reasoning: The paragraph describes the general purpose of the cybersecurity program (guiding efforts to evaluate and improve confidentiality, integrity, and availability) but lacks any specific processes, tools, organizational structures, or verifiable facts. While it references the CIA triad, this terminology is generic enough to apply to other risk domains (e.g., financial data integrity) and fails the ERM test for domain expertise; it reads as generic risk management language adapted to cybersecurity.


content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes board/committee oversight by detailing how management reports cybersecurity risks and incidents to 'The Committee,' answering how the board oversees cybersecurity. The text contains only generic governance language—'periodic reports' and unspecified 'management' updates—lacking domain-specific terminology, firm-unique details (e.g., named committee, specific cadence, VP+ titles), or externally verifiable facts.

provider: moonshotai

stage: benchmark


content_category: Risk Management Process

reasoning: The paragraph describes the company's cybersecurity risk management processes intended to protect systems and data, which directly answers what the cybersecurity program does (Risk Management Process). However, the language ('developed and implemented cybersecurity risk management processes') is generic and fails the ERM test—swapping 'cybersecurity' for 'financial' yields standard ERM language. No domain-specific practices, firm-unique details, or verifiable facts are present, resulting in Generic Boilerplate specificity.


content_category: None/Other

reasoning: This paragraph is a pure cross-reference directing readers to Item 1A risk factor disclosures rather than answering any substantive cybersecurity question itself. As a cross-reference containing no actual cybersecurity measures, processes, or assessments, it falls under None/Other and receives Generic Boilerplate specificity per Rule 6 and the N/O threshold guidelines.


fact: hardening our environment

fact: vulnerability to attack

fact: cyber readiness

reasoning: The paragraph primarily describes cybersecurity program activities—internal audits, system hardening, and employee training—answering what the program does rather than who governs it or its business impact. Domain-specific terminology such as 'hardening' (system hardening), 'vulnerability to attack,' and 'cyber readiness' demonstrates specific cybersecurity expertise that would not appear in generic enterprise risk management disclosures, satisfying the ERM test for Level 2.


content_category: Management Role

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

fact: CIO's team - specific team composition for cybersecurity operations

fact: Collaborative structure between CIO, CEO, CFO, and General Counsel

fact: Management team monitors threats in real time and reports to Board

fact: incident response and recovery plans - cybersecurity domain terminology

fact: prevention, detection, mitigation and remediation - cybersecurity domain terminology

reasoning: Paragraph primarily answers how management is organized to handle cybersecurity, detailing specific leadership roles (CIO coordinating with CEO, CFO, GC), team composition (CIO's team), and internal reporting lines to the Board. Specificity is Firm-Specific due to identification of the CIO as the cybersecurity leader and description of team deployment, while also incorporating domain-adapted terminology such as 'prevention, detection, mitigation and remediation'.


reasoning: The paragraph describes the components and activities of the cybersecurity program (risk assessments, security controls, incident response plan, awareness training, third-party risk management), which aligns with Risk Management Process. However, it uses generic language that any ERM professional could apply to other risk domains ('risk assessments,' 'security controls,' 'procedures for responding') without demonstrating cybersecurity domain expertise, naming specific leadership roles, or providing quantifiable details, resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a pure cross-reference to Item 1A Risk Factors and contains no substantive cybersecurity disclosure, governance description, or process details. As a cross-reference with no specific facts, domain terms, or verifiable claims, it is classified as None/Other with Generic Boilerplate specificity.


reasoning: The paragraph functions primarily as a cross-reference directing readers to Item 1A for risk discussion, and contains only generic forward-looking statements about threat severity without answering any of the six substantive disclosure questions. No specific cybersecurity domain terminology, firm-specific details, or verifiable facts are present—only boilerplate risk language and administrative cross-referencing.


category_confidence: low

reasoning: The paragraph generically states the company recognizes the importance of assessing and managing cybersecurity risks and lists common risk categories (operational risks, IP theft, fraud), but does not describe specific methodologies, governance structures, or management activities that would answer any of the other category questions more precisely. The language consists entirely of standard enterprise risk management terminology that any non-security professional would use ('assessing, identifying, and managing material risks'), with no domain-specific practices, firm-specific details, or quantifiable facts to elevate specificity above boilerplate.


reasoning: The paragraph describes general IT infrastructure and business operations ('information systems,' 'cloud technologies,' 'purchased and licensed software') without addressing any substantive cybersecurity question regarding governance, risk management processes, or strategy. It contains no cybersecurity domain terminology that would distinguish it from general enterprise risk management language, no firm-specific organizational details, and no quantifiable or verifiable facts.


reasoning: This paragraph is a cross-reference directing readers to Item 1A for materiality assessments regarding cybersecurity risks rather than providing substantive disclosure itself. As a None/Other paragraph per Rule 6 and the cross-reference guidance in Rule 5, it receives Generic Boilerplate specificity.


fact: military veterans

fact: Master's degree in Cybersecurity

fact: forensic analysis

reasoning: The paragraph exclusively describes the cybersecurity leadership team's composition, qualifications, and collective experience (military background, degrees, certifications), which aligns with Management Role under the person-removal test. The specificity reaches Level 4 due to the quantified claim of 'over 23 years of combined Cybersecurity experience,' which sets a verifiable threshold that could be confirmed by summing individual team members' tenures.


fact: SaaS platforms

fact: cloud-based infrastructure

fact: encryption and authentication technology

fact: threat intelligence service providers

fact: cybersecurity software providers

fact: penetration testing firms

fact: Response, eradication and recovery

fact: Post-incident analysis

reasoning: Per Rule 3, third parties hired to serve the company (penetration testing firms, threat intelligence providers) fall under Risk Management Process rather than Third-Party Risk, as the paragraph describes external capabilities used by the program rather than vendor oversight requirements. The specificity is Domain-Adapted due to the use of cybersecurity-specific terminology including threat intelligence, penetration testing, encryption technology, and incident response lifecycle phases (response, eradication, recovery, post-incident analysis) that demonstrate domain expertise beyond generic risk management language.


reasoning: The paragraph describes cybersecurity responsibilities assigned to specific management roles (CFO and Head of IT), addressing how the company organizes its leadership to handle cybersecurity (Management Role). It contains only generic titles (CFO exists at every company; Head of IT is below VP level without a security qualifier) and high-level oversight activities (approving budgets, reviewing reports) without specific domain terminology, firm-unique organizational details, or externally verifiable facts.


fact: Advisory Committee of the Board of Managers of the general partner of our General Partner has oversight responsibility for cybersecurity threats

fact: Board of Managers receives findings and recommendations on cybersecurity matters

fact: Reports on cybersecurity risks and incidents are provided periodically during board meetings

reasoning: The paragraph primarily answers how the board oversees cybersecurity by describing the specific governance chain (Advisory Committee of the Board of Managers reporting to the full Board) and information flows from management. Specificity is Firm-Specific because it identifies the particular oversight body (Advisory Committee of the Board of Managers of the general partner) and the specific reporting cadence during board meetings, which distinguish this company's governance structure from generic descriptions.


reasoning: This paragraph is a pure cross-reference to Item 1A Risk Factors, containing no substantive cybersecurity disclosure about governance structures, management roles, risk management processes, or actual incidents. It merely directs readers to another section without describing any specific cybersecurity measures, organizational structures, or verifiable facts about the company's program.


content_category: Third-Party Risk

reasoning: The paragraph focuses exclusively on managing cybersecurity risks from third parties (vendors, service providers, external users), making it Third-Party Risk. The language consists entirely of generic risk management terminology ('comprehensive, risk-based approach,' 'identifying and overseeing') that would apply to any type of vendor risk and contains no specific cybersecurity practices, domain terminology, firm-specific details, or verifiable facts.


fact: NIST (National Institute of Standards and Technology)

fact: ISO (International Organization for Standardization)

fact: Confidentiality, integrity, and availability

reasoning: The paragraph describes the company's cybersecurity risk assessment methodology, framework adoption (NIST, ISO), and risk management approach, which falls under Risk Management Process. Specificity is Domain-Adapted because it references specific cybersecurity standards (NIST, ISO) and the CIA triad (confidentiality, integrity, availability), demonstrating domain expertise that would not appear in generic enterprise risk management language.


reasoning: The paragraph primarily answers how the Board oversees cybersecurity by describing the information flow from the IT department to the Board regarding security frameworks and incidents, which falls under Board Governance. The text contains only generic governance language ('periodically,' 'responsible for oversight') without domain-specific cybersecurity practices, firm-unique organizational details, or quantifiable facts, warranting a Generic Boilerplate classification.


fact: InfoSec Director

fact: eRISC committee

reasoning: The paragraph describes the organizational reporting structure of the company's cybersecurity function, specifically detailing how the InfoSec Director communicates with the eRISC committee and C-suite executives (CEO, CFO, CTO, GC) to escalate incidents to the Board. This focuses on management's organizational role and reporting lines rather than board oversight mechanisms. The specificity is Firm-Specific due to the mention of the distinct role 'InfoSec Director' (Director-level with security qualifier) and the uniquely named 'eRISC committee', which distinguish this company's structure from generic governance descriptions.


reasoning: The paragraph focuses on managing cybersecurity risks from third-party service providers and vendors, including onboarding and monitoring processes, which aligns with Third-Party Risk. The language is entirely generic, describing 'processes' and 'best practices' without specifying particular controls, frameworks, metrics, or verifiable facts, resulting in Generic Boilerplate specificity.


