fact: over 7 years of experience leading cybersecurity teams and programs

reasoning: The paragraph describes the governance chain for cybersecurity oversight, emphasizing Board oversight responsibility, the delegation to the ITD and CFO, and the annual reporting and escalation processes to the Board. Specificity is driven by the quantified and verifiable claim regarding the Director of ITD's years of experience.


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph primarily answers whether cybersecurity has affected the business by stating a backward-looking materiality assessment that incidents have not materially affected business strategy, results of operations, or financial condition, which per Rule 5 classifies as Strategy Integration. The text contains no firm-specific details (e.g., named roles, committees, or programs), no domain-specific cybersecurity terminology (e.g., specific frameworks, tools, or technical practices), and no quantifiable or externally verifiable facts, resulting in Generic Boilerplate specificity.

provider: moonshotai

stage: benchmark


reasoning: The paragraph primarily answers whether cybersecurity has affected the business by stating a backward-looking materiality conclusion that past incidents have not materially affected business strategy, results of operations, or financial condition (Rule 5 SI materiality rule). It contains no specific facts—no domain terminology, firm-specific details, or verifiable data points—consisting only of generic risk language and negative assertions about materiality.


content_category: Board Governance

fact: CISO (Chief Information Security Officer)

fact: Chief Information Officer

reasoning: The paragraph describes the Board and Audit Committee's oversight structure for cybersecurity, including delegation to the Audit Committee and information flow protocols from management, which is Board Governance. It identifies specific VP-level leadership roles (CISO and CIO) responsible for cybersecurity reporting, which are firm-specific organizational facts distinguishing this company's governance structure.


content_category: Management Role

fact: Randy Jepsen (Vice President of IT)

fact: over 25 years of experience in the IT industry

fact: 19 years at Smith Douglas and The SMART Builder Solutions

fact: Russell Devendorf (Chief Financial Officer)

fact: oversaw IT and risk management functions at public homebuilder from 2008 to 2017

fact: combined experience of almost 50 years managing IT and internal audit functions

reasoning: This paragraph primarily answers how management is organized to handle cybersecurity by identifying the specific executives (VP of IT and CFO) responsible, their reporting structure, and their detailed qualifications. The specificity is Quantified-Verifiable due to named individuals (Randy Jepsen, Russell Devendorf), specific VP-level titles, and externally verifiable experience claims including 'over 25 years,' '19 years,' and the specific date range '2008 to 2017.'


content_category: Incident Disclosure

fact: late May 2023 - specific verifiable timeframe of the cybersecurity incident

fact: ransomware attack - domain-specific threat type

reasoning: The paragraph describes an actual, specific cybersecurity incident (a ransomware attack in late May 2023) and the company's response actions, clearly fitting Incident Disclosure. Specificity reaches Level 4 due to the verifiable specific date ('late May 2023') tied to the real event, while 'ransomware' also demonstrates domain-adapted terminology (Level 2).


content_category: Third-Party Risk

fact: third-party risk management (TPRM) program

fact: security controls

specificity_confidence: medium

reasoning: The paragraph centrally addresses how third-party cyber risks are managed through a TPRM program and assessment of vendors' security controls, fitting the Third-Party Risk category. Specificity is Domain-Adapted due to use of cybersecurity domain terminology ('TPRM' in security context, 'security controls') that demonstrates domain expertise beyond generic risk management, though no firm-specific details or verifiable facts are present.


content_category: None/Other

reasoning: The paragraph consists primarily of forward-looking disclaimers ('we may not be successful'), speculation about material adverse effects (explicitly excluded from Strategy Integration per Rule 5), and a cross-reference to Item 1A Risk Factors. As a None/Other paragraph, it receives Generic Boilerplate specificity.


reasoning: This paragraph is primarily a forward-looking disclaimer ('we may not be successful in preventing...') and cross-reference to Item 1A, both of which are explicitly classified as None/Other. While it mentions maintaining cybersecurity insurance, this is incidental to the disclaimer structure and does not constitute a substantive discussion of strategy integration. The paragraph contains no specific facts—only generic concluding language ('prioritizing cybersecurity,' 'protect interests of stakeholders') and unquantified speculation about material adverse effects.


content_category: Risk Management Process

reasoning: The paragraph describes incident response procedures (initial assessment, cross-functional review of attack scope, materiality measures, and response status) but uses generic enterprise risk management terminology that any ERM professional would apply to operational crises. Under the person-removal test, removing 'IT team' and 'cross-functional team' leaves substantive process content, confirming RMP over MR. No domain-specific cybersecurity terms (e.g., forensic analysis, containment playbooks), firm-specific organizational details (e.g., named departments, VP-level security roles), or verifiable facts (e.g., specific timeframes, headcounts) are present.


