only generic statements about the absence of operations and incidents—resulting in Generic Boilerplate specificity.


fact: stronger privileged access policies

fact: enhanced and expanded multi-factor authentication

reasoning: The paragraph describes specific remediation measures (privileged access policies, multi-factor authentication) implemented in response to a referenced cybersecurity incident, fitting Incident Disclosure. The specific technical controls mentioned demonstrate cybersecurity domain expertise, satisfying Level 2 specificity.


reasoning: The paragraph merely inventories generic business IT systems (accounting software, CRM, POS) and states that confidential information is collected, without addressing any of the six substantive cybersecurity questions (governance, management organization, risk processes, third-party oversight, incidents, or strategy impact). It contains no cybersecurity domain terminology, firm-specific details, or verifiable facts—only generic operational descriptions that could apply to any retail business.


reasoning: The paragraph describes the Audit Committee's oversight activities—periodic discussions and an annual review of the cybersecurity program—which is classic Board Governance content describing oversight structure and frequency. The language is entirely generic, containing no domain-specific cybersecurity terminology (failing the ERM test), no firm-specific details (e.g., specific titles, named committees beyond the standard Audit Committee, or organizational structures), and no quantifiable or verifiable facts.


reasoning: The paragraph centers on oversight of third-party service providers, describing vendor security assessments and monitoring, which fits the Third-Party Risk category under Rule 3. For specificity, the language consists of generic ERM-compatible phrases ('processes to oversee', 'thorough security assessments', 'ongoing monitoring') that fail the ERM test—swapping 'cybersecurity' for 'financial' yields standard vendor management language any risk professional could write, with no domain-specific practices, firm-unique details, or verifiable facts present.


reasoning: The paragraph primarily answers what the cybersecurity program does (standards adoption, software deployment, internal audits, vendor requirements), fitting Risk Management Process. Specificity is Domain-Adapted because the reference to 'System and Organizational Control (SOC) type reports' demonstrates cybersecurity domain expertise beyond generic risk management terminology, though no firm-specific details or verifiable facts are present.


fact: IT Steering Committee

fact: attack vectors

fact: continuous cyber monitoring

fact: reported vulnerabilities

reasoning: The paragraph primarily describes the company's cybersecurity activities (continuous monitoring, quarterly threat briefings, vulnerability trend analysis, and risk mitigation tracking), making it Risk Management Process rather than a focus on management structure. Specificity reaches Firm-Specific due to the named management committee 'IT Steering Committee,' which distinguishes this company's governance structure from generic frameworks, supplemented by domain-adapted terminology including 'attack vectors' and 'continuous cyber monitoring.'


reasoning: The paragraph provides a materiality assessment required by SEC Item 106(b)(2), stating that cybersecurity risks have not and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition. It contains no specific facts—only generic negative assertions and cross-references that are not externally verifiable, resulting in Generic Boilerplate specificity.


fact: CFO has been responsible for oversight function to the Company for three years

fact: CFO has worked in the financial services industry for more than 30 years

fact: CCO has been responsible for oversight functions for the Company for three years

fact: Current CCO has been serving since April 2025

fact: CCO has worked in the financial services industry for more than 35 years

reasoning: The paragraph centers on management's organizational structure for cybersecurity, identifying the CFO and CCO as responsible parties and detailing their specific tenures (three years in current roles; CCO serving since April 2025) and quantified industry experience (over 30 and 35 years), which are externally verifiable claims. It describes reporting lines (reliance on the Adviser's IT staff) and leadership qualifications rather than Board governance, risk management processes, or third-party risk programs.


fact: over 30 years of experience

fact: CIO Program Certificate from the College of Information and Cyberspace, National Defense University

fact: Certified Information System Security Professional (CISSP)

fact: Certified Information Privacy Professional (CIPP)

reasoning: The paragraph primarily describes the organizational structure of cybersecurity leadership (CISO reporting to CIO and coordinating with Chief Legal Officer) and extensively details the CISO's qualifications and credentials. The specificity is driven by externally verifiable facts including the CISO's 30+ years of experience and specific professional certifications (CISSP, CIPP, and CIO Program Certificate from National Defense University).


reasoning: This paragraph contains the SEC Item 106(b)(2) materiality assessment, stating that cybersecurity risks have not materially affected and are not reasonably likely to materially affect business strategy, results of operations, or financial condition. This is a classic Strategy Integration disclosure. For specificity, the paragraph contains only generic temporal references ('fiscal year 2023') and negative assertions about material impact that are not externally verifiable, with no domain-specific technical terminology, firm-specific organizational details, or quantifiable facts.