fact: GC Advisors (firm-specific entity reference indicating the cybersecurity program is operated by the investment adviser)

reasoning: The paragraph describes Board oversight mechanisms and the information flow from management (CFO/CCO) to the Board regarding cybersecurity matters, which is classic Board Governance content. Specificity is Firm-Specific because the paragraph references 'GC Advisors' (Golub Capital Advisors), a named entity specific to this corporate structure, distinguishing its cybersecurity program oversight from generic disclosures.


fact: threat detection

fact: continuous system monitoring

reasoning: The paragraph describes cybersecurity activities the company performs (program evaluation, system monitoring, threat detection, and assessments), which answers 'What does the cybersecurity program do?' Although third parties are mentioned as the agents performing these functions, the content focuses on the risk management activities themselves rather than vendor oversight protocols, placing it in Risk Management Process per Rule 3 (third parties hired for assessment/monitoring services). Specificity is Domain-Adapted due to the presence of cybersecurity domain terminology like 'threat detection' and 'continuous system monitoring,' which fail the ERM test (an enterprise risk professional would use generic 'risk monitoring' rather than 'threat detection'), but the paragraph lacks any firm-specific organizational details or verifiable claims.


reasoning: The paragraph describes the Board's awareness of cybersecurity risks and explicitly states that oversight has been delegated to the Audit Committee, directly answering how the board governs cybersecurity (Board Governance). The language consists entirely of generic governance and risk management terms ('oversight mechanisms,' 'operational integrity,' 'managing risks') that any ERM professional would use, with no domain-specific cybersecurity practices, firm-specific organizational details, or quantifiable facts.


fact: SVP, Engineering (VP-level role with cybersecurity responsibility)

fact: VP, Technology & CISO (VP-level role with cybersecurity responsibility)

fact: head of security and CISO positions at both public and private companies (prior experience of named officer)

reasoning: The paragraph identifies specific VP-level management positions (SVP, Engineering and VP, Technology & CISO) responsible for cybersecurity oversight, their reporting structure, and professional qualifications, which falls squarely under Management Role. Specificity is Firm-Specific because it discloses distinct VP-level leadership titles and organizational structure that distinguish this company's cybersecurity governance from others.


reasoning: The paragraph exclusively addresses how the company manages cybersecurity risks from vendors and service providers, fitting the Third-Party Risk category. It employs generic enterprise risk management terminology ('rigorous due diligence', 'oversight') that would apply equally to financial or operational vendor risk, failing the ERM test for domain-adapted specificity. It contains no firm-specific details (e.g., named roles, specific vendor requirements) or verifiable facts (e.g., assessment frequencies, named standards).


content_category: Strategy Integration

reasoning: The paragraph states a backward-looking materiality assessment regarding whether cybersecurity threats affected business strategy, results of operations, or financial condition, which per Rule 5 is Strategy Integration. It contains no specific facts, named individuals, quantified metrics, or domain-specific terminology beyond generic references to 'cybersecurity threats,' resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers whether cybersecurity risks have materially affected the business, stating a backward-looking materiality conclusion that no risks have materially affected the organization, which falls under Strategy Integration per Rule 5. The text contains no verifiable facts (no dates, numbers, certifications, or named entities), no firm-specific details (no leadership titles, committee names, or organizational specifics), and no domain-adapted terminology that would fail the ERM test (generic references to 'tabletop exercises' and 'risk management practices' are standard business continuity language).


content_category: Incident Disclosure

fact: In 2021, the Bank was the target of a ransomware attack

fact: sued in a purported class action lawsuit

fact: lawsuit is currently in process of settlement, subject to final court approval

reasoning: The paragraph primarily answers 'What happened?' by describing a specific 2021 ransomware attack, unauthorized data access, and resulting class action litigation with current settlement status, making it Incident Disclosure. Specificity is Level 4 because the paragraph contains verifiable hard facts including the specific year (2021), the exact nature of the legal proceeding (class action lawsuit), and its procedural status (settlement pending court approval), all of which could be independently confirmed through court records or news reports.


reasoning: The paragraph addresses board oversight of cybersecurity risks and the board members' lack of relevant experience, which directly answers how the board governs cybersecurity (Board Governance). However, it contains only generic governance references (explicitly listed as non-firm-specific) and general business terms like 'enterprise risk management' that fail the ERM test, with no domain-specific cybersecurity practices, verifiable facts, or firm-unique details.


reasoning: Per Rule 5, the paragraph's backward-looking and forward-looking materiality assessment ('have not... materially affected or are reasonably likely to materially affect') is a Strategy Integration conclusion. The paragraph contains no specific facts—only a negative assertion about incident absence and a cross-reference to Risk Factors—resulting in Generic Boilerplate specificity.


fact: Vice President of IT and Digital

fact: CISO

reasoning: The paragraph describes how specific management roles maintain current cybersecurity knowledge through external providers and seminars, addressing management qualifications and ongoing education (Management Role). The specificity reaches Level 3 due to the identification of firm-specific leadership positions: 'Vice President of IT and Digital' and 'CISO', which are VP-level titles with IT/security portfolios.


reasoning: The paragraph consists entirely of forward-looking speculation about potential future cybersecurity failures and their hypothetical consequences ('may not be able to detect,' 'may incur significant costs'), which constitutes generic risk factor boilerplate rather than substantive disclosure about actual governance, management, processes, or incidents. As pure speculation without measures, it falls under None/Other with no specific facts to elevate specificity above Level 1.


reasoning: The paragraph describes the company's cybersecurity processes, safeguards, and testing activities, answering what the program does (RMP). It contains only generic language ('processes for assessing risks', 'physical, procedural, and technical safeguards', 'tests on our systems') with no domain-specific terminology, firm-specific details, or verifiable facts, resulting in Generic Boilerplate specificity.


fact: firewalls

fact: intrusion prevention and detection systems

fact: anti-malware

fact: access controls

reasoning: The paragraph describes specific technical security controls (firewalls, intrusion prevention/detection systems, anti-malware) and the engagement of third-party service providers for security evaluations and audits, which addresses what the cybersecurity program does (Risk Management Process). Specificity is Domain-Adapted because the text employs specific cybersecurity infrastructure terminology that demonstrates technical domain knowledge beyond generic enterprise risk management language.


fact: senior IT executive with ten years of cybersecurity experience

fact: thirty-five years of experience in various technology domains

fact: experience includes both Fortune 500 and large semiconductor companies

fact: Cybersecurity Committee

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, detailing the specific qualifications and experience (10 and 35 years) of the senior IT executive responsible for oversight, which are externally verifiable claims, and referencing the firm-specific Cybersecurity Committee. It is Management Role rather than Board Governance because it focuses on executive and IT management responsibilities and a management-level committee structure rather than Board oversight, and the detailed resume facts would collapse to near-nothing under the person-removal test.


fact: accounting software, point-of-sale software, and back-of-house software

fact: confidentiality, integrity or access

category_confidence: medium

reasoning: The paragraph describes the scope and objectives of the cybersecurity program (protecting specific system types and data categories), which aligns with Risk Management Process. Specificity is Domain-Adapted due to the use of industry-specific system categories (POS, back-of-house) and the reference to the confidentiality, integrity, and access (availability) triad, which demonstrates cybersecurity domain knowledge beyond generic risk management language.


fact: Cybersecurity Steering Committee

fact: one director is the President of a major cybersecurity services provider

reasoning: The paragraph primarily answers how the board oversees cybersecurity by describing Board education, reporting cadence, and Audit Committee expertise, with the CISO and management committee mentioned only as part of the governance chain explaining information flow to the Board. Specificity is Firm-Specific due to the identification of the CISO leadership role, the named Cybersecurity Steering Committee, and the specific cybersecurity industry background of an individual director.


fact: chief information security officer

reasoning: The paragraph primarily describes the governance structure and information flow to the board, specifically that the chief information security officer presents quarterly reports on material cyber risks and mitigation efforts to the Audit Committee. The mention of a 'chief information security officer' (a VP-level cybersecurity leadership role) constitutes a firm-specific fact that elevates specificity to Level 3.


reasoning: The paragraph provides only generic introductory language acknowledging the importance of cybersecurity and referencing the confidentiality/integrity/availability triad without describing any actual governance structures, management roles, risk management processes, or specific security measures. As per Rule 6 and the N/O threshold guidance, this constitutes non-substantive boilerplate rather than a meaningful disclosure answering any of the six substantive questions.


fact: Head of Resources Management has more than 30 years of overall experience

fact: Head of Resources Management has more than 20 years directly assessing and managing cyber information technology systems

fact: CCO has more than 30 years of overall experience as a CPA

fact: CCO has more than 15 years managing information technology systems and databases

fact: CCO has 15-plus years supporting Adviser's and Administrator's resource management department

fact: Head of Resources Management is a member of the Board of Directors

reasoning: The paragraph primarily describes the organizational structure and qualifications of management personnel responsible for cybersecurity (Head of Resources Management and CCO), including their years of experience and professional credentials, which fits Management Role. Specificity is Quantified-Verifiable due to multiple hard-number claims about years of experience (30+, 20+, 15+, 15-plus) and the CPA certification, all of which are externally verifiable claims.