fact: 2024 cybersecurity incident involving unauthorized access of employee email account

fact: threat actor fraudulently diverted Company funds to its bank account

fact: immaterial impact to financial results

fact: no disruption to ability to generate revenues

reasoning: The paragraph describes an actual 2024 cybersecurity incident (business email compromise leading to fund diversion), including the attack vector, timeline, and impact assessment, which directly answers what happened in the incident. While it contains domain terminology ('threat actor'), the specificity is Firm-Specific because it details a real event unique to the company without Level 4 verifiable details such as specific dates (month/day), dollar amounts, or named forensic firms.


fact: Chief Information Security Officer

fact: incident response and recovery plans

fact: prevention, detection, mitigation and remediation of cybersecurity incidents

reasoning: The paragraph primarily describes cybersecurity activities—implementing a protection program, maintaining incident response and recovery plans, and monitoring prevention/detection/mitigation/remediation in real time—making it Risk Management Process (applying the person-removal test leaves substantive program description). Specificity is Firm-Specific because the paragraph identifies a 'Chief Information Security Officer,' a VP-level cybersecurity leadership role that distinguishes this company's organizational structure.


fact: encryption

fact: data loss prevention technology

fact: authentication technology

fact: entitlement management

fact: access control

fact: anti-virus and anti-malware software

fact: transmission of data over private networks

fact: National Institute of Standards and Technology Cybersecurity Framework

reasoning: The paragraph describes specific technical security controls (encryption, DLP, entitlement management, etc.) and references the NIST Cybersecurity Framework, demonstrating cybersecurity domain expertise (Level 2). It primarily answers what the cybersecurity program does by detailing protective technologies and risk categories, placing it in Risk Management Process.


reasoning: The paragraph primarily describes the company's cybersecurity risk management activities and capabilities (avoidance, identification, assessment, protection, detection, response, recovery) rather than governance structure or management roles. While it mentions Board and Audit Committee oversight in the final sentence, this is subordinate to the main focus on program operations. The language remains generic throughout—using phrases like 'processes and technologies,' 'significant investments,' and 'multiple teams' without specifying actual tools, standards, organizational structures, or quantified metrics that would elevate specificity above boilerplate.


fact: fiscal year ended September 30, 2025

fact: last 24 months

fact: firemen's access conduit

reasoning: The paragraph primarily answers whether cybersecurity has materially affected the business, stating no material cybersecurity incidents occurred in the last 24 months and describing a specific physical security incident that 'did not result in a material impact,' which aligns with Strategy Integration per Rule 5 (materiality assessments). Specificity is driven by the hard date 'September 30, 2025' tied to the actual incident and the specific 24-month timeframe, both externally verifiable temporal claims.


reasoning: The paragraph centers on the company's oversight of its IT consultant, requiring the consultant to maintain appropriate security measures and promptly report breaches, which directly answers how third-party cyber risks are managed (TP). It contains no specific facts—no named vendors, quantified metrics, dates, or technical domain practices—and relies on generic terms such as 'risk assessment processes' and 'policies and procedures' that appear in the Level 1 commonly-confused list, resulting in Generic Boilerplate specificity.


fact: vulnerability scans

fact: security questionnaires

fact: written security programs

fact: contractual information security obligations

reasoning: The paragraph centrally addresses vendor oversight—describing risk-based assessments and contractual security obligations imposed on third-party providers (Third-Party Risk). It demonstrates cybersecurity domain expertise through specific technical practices including vulnerability scans, security questionnaires, and written security program reviews, which exceed generic enterprise risk management vocabulary (Domain-Adapted).


fact: ISO 27001:2022 information security standard

fact: Security Operations Center (SOC)

fact: enterprise event visibility

reasoning: The paragraph describes the company's cybersecurity program activities—including risk assessment methodology (ISO 27001:2022), incident response lifecycle processes, and security operations infrastructure (SOC)—which answers what the program does (RMP). Specificity is Domain-Adapted because it references specific cybersecurity standards and technical infrastructure (ISO 27001:2022, SOC, enterprise event visibility) that demonstrate domain expertise beyond generic enterprise risk management language, without containing firm-specific organizational details or verifiable quantitative claims.