reasoning: The paragraph consists entirely of forward-looking disclaimers about security limitations and a cross-reference to Risk Factors (Item 1A), without describing any actual cybersecurity governance, management, processes, or incidents. It contains no specific facts, domain terminology, firm-specific details, or verifiable claims.


fact: core operating systems for manufacturing, wholesale and retail order processing and fulfillment, or financial reporting

fact: restore the IT systems and data

fact: investigation has not found evidence

specificity_confidence: medium

reasoning: The paragraph describes the timeline, operational impact, remediation status, and investigation findings of an actual cybersecurity incident (manufacturing interruption, order delays, system restoration), which fits Incident Disclosure. It demonstrates domain expertise by specifying categories of core operating systems affected and referencing forensic investigation and data restoration practices, meeting Level 2 specificity, though it lacks named individuals, specific dates, or quantified metrics that would elevate it to Level 3 or 4.


reasoning: The paragraph references cybersecurity activities (third-party assessments, industry certifications) and organizational structure, but lacks specific details about board oversight (BG), management roles (MR), or specific program methodologies. It contains no specific domain terminology (e.g., specific certification names like ISO 27001 or assessment types), firm-specific details (e.g., named roles or committees), or verifiable facts, consisting entirely of generic aspirational language that could apply to any company in any industry.


reasoning: The paragraph describes how the cybersecurity program integrates with enterprise risk management and shares governance processes, answering what the risk management framework entails (RMP). The language consists entirely of generic ERM terminology ('common methodologies,' 'reporting channels,' 'governance processes') that any enterprise risk professional would naturally use, with no domain-specific cybersecurity concepts, firm-specific structural details, or quantifiable facts.


fact: penetration testing

fact: offensive testing

fact: maturity assessments

fact: continuous monitoring for third-party cybersecurity incidents

fact: incident response program

fact: cyber phishing tests

fact: mandatory annual employee security awareness training focusing on cyber threats

reasoning: The paragraph describes specific activities of the cybersecurity program (assessments, testing, training, monitoring) rather than governance structure or management roles, placing it in Risk Management Process. It demonstrates domain expertise through specific cybersecurity practices like offensive testing, maturity assessments, and cyber phishing tests that would not naturally appear in generic ERM language, but lacks firm-specific details (named roles, team sizes, dates) or verifiable quantifications, resulting in Domain-Adapted specificity.


reasoning: The paragraph consists entirely of forward-looking speculation ('may not be successful', 'could have a material adverse effect') and a negative assertion regarding the absence of insurance coverage. Under Rule 5, hypothetical language ('could have') is classified as speculation rather than a materiality assessment, and per Rule 6, the paragraph describes no actual cybersecurity measures, processes, or assessments. No specific facts, domain terminology, or verifiable claims are present.


reasoning: The paragraph describes cybersecurity program activities including employee training, security awareness education, and incident response plan operation, which answer what the program does (Risk Management Process). The language consists entirely of generic terms like 'incident response plan' and 'annual training' that fail the ERM test for domain expertise, and contains no firm-specific details or verifiable facts.


fact: does not have its own cybersecurity policy

fact: contracts with CROs that handle all of its data and software

fact: reviewed the cybersecurity policies and procedures of our CRO

fact: require them to report any cybersecurity breaches or incidents

fact: 21 CFR 11 (Part 11) compliant

reasoning: The paragraph centrally addresses how the company manages cybersecurity risks through third-party CROs, including contractual oversight and vendor assessment, fitting the Third-Party Risk category. Specificity is Firm-Specific because the paragraph discloses the company's distinctive organizational posture of having no internal cybersecurity policy and fully outsourcing data handling to CROs—facts that uniquely identify this company's structure.


reasoning: The paragraph primarily answers how cybersecurity is overseen by describing a governance chain where the Board has overall responsibility and Management handles risk identification and monitoring. The text consists of generic risk management language ('identifying, assessing, and monitoring risks') that fails the ERM test for domain expertise, contains no firm-specific roles or details, and offers no externally verifiable claims—only a negative assertion about incident history that is not independently confirmable.


reasoning: The paragraph describes outsourced IT activities (vCIO services) performed by a managed service provider as components of the company's technology program, which falls under Risk Management Process (Rule 3: third parties hired to serve the company). However, the content consists entirely of generic IT service descriptions (operational review, policy development, SLA reporting) that lack domain-specific cybersecurity terminology, firm-unique details, or verifiable data points, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers how third-party cyber risks are managed by describing the quarterly executive summary process for third-party risk presented to leadership. The mention of a 'virtual Chief Information Security Officer (vCISO)'—indicating an outsourced or contracted cybersecurity leadership role rather than a full-time internal executive—provides a firm-specific organizational detail that distinguishes this company's approach, elevating the specificity to Level 3.


reasoning: The paragraph describes the Board's oversight role (being periodically informed, monitoring strategic risks) and contrasts it with executive officers' day-to-day management responsibilities, constituting a governance-chain description of oversight structure. The language is entirely generic—containing no domain-specific cybersecurity practices, firm-unique organizational details, or verifiable facts—and could apply to any public company's risk governance framework.


reasoning: The paragraph primarily answers whether cybersecurity affects the business by providing the SEC-required backward- and forward-looking materiality assessment ('have not materially affected... are reasonably likely to materially affect'), which is Strategy Integration per Rule 5. The brief mention of third-party due diligence is generic and subordinate to the materiality conclusion. The paragraph contains no domain-specific terminology that would fail the ERM test (terms like 'due diligence' and 'ongoing monitoring' are generic risk management concepts), no firm-specific organizational details, and no quantifiable or verifiable facts—only negative assertions and reporting period context.


reasoning: The paragraph describes how the company manages cybersecurity operations (protection, detection, and response) by outsourcing to a third-party subcontractor, which falls under Risk Management Process. The disclosure contains no specific domain terminology (e.g., specific tools, frameworks, or threat types), no firm-specific details (e.g., the subcontractor's name, internal titles, or organizational structure), and no quantifiable or verifiable facts, rendering it generic boilerplate.


reasoning: The paragraph describes the governance chain for cybersecurity oversight (Audit Committee → Board) and information flow from management to the committee, which answers how the board oversees cybersecurity. The language is entirely generic, containing no firm-specific details about the committee structure, cadence of reviews, or specific oversight mechanisms, and no verifiable facts.


reasoning: The paragraph states a backward-looking conclusion that cybersecurity has not materially affected the company's results of operations or financial condition, which falls under Strategy Integration per Rule 5 (SI materiality rule). The paragraph contains no specific organizational details, domain terminology demonstrating expertise (e.g., specific threat types, security frameworks, or technical controls), or verifiable facts—only generic negative assertions about incident history and forward-looking risk speculation—resulting in Generic Boilerplate specificity.


reasoning: The paragraph contains a backward-looking materiality assessment ('have not... materially impaired our operations or financial standing') and discusses cyber liability insurance coverage, both classic Strategy Integration topics under Rule 5. However, it lacks any specific facts: the materiality assertion is a negative self-report that is not externally verifiable (per Level 4 exclusions), and the insurance mention includes no quantified coverage amounts, carrier names, or policy details. The language ('cybersecurity challenges', 'cyber liability insurance') consists of generic business risk terminology that would be used by non-security ERM professionals, failing the domain expertise test for Level 2.


reasoning: The paragraph states a materiality assessment regarding cybersecurity risks as required by SEC Item 106(b)(2), asserting that no material incidents have been identified and none are reasonably likely to materially affect the company. This is the defining characteristic of Strategy Integration per Rule 5. The paragraph contains no specific facts, domain-adapted terminology, firm-specific details, or verifiable claims, consisting entirely of generic regulatory boilerplate language.


reasoning: The paragraph primarily answers how third-party cyber risks are managed, describing the use of external consultants for internal risk assessment processes and future intent to impose security certification requirements on vendors. The disclosure lacks specific cybersecurity domain terminology (e.g., specific standards, testing methods, or tools), firm-unique details (e.g., named roles, specific committee structures), or verifiable facts (e.g., named vendors, dates, certifications, headcounts), consisting instead of generic descriptions of vendor engagement and oversight that could apply to any enterprise risk management context.


reasoning: This paragraph contains a backward-looking materiality assessment stating that cybersecurity challenges have not materially impaired operations or financial standing, which falls squarely under Strategy Integration per Rule 5. The paragraph contains no specific facts—no dates, numbers, named roles, verifiable certifications, or domain-specific terminology that would distinguish it from generic boilerplate; the negative assertion about absence of material impact is not externally verifiable.


fact: triage

fact: eradicate

reasoning: The paragraph primarily answers how cybersecurity affects the business through an explicit SEC Item 106(b)(2) materiality assessment ('have not materially affected or are reasonably likely to materially affect') and discussion of cyber insurance coverage limitations. While it briefly references operational controls, the materiality conclusion and financial impact framing dominate. Specificity is Domain-Adapted due to precise incident response terminology ('triage', 'eradicate') that demonstrates cybersecurity domain expertise beyond generic risk management vocabulary.


reasoning: This paragraph states a conclusion about whether cybersecurity has materially affected business strategy, results of operations, and financial condition, which is the definition of Strategy Integration per Rule 5. The language is generic risk management boilerplate ('materially affect,' 'business strategy') that fails the ERM test—any ERM professional could write this by swapping 'cybersecurity' for another risk type. It contains no domain-specific security practices, firm-specific organizational details, or externally verifiable facts.


fact: World Gold Council (named entity providing reports to the Board regarding cybersecurity programs)

reasoning: The paragraph describes Board oversight mechanisms by detailing the reporting structure from the Sponsor's officers and the World Gold Council. The mention of 'World Gold Council' as a specific source of cybersecurity reports provides a named third-party entity that distinguishes this disclosure and serves as a verifiable fact.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for information about cybersecurity impacts on financial condition, rather than providing substantive disclosure about any of the six content categories. It contains no specific facts about the company's cybersecurity program, governance structure, or risk management processes—only a boilerplate incorporation by reference.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks arising from third-party service providers, including a vendor qualification program and reliance on providers for threat notification, which falls squarely under Third-Party Risk per Rule 3. For specificity, the text contains only generic descriptions of vendor oversight ('vendor qualification and management program') without naming specific assessment criteria (e.g., SOC 2), quantifying the vendor population, or identifying firm-specific roles or committees responsible for this oversight, resulting in Generic Boilerplate classification.


fact: Chief Compliance Officer plays oversight role in cybersecurity preparedness regarding third-party entities

fact: Reliance on risk management, legal, information technology, and compliance personnel of the Adviser for identifying and overseeing third-party cyber risks

reasoning: The paragraph primarily answers how third-party cyber risks are managed by describing oversight mechanisms involving the CCO and specific departments (risk management, legal, IT, compliance) of the Adviser. The identification of specific departmental roles and the CCO's cybersecurity oversight responsibilities provides firm-specific organizational detail.


reasoning: The paragraph primarily answers whether cybersecurity has or will affect business outcomes, containing backward-looking negative assertions ('have not experienced any material cybersecurity incidents') and forward-looking materiality assessments ('reasonably likely that we may expend greater resources'), which classifies as Strategy Integration per Rule 5. It lacks any domain-specific terminology, firm-specific details, or verifiable facts, consisting entirely of generic risk language that fails the ERM test and contains no quantifiable claims.


reasoning: The paragraph primarily addresses contractual security requirements imposed on third-party service providers (certification obligations, breach reporting), which is the central focus of Third-Party Risk. The language consists entirely of generic descriptions ('appropriate security measures,' 'reasonable security measures,' 'suspected breach') without firm-specific details, quantified metrics, or domain-adapted terminology that would demonstrate cybersecurity-specific expertise.


reasoning: The paragraph primarily answers whether cybersecurity risks have materially affected the business, stating that 'To date, these risks... have not had a material impact on our operations, business strategy or financial results'—a backward-looking materiality assessment that falls under Strategy Integration per Rule 5. Specificity is Generic Boilerplate because the paragraph contains only generic risk management language ('cybersecurity program,' 'governance procedures') that passes the ERM test, with no domain-specific terminology, firm-specific details, or verifiable facts (the negative materiality assertion is a self-reported conclusion, not an externally verifiable claim).


reasoning: The paragraph primarily answers whether cybersecurity risks are reasonably likely to materially affect the business by stating the required SEC Item 106(b)(2) conclusion that no such risks are currently known. Despite touching on management responsibility, the materiality assessment is the substantive content. The text contains no specific facts—only generic references to management responsibility and forward-looking materiality assertions without quantification, dates, or domain-specific cybersecurity terminology.


reasoning: The paragraph primarily answers whether cybersecurity risks have materially affected the business, containing the exact SEC Item 106(b)(2) materiality assessment language ('have not materially affected, or are reasonably likely to materially affect our business strategy, results of operations, or financial condition') and mentions cybersecurity insurance coverage without specific limits or costs. For specificity, the paragraph contains only generic assertions and required SEC safe harbor disclosures without any verifiable facts, firm-specific organizational details, or domain-specific cybersecurity terminology that would demonstrate expertise beyond standard enterprise risk management language.


fact: SOC reports

fact: complementary controls

reasoning: The paragraph primarily describes the company's oversight of third-party service providers, including security assessments and monitoring of SOC reports, which is central to Third-Party Risk. While it ends with a materiality statement, the vendor management content dominates. The use of specific domain terminology such as 'SOC reports' and 'complementary controls' demonstrates cybersecurity expertise, warranting Domain-Adapted specificity, though the disclosure lacks firm-specific organizational details or quantifiable metrics.


reasoning: The paragraph describes the Chief Executive Officer's assigned responsibilities for leading cybersecurity processes and reporting to the Board, which addresses how management is organized to handle cybersecurity (Management Role). The language consists entirely of generic governance and risk management terms ('risk assessment,' 'incident response plan,' 'prevention, mitigation, detection') that do not demonstrate cybersecurity domain expertise, contain no firm-specific structural details (e.g., named officers, specific committees), and include no quantifiable or verifiable facts.


reasoning: The paragraph contains generic risk disclosure language regarding the importance of cybersecurity and the threat landscape (ransomware, denial-of-service), but does not describe actual governance structures, management roles, risk management processes, or third-party oversight mechanisms. The material impact language uses speculative 'could' phrasing, which per Rule 5 explicitly disqualifies it from Strategy Integration. As None/Other, it receives Generic Boilerplate specificity.


reasoning: The paragraph describes the Board's delegation of cybersecurity oversight to the Audit Committee and the Committee's oversight of management's program implementation, which is a governance-chain structure (Board → Committee → Management) characteristic of Board Governance. It contains only generic oversight language ('considers cybersecurity risk as part of its risk oversight function,' 'delegated to our Audit Committee') that any ERM professional would naturally use, with no domain-specific terminology, firm-specific details (Audit Committee is a generic governance body per instructions), or verifiable facts.


reasoning: This paragraph makes a negative assertion about material cybersecurity incidents and their financial impact (no breaches, no expenses, no penalties), which Rule 5 explicitly classifies as Strategy Integration. For specificity, the paragraph contains only generic temporal references ('last three years') and unverifiable negative claims about the absence of incidents and expenses, with no domain-specific terminology, firm-unique organizational details, or externally verifiable facts.


reasoning: The paragraph primarily answers whether cybersecurity affects the business by stating that risks 'have not previously materially affected us' and are not 'reasonably likely to materially affect us,' which is a materiality assessment falling under Strategy Integration per Rule 5. The text contains only generic risk language ('preventative actions,' 'controls,' 'protect our systems') that fails the ERM test for domain expertise, with no firm-specific details or verifiable facts, resulting in Generic Boilerplate specificity.


fact: CDO has more than 20 years of executive IT leadership experience

fact: CDO joined MPC in 2021

fact: CDO was employed by GE and its subsidiary companies for over 20 years

fact: CDO was named Senior Vice President and Chief Information Officer of Services for GE in 2017

fact: CDO was named Vice President and Chief Information Officer of GE Healthcare

fact: CDO holds a Bachelor's degree in Business Administration, Management and Information Systems

reasoning: The paragraph focuses on the organizational structure (CISO reporting to CDO) and detailed qualifications/career history of the Chief Digital Officer, fitting Management Role. Specificity is driven by multiple independently verifiable claims including precise years of experience (≥20), specific employment dates (joined 2021, GE 2017), and educational credentials.


reasoning: The paragraph centrally addresses vendor cybersecurity oversight through contractual security requirements and due diligence, fitting the Third-Party Risk category. It employs generic process language ('risk-based due diligence,' 'reasonable security controls') that any ERM professional could apply to non-cyber risks, lacking specific domain terminology, firm-unique details (e.g., named programs, specific roles), or quantifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily addresses how the company manages cybersecurity risks from third parties by requiring service providers to certify security capabilities and report breaches, which falls under Third-Party Risk. The language consists entirely of generic vendor management terms ('appropriate security measures', 'reasonable security measures', 'suspected breach') without specific domain expertise, firm-unique details, or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers whether cybersecurity has or will materially affect business outcomes, stating a backward-looking negative conclusion ('does not believe that it has experienced any material cybersecurity incidents') and a forward-looking materiality assessment ('will not be materially impacted'), which falls under Strategy Integration per Rule 5. It contains no domain-specific cybersecurity terminology, firm-unique organizational details, or externally verifiable quantitative facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers whether cybersecurity has affected the business by stating a backward-looking materiality conclusion ('have not... materially impaired our operations or financial standing'), which qualifies as Strategy Integration under Rule 5. Despite containing a date (December 31, 2024), this is merely reporting-period context rather than a verifiable cybersecurity fact; the text otherwise consists of generic forward-looking speculation and cross-references with no domain-specific terminology, firm-unique organizational details, or quantifiable claims.


fact: ransomware attack on our computer network which occurred on April 28, 2023

fact: network returned to full operation on May 1, 2023

fact: ransomware

reasoning: The paragraph describes an actual ransomware attack with specific dates (April 28, 2023, and May 1, 2023), making it Incident Disclosure. The specific dates tied to a real event constitute externally verifiable facts, establishing Quantified-Verifiable specificity.


reasoning: The paragraph primarily answers whether cybersecurity has materially affected the business by stating the negative conclusion that the company 'has not experienced any unauthorized access resulting from cybersecurity incidents with a materially adverse effect,' which is a backward-looking materiality assessment per Rule 5 (Strategy Integration). It contains no specific facts, named individuals, quantifiable metrics, certifications, or domain-specific technical terminology (e.g., specific frameworks, tools, or practices), resulting in Generic Boilerplate specificity.