fact: CISSP certification

fact: CCNP certification

fact: CISA certification

fact: CySA+ certification

reasoning: The paragraph describes management's organizational responsibility for cybersecurity risk assessment and their professional qualifications, fitting the Management Role category. The specificity is driven by the enumeration of specific, externally verifiable professional certifications (CISSP, CCNP, CISA, CySA+) that can be independently confirmed through certification bodies, satisfying the Level 4 threshold despite the lack of specific years of experience or named individuals.


reasoning: The paragraph provides a backward-looking materiality assessment that cybersecurity risks 'have to date not materially affected us, our business strategy, results of operations or financial condition,' which is explicitly defined as Strategy Integration under Rule 5. Specificity is Generic Boilerplate because the text contains only generic statements about experiencing threats and cross-referencing Risk Factors, with no domain-adapted security terminology (e.g., specific tools, frameworks, or architectural concepts), no firm-specific organizational details (e.g., named roles, committees, or programs), and no externally verifiable facts (e.g., specific dates, numbers, certifications, or named third parties).


reasoning: The paragraph describes the governance chain—how management and the Risk Committee provide quarterly and annual cybersecurity updates to the board of directors, and how enterprise risk assessments flow to the board—which directly answers how the board oversees cybersecurity (Board Governance). It contains no firm-specific details (only generic 'Risk Committee' and 'board of directors' roles) and no domain-adapted terminology (only high-level labels like 'cybersecurity program' and 'enterprise risk assessment' that any ERM professional could apply to financial or operational risks), resulting in Generic Boilerplate specificity.


fact: Our CISO - VP-level cybersecurity leadership role

fact: threat landscape - domain-specific cybersecurity concept

fact: client security audits - domain-specific security assessment type

reasoning: The paragraph describes the Board's delegation of cybersecurity oversight to the Audit Committee and the upward reporting flow from the CISO to the Board and Committee, which is governance structure (BG). The mention of 'Our CISO' establishes a firm-specific cybersecurity leadership role (VP-level), satisfying the Firm-Specific threshold despite the absence of quantifiable metrics.


reasoning: The paragraph describes general risk management activities including identifying risks, evaluating safeguards, and employee training requirements, which directly answers what the cybersecurity program does (RMP). The language consists of generic risk management terminology ('procedures to help mitigate,' 'evaluating and improving effectiveness,' 'communication to employees') that would apply to any risk domain and contains no domain-specific expertise, firm-unique details, or verifiable facts, resulting in Level 1 specificity.


fact: CISO (Chief Information Security Officer)

fact: CIO (Chief Information Security Officer)

fact: briefing cadence of multiple times a year

reasoning: The paragraph primarily describes the Audit & Finance Committee's oversight responsibilities, briefing frequency, and information flow from management (CISO/CIO) to the board, which is classic Board Governance content. Specificity is Firm-Specific because it identifies the CISO and CIO as the specific officers briefing the committee and states the specific briefing cadence of 'multiple times a year,' distinguishing this company's governance structure from generic periodic review language.


fact: Senior Vice President of Engineering (VP-level leadership with cybersecurity portfolio)

fact: Chief Information Security Officer (CISO) (C-level cybersecurity leadership)

fact: CISO reports to Chief Executive Officer (specific reporting line)

fact: Chief Privacy Officer (C-level privacy/security leadership)

fact: Chief Privacy Officer reports to General Counsel (specific reporting line)

fact: Privacy and Security Council (named management-level committee)

reasoning: The paragraph primarily describes management's organizational structure for cybersecurity: specific VP-and-above leadership titles (SVP of Engineering, CISO, Chief Privacy Officer), their reporting relationships (CISO to CEO, Chief Privacy Officer to General Counsel), and a named management committee (Privacy and Security Council). This fits Management Role per Rule 2, as removing these person-specific organizational details would collapse the paragraph's substance. The specificity is Firm-Specific (Level 3) due to multiple verifiable C-level/VP-level cybersecurity leadership titles and a distinct committee name, with no quantified metrics or certifications present to reach Level 4.


fact: Chief Information Security Officer (CISO) identified as cybersecurity leadership role at VP level or above

reasoning: The paragraph describes the CISO's organizational responsibilities, coordination with corporate functions and business segments, and communication of risk posture to internal stakeholders, directly addressing how management is organized to handle cybersecurity. The explicit identification of a Chief Information Security Officer—a VP-level cybersecurity leadership role—constitutes a firm-specific fact per the Level 3 criteria, distinguishing this from generic governance descriptions.