reasoning: The paragraph provides the SEC-required materiality assessment 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, which falls under Strategy Integration per Rule 5. The content consists solely of generic materiality conclusions and cautionary disclaimers without any specific cybersecurity practices, organizational details, or verifiable metrics—the date provided is merely a reporting anchor and the negative assertion regarding material effects is a self-reported conclusion that is not externally verifiable.


fact: Chief Information Security Officer (CISO)

fact: over 30 years of experience in cybersecurity

fact: Security Officer while in the United States Navy

fact: CISO at Amgen

fact: CISO at Warner Bros

fact: Cybersecurity roles at KPMG

fact: Forrester

reasoning: This paragraph describes the organizational role, responsibilities, and qualifications of the company's CISO, fitting the Management Role category. Specificity reaches Level 4 due to the verifiable claim of 'over 30 years of experience' (a quantified lower-bound) and the naming of specific former employers (US Navy, Amgen, Warner Bros, KPMG, Forrester) that could be independently verified against the officer's employment history.


fact: threat intelligence feeds

fact: vulnerability management

reasoning: Paragraph describes operational cybersecurity activities (incident response operations, vulnerability handling, threat monitoring) rather than governance structure or management roles, placing it in Risk Management Process. Specificity is Domain-Adapted due to technical terminology including 'threat intelligence feeds' and 'vulnerability management' which demonstrate cybersecurity domain expertise that would not naturally appear in generic enterprise risk management discourse.


reasoning: The paragraph primarily answers whether cybersecurity has affected the business by stating that 'threats and breach attempts have not materially affected our business, strategy, results of operations or financial condition,' which is a backward-looking materiality assessment classified as Strategy Integration under Rule 5. The paragraph contains no specific facts—only generic forward-looking speculation, a non-verifiable negative assertion about materiality, and a cross-reference—resulting in Generic Boilerplate specificity.


reasoning: The paragraph is split between Board Governance (describing the Board's commitment to remaining updated on regulations and overseeing process development) and Strategy Integration (the negative assertion regarding incident absence). The Board Governance content comprises the majority of the text, so it wins per the 'most text' tiebreaker rule. The paragraph contains no specific facts: the commitment language is generic ERM terminology that passes the ERM test, and the negative incident assertion is not externally verifiable.


reasoning: The paragraph states a conclusion that cybersecurity incidents have not materially affected the company and are not reasonably likely to materially affect its business strategy, results of operations, or financial condition, which is a materiality assessment falling under Strategy Integration per Rule 5. The text contains no domain-specific cybersecurity terminology (only generic references to 'threats,' 'security measures,' and 'information technology' that any ERM professional would use), no firm-specific organizational details, and no quantifiable or independently verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph provides a backward-looking materiality assessment stating that the company did not experience a material cybersecurity incident during the fiscal year, which falls squarely under Strategy Integration per Rule 5 (negative assertion). No specific facts elevate the specificity: the fiscal year date is reporting context rather than a verifiable cybersecurity fact, and negative assertions about incident absence are explicitly excluded from being externally verifiable under the Level 4 criteria.


reasoning: The paragraph provides a backward-looking and forward-looking materiality assessment regarding cybersecurity threats (stating that none have materially affected or are reasonably likely to affect business outcomes), which falls squarely under Strategy Integration per Rule 5. However, it contains only generic assertions about materiality and residual risk without any specific facts about the company's cybersecurity program, organizational structure, or verifiable metrics; the negative assertion about not identifying material threats is not externally verifiable, and the temporal reference 'In 2024' is merely reporting-period context rather than a substantive cybersecurity fact, resulting in Generic Boilerplate specificity.


reasoning: The paragraph explicitly states that Atlas Lithium, as an exploration stage company, has not yet adopted formal cybersecurity risk management programs or processes. Per Rule 6, no-operations/exploration-stage companies with no program receive N/O classification. While the paragraph mentions future commitments and the absence of customer data, it describes no actual cybersecurity measures, governance structures, management roles, or third-party oversight—only the lack thereof. The mention of 'material risks' does not constitute a materiality assessment per Rule 5 (no conclusion about business impact), and 'exploration stage company' is generic business classification rather than firm-specific cybersecurity governance.


reasoning: This paragraph is a forward-looking disclaimer and cross-reference to Item 1A Risk Factors that vaguely acknowledges past incidents without describing any specific event's nature, scope, timing, or impact. It contains no substantive disclosure about governance structures, management roles, risk management processes, or third-party oversight. As generic boilerplate language with no domain-specific terminology, firm-specific details, or verifiable facts, it qualifies as None/Other at the Generic Boilerplate level.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party service providers, including assessment timing (onboarding, renewal, ongoing monitoring) and evaluation of vendor controls, which falls squarely under Third-Party Risk per Rule 3. For specificity, the text contains only generic process descriptions ('risk-based approach,' 'design and operational effectiveness,' 'information security division') without domain-specific security terminology (e.g., specific frameworks, tools, or threat types), firm-unique organizational details (e.g., named VP-level roles, specific committees), or quantifiable/verifiable facts (e.g., headcounts, dates, certifications), resulting in Level 1 classification.


fact: ISAT (firm-specific team/committee acronym)

fact: penetration testing (domain-specific security practice)

reasoning: The paragraph describes third-party consultants assisting with security assessments and penetration testing, which are core activities of the cybersecurity program (RMP), not oversight of vendors. Specificity is Firm-Specific due to the reference to 'ISAT,' a named internal team acronym specific to the company's organization, supplemented by domain-adapted terminology including 'penetration testing.'


reasoning: This paragraph is a pure cross-reference ('incorporated by reference herein') directing readers to Item 1A for materiality disclosures rather than providing substantive cybersecurity content itself. It contains no specific facts—only generic references to 'cybersecurity threats,' 'cyber-attacks,' and 'information technology systems' used to describe the location of actual disclosures elsewhere in the filing.


fact: SMIS (firm-specific organizational entity/acronym)

fact: Cybersecurity Committee (named non-generic committee distinct from Audit Committee)

fact: SMIS's team (specific internal organizational unit)

fact: Specific governance chain: SMIS's team informs Cybersecurity committee of incidents; Cybersecurity committee and SMIS's team jointly inform Board of Directors and Audit Committee of adverse incidents

reasoning: The paragraph primarily answers how the board oversees cybersecurity by describing the reporting structure and information flow from management teams (SMIS) through committees to the Board and Audit Committee. Specificity is Firm-Specific due to the presence of the firm-specific acronym 'SMIS,' the named 'Cybersecurity Committee,' and the detailed organizational chart showing how incident information escalates through specific internal entities.


reasoning: The paragraph states a backward-looking conclusion that no cybersecurity incidents have had a material adverse effect on business or financial condition, which falls under Strategy Integration per Rule 5 (SI materiality rule). It contains no firm-specific details, domain-adapted terminology demonstrating cybersecurity expertise (e.g., specific practices, tools, or architectural concepts), or externally verifiable facts—only generic negative assertions and forward-looking speculation, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily describes senior management's responsibilities (day-to-day operations, reviewing incident reports, determining SEC filing obligations) and the internal reporting structure from business units to senior management, which aligns with Management Role. While it references the CGNC (likely the Corporate Governance and Nominating Committee), this is a standard board committee and the focus is on management's organizational duties rather than board oversight structure. The paragraph contains no firm-specific details (generic references to 'senior management' and 'business units'), no quantifiable data, and no domain-specific cybersecurity terminology that would demonstrate specialized expertise, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers whether cybersecurity has materially affected the business, containing explicit backward-looking ('have not been materially affected') and forward-looking ('reasonably likely to materially affect') materiality assessments per Rule 5, which defines Strategy Integration. Specificity is Generic Boilerplate as the paragraph contains only generic risk management terminology ('risk-based approach,' 'security controls,' 'remediation actions') that passes the ERM test, with no domain-specific cybersecurity practices, firm-specific details, or verifiable facts.


reasoning: The paragraph primarily answers whether cybersecurity risks have materially affected or are reasonably likely to materially affect the company’s business strategy, results of operations, or financial condition, which is a Strategy Integration assessment per Rule 5. It contains no firm-specific details (e.g., named officers, team structures), no domain-specific cybersecurity practices or tools (e.g., penetration testing, EDR), and no verifiable facts (e.g., specific dates of incidents, certifications, headcounts), consisting only of generic materiality language and cross-references to risk factors.


fact: monitor information systems for potential vulnerabilities

fact: identify, escalate, investigate, resolve, and recover from security incidents

fact: cybersecurity prevention and response systems

fact: third-party cybersecurity risk management process

fact: verification and validation of cybersecurity risks

reasoning: The paragraph primarily describes the company's cybersecurity activities and processes (assessing risks, monitoring systems, testing, using tools, incident response phases), which aligns with Risk Management Process. While it mentions board oversight, third-party due diligence, and a backward-looking materiality conclusion, these are subordinate to the detailed operational description of the program. Specificity is Domain-Adapted due to the use of technical terms such as 'vulnerabilities,' specific incident response lifecycle actions (escalate, investigate, resolve, recover), and 'prevention and response systems,' which demonstrate cybersecurity domain expertise beyond generic enterprise risk management language.


reasoning: The paragraph provides a materiality assessment regarding cybersecurity incidents, stating that none have materially affected or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which aligns with Strategy Integration per Rule 5 (backward-looking assessment). Specificity is Generic Boilerplate because the paragraph contains only negative assertions about incident materiality and regulatory cross-references without any domain-specific terminology (e.g., specific threat types, security tools, or frameworks), firm-specific details (e.g., named roles, committees, or organizational structure), or externally verifiable facts (e.g., specific dates, headcounts, certifications, or dollar amounts).


reasoning: This paragraph is a pure cross-reference/incorporation by reference that points to another section for materiality disclosures rather than providing any substantive cybersecurity content itself. It contains no specific facts, domain terminology, firm-specific details, or verifiable claims—only generic references to 'cybersecurity threats' and 'security breaches' in the context of directing readers to another disclosure location.


fact: Chief Financial Officer and Chief Executive Officer are the members of management responsible for managing and assessing our cybersecurity practices (firm-specific leadership roles at VP-or-above level)

fact: subsequent to June 30, 2024 (specific verifiable date)

reasoning: The paragraph establishes the governance chain for cybersecurity oversight, describing the Board's responsibility and delegating management functions to specific C-suite officers (CFO/CEO). Specificity reaches Level 4 due to the named executive roles with cybersecurity portfolios (firm-specific) and the precise temporal reference 'subsequent to June 30, 2024' (externally verifiable date).


fact: Energy Transfer's Chief Information Officer has more than 35 years of experience leading business technology functions

fact: Energy Transfer IT team members have over 50 years of combined experience in IT, including 20 years dedicated to cybersecurity

fact: Energy Transfer IT team holds Global Industrial Cyber Security Professional (GICSP) certifications

fact: Energy Transfer IT team holds Certified Information Systems Security Professional (CISSP) certifications

fact: Energy Transfer IT team holds Certified Ethical Hacker (CEH) certifications

fact: USAC's internal cybersecurity program is led by USAC's IT department

fact: USAC IT leadership team has an average of over 25 years of experience in IT operations

fact: USAC IT leadership team has over 10 years of experience in IT security

reasoning: The paragraph primarily describes management's organizational structure and qualifications (CIO oversight, IT department leadership, team composition) rather than board governance or specific risk management activities. It contains multiple verifiable facts including specific years of experience (lower bounds of 10, 20, 25, and 35 years) and named professional certifications (GICSP, CISSP, CEH) that can be independently verified through certification bodies.


fact: SOC reports

fact: complementary controls

reasoning: The paragraph primarily answers how third-party cyber risks are managed, describing security assessments, annual SOC report reviews, and complementary controls implemented to mitigate vendor-related data breach risks. While it concludes with a backward-looking materiality assessment (Strategy Integration), the substantive content focuses on vendor oversight processes. Specificity is Domain-Adapted due to precise cybersecurity terminology including 'SOC reports' (Service Organization Control audit reports) and 'complementary controls' (compensating security measures for third-party gaps), which demonstrate domain expertise beyond generic enterprise risk management language.


reasoning: The paragraph describes due diligence factors for vendor oversight, including reviews of vendors' information security controls and disaster recovery capabilities, which falls under Third-Party Risk management. The terminology ('third-party audit', 'business continuity', 'country risk') represents generic vendor risk management language that any enterprise risk management professional would use, lacking specific cybersecurity domain expertise, firm-specific details, or verifiable facts.


reasoning: The paragraph discloses the existence of a cyber liability insurance policy, which addresses how the company manages financial exposure to cyber risks (Strategy Integration). However, it contains no domain-specific cybersecurity terminology, firm-specific details (e.g., coverage amounts, named providers), or verifiable facts, resulting in a Generic Boilerplate specificity level.


fact: breach notification requirements

reasoning: The paragraph describes board oversight of cybersecurity investments, compliance, and legal counsel, fitting Board Governance. Specificity is elevated to Domain-Adapted by the inclusion of 'breach notification requirements,' a cybersecurity-specific legal compliance concept that would not naturally appear in generic enterprise risk management discourse and demonstrates domain knowledge of data privacy obligations.


reasoning: The paragraph primarily states a conclusion about whether cybersecurity risks have materially affected or are reasonably likely to materially affect the company's business and financial condition, which falls squarely under the Strategy Integration materiality rule (Rule 5). It lacks specific facts elevating specificity: the materiality assertion is a non-verifiable negative claim, and the board oversight description uses generic governance terminology ('considers cybersecurity risks as part of its risk oversight function') without identifying specific committees, leadership roles, or domain practices.


fact: threat modeling

fact: vulnerability testing

reasoning: Paragraph primarily describes specific cybersecurity program activities and assessment methodologies (threat modeling, vulnerability testing, information security maturity assessments) rather than board oversight structure or management roles, placing it in Risk Management Process. Specificity is Domain-Adapted because these technical practices demonstrate cybersecurity domain expertise beyond generic enterprise risk management terminology (an ERM professional would not naturally use 'threat modeling' or 'vulnerability testing' for financial/operational risks).


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

reasoning: The paragraph primarily describes the oversight structure and information flow between the CISO, Risk and Compliance Committee, and Board, answering how the board oversees cybersecurity (Board Governance). Specificity is Firm-Specific because it identifies the CISO, a firm-specific cybersecurity leadership role at the VP level or above.


reasoning: The paragraph primarily answers whether cybersecurity risks have materially affected the business, stating that they have not affected business strategy, results of operations, or financial condition to date, which is a backward-looking materiality assessment qualifying as Strategy Integration per Rule 5. However, it contains no specific facts—only generic risk language, vague temporal references ('from time to time'), and a negative materiality assertion that is not externally verifiable, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the activities of the IT Committee (assessing security layers, evaluating new technologies) and engagement of external experts to analyze infrastructure, which constitutes cybersecurity risk management processes rather than governance structure or management roles. The language is entirely generic—containing no named technologies, frameworks, individuals, quantified metrics, or verifiable claims—and relies on standard business terminology ('incremental improvements', 'new technologies', 'as necessary') that fails the ERM domain expertise test.


fact: regular scanning of both internal and externally facing systems

fact: annual third-party penetration testing

fact: security technologies intended to identify and assist in containing and remediating malware risks

fact: Active monitoring of logs and events for our network perimeter and internal systems

reasoning: The paragraph describes specific cybersecurity program activities and controls (scanning, penetration testing, malware containment, log monitoring, network perimeter defense), which are domain-specific practices requiring cybersecurity expertise. It contains no firm-specific organizational details (e.g., named officers, team compositions) or externally verifiable facts (e.g., specific dates, named vendors, certifications).


fact: February 2023 ransomware attack

reasoning: The paragraph describes a specific historical cybersecurity incident (the February 2023 ransomware attack), including the nature of the breach (unauthorized release of employee personal information), remediation actions taken, and specific timing. The explicit date 'February 2023' provides a verifiable temporal anchor that external parties could confirm against public incident records or the company's prior disclosures. While remediation expenditures are mentioned, they are framed as incident response actions rather than materiality assessments or business strategy impact, keeping the primary category as Incident Disclosure.


fact: October 15, 2025

fact: Federal Bureau of Investigation (FBI)

reasoning: The paragraph answers what happened in a specific cybersecurity incident, providing the exact date of discovery (October 15, 2025), describing the nature of the unauthorized access and deployed malware, and detailing the response including notification to the FBI and engagement of external experts. The specific date and named federal law enforcement agency constitute externally verifiable facts that elevate the specificity to Level 4.


fact: more than 20 years [of experience in information security]

fact: Deutsche Bank's Chief Security Officer

fact: global Chief Information Security Officer ("CISO") / CSO

fact: three different large European financial institutions

fact: partner position in a global strategy and consulting firm

fact: information security role holders at various seniority levels

reasoning: The paragraph describes the organizational structure, qualifications, and career history of Deutsche Bank's Chief Security Officer and supporting information security personnel, making it Management Role. Specificity is Level 4 due to the quantified, verifiable claim of 'more than 20 years' of experience (a checkable lower bound), alongside firm-specific details including the CSO/CISO title and specific career background.


fact: threat intelligence service providers

fact: penetration testing firms

fact: managed cybersecurity service providers

reasoning: The paragraph describes using external service providers to perform cybersecurity functions (threat intelligence, penetration testing, managed services), which under Rule 3 falls under Risk Management Process rather than Third-Party Risk. Specificity is Domain-Adapted because the text uses specific cybersecurity domain terminology (threat intelligence, penetration testing, managed cybersecurity services) that demonstrates expertise beyond generic risk management language, but contains no firm-specific details (named roles, programs, or organizational structures) or verifiable facts (named vendors, quantities, dates, certifications).


fact: Partnership with National Security Administration's Cybersecurity Collaboration Center

fact: Participation in U.S. Cybersecurity and Infrastructure Security Agency's Critical Partnership

fact: Membership in Federal Bureau of Investigation InfraGard

fact: Participation in U.S. Coast Guard Area Maritime Security Committees and Cybersecurity Subcommittees

fact: Participation in Cyber-Hawaii Maritime Transportation System Information Sharing and Analysis Center (MTS-ISAC)

reasoning: The paragraph describes specific external collaboration mechanisms and threat intelligence partnerships that constitute the company's cybersecurity risk management activities (RMP), not vendor oversight or governance structure. Specificity is Level 4 because it contains multiple named third-party entities and specific programs (NSA CCC, CISA Critical Partnership, FBI InfraGard, Coast Guard committees, MTS-ISAC) that represent independently verifiable claims about the company's security posture.


reasoning: The paragraph provides a materiality assessment regarding cybersecurity risks, stating that known threats have not materially affected the company and describing potential future material impacts, which falls under Strategy Integration per Rule 5. The paragraph contains no specific facts, verifiable claims, or domain-specific terminology—only generic materiality conclusions and cross-references to Risk Factors.


fact: Chief Information Security Officer (leadership role)

fact: 25 years of prior experience

fact: Certified Information Systems Security Professional (CISSP)

fact: Certified Information Systems Auditor (CISA)

fact: Certified in Risk and Information Systems Control (CRISC)

fact: Certified Internal Controls Auditor (CICA)

fact: Payment Card Industry Professional (PCIP)

fact: master's and bachelor's degrees in Computer Information Systems and Business Administration

reasoning: The paragraph describes the management structure for cybersecurity, specifically the Chief Information Security Officer's responsibilities and qualifications, which fits Management Role. Specificity is Level 4 due to the quantified years of experience (25 years) and multiple named, externally verifiable professional certifications (CISSP, CISA, CRISC, CICA, PCIP).


reasoning: Paragraph describes standard board oversight mechanics including committee reporting structures, meeting cadences, and escalation protocols using generic governance terminology ('periodic performance and effectiveness review,' 'regularly scheduled meetings') applicable to any risk oversight context. No domain-specific cybersecurity practices, firm-specific organizational details (e.g., named committees, specific titles), or verifiable quantitative claims are present.


reasoning: This paragraph is a pure cross-reference directing readers to Item 1A for risk and governance details, containing no substantive cybersecurity disclosure about the company's actual practices, oversight, or incidents. It lacks any specific facts, domain terminology, firm-specific details, or verifiable claims, consisting solely of generic directional language applicable to any SEC filing.


fact: Chief Information Security Officer

fact: vulnerability assessments

fact: threat environment

reasoning: The paragraph primarily answers how the Board oversees cybersecurity, describing Audit Committee oversight, quarterly management briefings, and annual discussions with the Chief Information Security Officer. Specificity is Firm-Specific due to the explicit mention of a 'Chief Information Security Officer' (a firm-specific cybersecurity leadership role), supplemented by domain-adapted terminology including 'vulnerability assessments' and 'threat environment'.


reasoning: The paragraph describes the Board of Directors' and Audit Committee's oversight responsibilities for cybersecurity, including briefing cadence, which directly answers how the board governs cybersecurity risk. The language consists of generic enterprise risk management terminology ('provides oversight,' 'integrates into overall evaluation,' 'primary responsibility') that could apply to any risk domain without modification, and contains no specific cybersecurity practices, firm-unique organizational details, or quantifiable facts.


reasoning: The paragraph contains the standard SEC Item 106(b)(2) materiality assessment language, stating conclusions that cybersecurity threats have not materially affected the company to date but are reasonably likely to materially affect future operations and financial condition if realized. This is a pure materiality/strategy impact assessment without any specific facts about the cybersecurity program, organizational structure, or specific threat types. The garbled text ('active interactions with children's hospitals...') does not constitute a clear firm-specific organizational fact or domain-adapted cybersecurity term.


fact: June of 2023 (incident date)

fact: early September 2023 (notification date)

fact: approximately $25,000 (incident expenses)

fact: two employees (affected email accounts)

reasoning: The paragraph primarily answers what happened in a specific cybersecurity incident, describing the June 2023 breach of two employee email accounts, notification timing, and remediation expenses. The presence of specific dates, a quantified financial impact ($25,000), and a specific number of affected accounts makes this Quantified-Verifiable.


fact: Our CEO is responsible for overseeing the day-to-day assessment and management of risks from cybersecurity threats

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, detailing the CEO's responsibility for oversight and the executive management team's role in Board reporting, which aligns with Management Role. The assignment of cybersecurity oversight responsibility to the CEO constitutes a firm-specific organizational fact (Level 3), as it identifies a specific C-suite role accountable for cyber operations; no quantifiable or externally verifiable facts are present to elevate to Level 4.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party service providers and supply chain partners through contractual security requirements and audits, fitting the Third-Party Risk category. The language consists entirely of generic vendor risk management descriptions ('enterprise risk management assessment program', 'agree by contract', 'conduct as appropriate') that an ERM professional could apply to financial or operational vendor risks, containing no domain-specific cybersecurity practices, firm-specific organizational details, or quantifiable facts.


reasoning: The paragraph describes the board's delegation of cybersecurity oversight to the audit committee and the committee's role in overseeing management's program implementation, which constitutes board governance structure. The text contains no domain-specific cybersecurity terminology, firm-specific organizational details, or quantifiable facts, consisting entirely of generic governance language applicable to any public company.


fact: Information Security Steering Committee (ISSC)

fact: executives from Legal, Accounting, Internal Audit and Risk Management, Cybersecurity and Facilities departments

reasoning: The paragraph establishes a management-level governance structure, describing the ISSC's composition and oversight responsibilities per Rule 1 (management committees → MR when focused on structure/membership). Specificity is Firm-Specific due to the non-generic committee name and the explicit list of participating departments.


reasoning: The paragraph addresses financial protection through cybersecurity insurance coverage (Strategy Integration), listing general categories of covered losses. It contains no quantifiable details (coverage limits, costs, providers), firm-specific program names, or technical domain terminology that would elevate it beyond generic disclosure.


fact: vulnerability scans

fact: penetration tests

reasoning: The paragraph describes the company's cybersecurity program activities—specifically risk assessment, vulnerability management, and security testing—which falls under Risk Management Process. Specificity is Domain-Adapted because the paragraph includes cybersecurity-specific technical practices (vulnerability scans and penetration tests) that demonstrate domain expertise beyond generic enterprise risk management language, but contains no firm-specific organizational details or quantifiable/verifiable facts.


fact: threat actors

fact: exfiltrated images of video meetings and computer screens

fact: closing off the point of unlawful access

reasoning: The paragraph answers 'What happened?' by describing a specific cybersecurity incident involving unauthorized access, data exfiltration, and extortion, fitting the Incident Disclosure category. Specificity is Domain-Adapted due to the use of cybersecurity domain terminology such as 'exfiltrated' and 'threat actors' (terms an ERM professional would not naturally use) rather than generic descriptions like 'stolen by hackers,' though the paragraph lacks firm-specific organizational details or quantifiable data that would elevate it to higher levels.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity threat information and contains no substantive disclosure about the company's cybersecurity governance, management, or processes. It is generic boilerplate with no specific facts, domain terminology, or verifiable claims.


reasoning: The paragraph primarily answers how third-party cyber risks are managed, describing governance frameworks, risk evaluation factors, and contractual controls imposed on vendors. However, it employs generic ERM language ('defined framework,' 'evaluate risk based on multiple factors,' 'mandatory contractual obligations') that could apply to any risk domain without modification, and contains no specific controls, technologies, organizational details, or verifiable facts.


reasoning: The paragraph is a cross-reference to Item 1A risk factors, containing no substantive cybersecurity disclosure about governance, management, processes, or strategy. It lacks any specific facts, domain terminology, or verifiable claims, warranting Generic Boilerplate specificity.


fact: As of March 31, 2023, all significant systems had been restored (specific date of restoration)

fact: DISH TV, SLING TV and Retail Wireless services remained operational during the incident (firm-specific business lines affected)

fact: Wireless and data networks remained operational during the incident (firm-specific infrastructure)

reasoning: Paragraph answers what happened during and after a cybersecurity incident by providing a restoration timeline (March 31, 2023) and operational status of specific business lines, which is classic Incident Disclosure. The specific restoration date serves as a verifiable fact (Level 4), while the named services (DISH TV, SLING TV, Retail Wireless) provide firm-specific context (Level 3).


fact: Mr. Dennis has served as our Director of Information Technology since June 2019

fact: founder of a data privacy consulting company

fact: over 20 years of experience

fact: system alerts of potential malicious cyber activity

fact: real-time dashboards

fact: daily, weekly and monthly basis

reasoning: The paragraph primarily describes specific cybersecurity monitoring activities (system alerts, real-time dashboards, status reports on daily/weekly/monthly cadences) and threat intelligence processes, which remain substantive after removing person-specific content per Rule 2, placing it in Risk Management Process. Specificity is Quantified-Verifiable due to externally verifiable claims including Mr. Dennis's specific start date (June 2019), his quantified experience (over 20 years), and his founding of a data privacy consulting company.


reasoning: The paragraph describes the company's cybersecurity program activities—implementing controls and technologies to assess, identify, and manage risks, and engaging third-party specialists for reviews—which fits Risk Management Process. The language is entirely generic risk management terminology ('processes to assess, identify, and manage,' 'controls,' 'technologies,' 'formal reviews') that would apply to any enterprise risk domain, with no domain-specific security practices, firm-specific organizational details, or quantifiable facts.


reasoning: The paragraph primarily answers whether cybersecurity has affected the business by stating that 'risks from cybersecurity threats have not materially affected our Company,' which is a backward-looking materiality assessment classified as Strategy Integration under Rule 5. The text contains no specific domain terminology (failing the ERM test), no firm-specific organizational details or named programs, and no verifiable facts—only generic references to 'defensive measures,' 'processes,' and 'controls' that could apply to any risk management context.


fact: anomalous activity

fact: threat landscape

fact: risk register

reasoning: The paragraph describes specific cybersecurity program activities including annual penetration testing, monitoring for anomalous activity, and maintaining a risk register, which are core risk management processes. Specificity is Domain-Adapted because the paragraph employs cybersecurity domain terminology—such as penetration tests, anomalous activity detection, and threat landscape analysis—that demonstrates specialized security expertise beyond generic risk management language.


fact: Senior Vice President of Information Technology

fact: Executive Vice President and Chief Accounting Officer

fact: Co-Chief Operating Officer

fact: IT Committee includes senior executives and other members of management

fact: minimum frequency of once per year

reasoning: The paragraph primarily answers how the Board oversees cybersecurity by describing the governance chain (IT Committee → senior officers → Board), briefing frequency, and Board participation in strategic decisions, placing it in Board Governance despite mentioning management committees. Specificity is Firm-Specific due to named VP-level and C-level management titles (SVP IT, CAO, Co-COO) and the specific IT Committee structure, which distinguish this company's oversight model from generic disclosures.


fact: March 2023

fact: $2.7 million of loss

fact: fraudulently-induced outbound wire transfers

fact: Note 18 to the accompanying consolidated financial statements

reasoning: The paragraph describes an actual cybersecurity incident from March 2023 involving fraudulent wire transfers, including specific details about the timeline, response actions, investigation, and quantified financial impact of $2.7 million, making it Incident Disclosure. The presence of specific dates, dollar amounts, and financial statement references provides externally verifiable facts supporting Level 4 specificity.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks stemming from third-party suppliers, including contractual protections (security and privacy addendums) and remediation workflows, which fits the Third-Party Risk category. However, it employs generic risk management phrasing ('processes and procedures,' 'continuously assess,' 'where applicable') without specifying assessment methodologies, contract requirements, or organizational structures, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily answers whether cybersecurity has affected or will affect the business by providing the SEC-mandated backward-looking and forward-looking materiality assessments ('have not materially affected,' 'reasonably likely to materially affect') and mentioning cybersecurity insurance coverage, which falls squarely under Strategy Integration per Rule 5. It contains no specific facts, domain-adapted terminology (only generic references to 'processes,' 'preventative measures,' and 'breaches' that any ERM professional could write), or verifiable claims—the negative materiality assertions are self-reported and not externally verifiable.


fact: National Institute of Standards and Technology

fact: Center for Internet Security Controls

reasoning: The paragraph answers what frameworks the cybersecurity program uses (NIST, CIS Controls), placing it in Risk Management Process. Specificity is Domain-Adapted because it references named cybersecurity standards that demonstrate domain expertise, but lacks firm-specific organizational details (e.g., named officers, team size) or externally verifiable claims (e.g., certifications maintained, specific dates).


fact: service provider oversight committee

fact: Security assessments

fact: questionnaires

fact: onsite visits

reasoning: The paragraph is centrally about oversight of third-party service providers and security assessments of vendors, fitting Third-Party Risk. Specificity is Firm-Specific due to the existence of a dedicated 'service provider oversight committee' (a non-generic management committee specific to this company), supplemented by domain-adapted details describing specific security assessment methodologies (questionnaires, onsite visits).


fact: continuous monitoring of our cybersecurity environment

fact: investigation and remediation of events

fact: ongoing security reviews for critical suppliers

fact: security controls assessed for third-party providers part of the financial reporting system

reasoning: The paragraph primarily answers how third-party cyber risks are managed, describing vendor oversight through ongoing security reviews and differentiated assessment criteria for suppliers involved in the financial reporting system. Specificity is Domain-Adapted because the text demonstrates cybersecurity domain expertise through references to continuous monitoring, event investigation/remediation, and security controls—terminology specific to cybersecurity operations that would not naturally appear in generic enterprise risk management discourse.


fact: Chief Executive Officer responsible for assessing cybersecurity risks and confirming cybersecurity strategy

fact: Senior Vice President, Finance and Chief Financial Officer responsible for assessing cybersecurity risks and confirming cybersecurity strategy

fact: meet at least quarterly to review and assess potential cybersecurity threats

reasoning: Paragraph describes management's organizational responsibility for cybersecurity, specifically detailing the CEO and CFO's roles in risk assessment and strategy oversight, their enterprise risk management experience, and their interaction with IT staff. Specificity is driven by the verifiable claim that threat reviews occur 'at least quarterly' and the firm-specific identification of C-suite executives (including the SVP Finance/CFO title) holding cybersecurity responsibility.


reasoning: The paragraph primarily answers what the cybersecurity program does by listing implemented measures (security technologies, internal controls, network resiliency, disaster recovery, backup systems) and describing the risk environment. However, it fails to achieve Domain-Adapted specificity because terms like 'disaster recovery,' 'backup systems,' and 'internal controls' are standard business continuity language that any ERM professional would use (failing the ERM test), and the paragraph contains no firm-specific organizational details or verifiable quantitative claims.


fact: IT security infrastructure designed for third-party risk monitoring

fact: contractual controls to restrict information access

fact: risk-level-based vendor tiering (heightened requirements for certain vendors)

fact: comprehensive data lifecycle coverage (store, process, collect, share, create, transmit, destroy, access)

reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from vendors, including its Vendor Management Policy, tiered risk assessments, and contractual controls, making it Third-Party Risk. It demonstrates cybersecurity domain expertise (Level 2) by detailing specific data lifecycle stages requiring protection and describing a risk-based tiering approach for vendor oversight, though it lacks firm-specific identifiers (e.g., named roles, specific dates) or externally verifiable claims (e.g., SOC 2 requirements, named vendor count) that would elevate it to Level 3 or 4.


fact: March 31, 2023 system restoration date

fact: DISH TV and SLING TV services remained operational during incident

reasoning: The paragraph answers 'What happened in the cybersecurity incident?' by providing a specific restoration timeline (March 31, 2023) and operational status of named services (DISH TV and SLING TV), which is classic Incident Disclosure. The hard date and specific service names provide externally verifiable facts, elevating specificity to Quantified-Verifiable.


reasoning: The paragraph serves as a cross-reference directing readers to Part I, Item 1 for regulatory oversight details rather than answering any of the six substantive cybersecurity questions about the company's governance, management, or program. It contains no domain-specific cybersecurity terminology, firm-unique organizational details, or externally verifiable facts—only generic statements about regulatory applicability applicable to all banking institutions.


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

fact: Federal Financial Institutions Examination Council (FFIEC) Information Technology Examination Handbooks

fact: FFIEC Cybersecurity Assessment Tool

reasoning: The paragraph primarily describes the company's cybersecurity program objectives, alignment with specific industry frameworks, and review processes, which are core risk management activities rather than governance or management organizational details. Specificity is Domain-Adapted because it references specific cybersecurity frameworks (NIST CSF, FFIEC handbooks, and the FFIEC Cybersecurity Assessment Tool) that demonstrate specialized domain knowledge beyond generic enterprise risk management language; no firm-specific organizational details or externally verifiable quantitative claims are present.


reasoning: This paragraph provides the SEC Item 106(b)(2) forward-looking materiality assessment that no known cybersecurity risks are reasonably likely to materially affect the company, which falls squarely under Strategy Integration per Rule 5. It contains no specific facts elevating it beyond Level 1: it uses generic risk management language ('periodically evaluates,' 'processes') without domain-specific cybersecurity practices, cites unnamed consultants rather than firm-specific roles or named individuals, and offers no quantifiable metrics or verifiable claims.


reasoning: The paragraph centrally addresses vendor oversight, describing diligence processes, contractual security requirements, and audit rights imposed on third-party service providers, which aligns with the Third-Party Risk category. The language consists of generic risk management terminology ('perform diligence,' 'continually monitor,' 'cybersecurity audits') that any enterprise risk management professional could apply to non-cybersecurity vendor risks, failing the ERM test for domain expertise. While the mention of 'patient data' indicates the healthcare sector, this reflects business context rather than cybersecurity domain knowledge, and the negative assertion regarding high-risk vendors ('currently none') is neither firm-specific in structure nor externally verifiable.


reasoning: The paragraph describes the company's incident response planning activities, which is a core Risk Management Process category topic. However, the content consists entirely of generic statements ('established an incident response plan,' 'defining roles, responsibilities, and steps to recover') that fail the ERM test—this language could apply to any operational or business continuity risk program without demonstrating specific cybersecurity domain expertise, and contains no firm-specific details or verifiable facts.


reasoning: The paragraph primarily states a materiality assessment regarding whether cybersecurity risks have affected or are reasonably likely to affect business strategy, operations, and financial condition, which falls under Strategy Integration per Rule 5. The text contains only generic risk language and a reporting-period date anchor without specific cybersecurity domain terminology, firm-unique organizational details, or externally verifiable facts, resulting in Generic Boilerplate specificity.


fact: June 2018

fact: $10 million

reasoning: The paragraph primarily answers how cybersecurity affects business outcomes by stating a materiality conclusion (that risks have not materially affected business strategy, results of operations, or financial condition and are not reasonably likely to do so) as required by SEC Item 106(b)(2), using the June 2018 incident as an illustrative example. Specificity is Level 4 due to verifiable hard facts including the specific date (June 2018) and financial impact ($10 million) of the disclosed incident.


reasoning: This paragraph provides a materiality assessment regarding whether cybersecurity risks have affected or are likely to affect business outcomes, which is the defining characteristic of Strategy Integration (Rule 5). For specificity, the paragraph contains only a negative assertion about material impact that is not externally verifiable, generic business impact categories, and no domain-adapted cybersecurity terminology or firm-specific organizational details, resulting in Generic Boilerplate classification.