fact: CIO (Chief Information Officer)

fact: Morgan Stanley's Cybersecurity Program

reasoning: The paragraph describes the Board's oversight structure and the specific information flow from management roles to the Board (CCO, CIO, CISO, Operational Risk), which is governance-chain content under Rule 1. Specificity is Firm-Specific because it identifies specific VP-level cybersecurity leadership roles (CIO, CISO) and references the named 'Morgan Stanley's Cybersecurity Program,' distinguishing this company's reliance on its parent's program.


fact: 17-year period (of experience at banking institution)

fact: Certified Information Systems Security Professional (CISSP)

fact: Bachelor of Science in Electrical Engineering and Mathematics from the University of Texas at Arlington

fact: Chief Information Security Officer (CISO)

fact: Enterprise Risk Committee (ERC)

fact: Operational Risk Committee (ORC)

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, detailing TPG's committee structure (ERC/ORC), the CISO role, reporting lines, and specific qualifications (17-year tenure, CISSP certification, degree from UT Arlington), making it Management Role. Specificity is Quantified-Verifiable due to the hard-number experience claim, named professional certification, and verifiable educational credentials.


fact: Management team supervision includes specific departments: legal, finance, and internal audit

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity by identifying specific departments (legal, finance, internal audit) that comprise the supervision structure. Under the person-removal test, removing these role-specific elements collapses the paragraph's supervisory framework. While it mentions domain terms like 'threat intelligence' and 'security tools,' these describe inputs to management oversight rather than program activities, keeping it in Management Role. The explicit naming of departments constitutes a firm-specific organizational fact, elevating specificity to Level 3.


reasoning: The paragraph describes the company's cybersecurity program activities including controls, risk assessment processes, monitoring, and incident response, which answers what the program does (Risk Management Process). It contains only generic ERM language such as 'policies and procedures,' 'protective measures,' and 'risk management strategy' without domain-specific terminology (e.g., specific tools, frameworks, or architectural concepts like zero trust), firm-specific details (e.g., named roles or committees), or verifiable facts (e.g., certifications, headcounts, dates), resulting in Generic Boilerplate specificity.


fact: Cybersecurity Leadership Team (named internal reporting entity)

reasoning: The paragraph establishes the governance chain for cybersecurity oversight (Board → Audit Committee → management), which is the defining characteristic of Board Governance. Specificity is Firm-Specific because the paragraph identifies the 'Cybersecurity Leadership Team' as a distinct, capitalized internal entity that reports to the Audit Committee, distinguishing PLAYSTUDIOS' organizational structure from generic descriptions.


reasoning: The paragraph centrally addresses vendor oversight through security assessments and monitoring of third-party providers, fitting the Third-Party Risk category (Rule 3: vendor oversight as central topic). While it mentions a 'Cybersecurity Manager' and 'security engineers,' these are below VP/Director level and lack qualifying details (certifications, reporting lines, team size) needed for Firm-Specific status. The described processes—quarterly assessments, ongoing monitoring, compliance checks—are standard vendor risk management activities that any ERM professional would articulate, containing no domain-specific security practices, architectural concepts, or tools (failing the ERM test for Level 2). The closing sentence regarding material impact is Strategy Integration, but the paragraph's primary focus and bulk concern third-party oversight.


fact: January 2023 (date of security incident)

reasoning: The paragraph describes an actual security incident experienced by the company's advisor in January 2023, detailing the timing, impact on system operability, response (reporting to federal law enforcement, restoration), and impact assessment, which directly answers what happened in a cybersecurity incident. The specific date 'January 2023' constitutes a verifiable fact tied to a real event, elevating specificity to Level 4.


reasoning: This paragraph states a negative conclusion regarding the absence of material cybersecurity incidents, which Rule 5 explicitly classifies as Strategy Integration (negative assertion). The text contains only generic risk disclosure language with no domain-specific terminology, firm-specific details, or verifiable quantitative claims, resulting in Generic Boilerplate specificity.


fact: CIO has over two decades (20+) of experience in technology development, management, and security

fact: CIO holds a technical undergraduate degree

fact: CIO holds a graduate business degree with a strong technical focus

fact: CEO has over 15 years of experience managing enterprise risks including cybersecurity threats

fact: CFO has over 15 years of experience managing enterprise risks including cybersecurity threats

fact: GC has over 15 years of experience managing enterprise risks including cybersecurity threats

fact: Each executive holds undergraduate and graduate degrees in their respective fields

reasoning: The paragraph focuses on the qualifications, experience, and educational backgrounds of specific management positions (CIO, CEO, CFO, GC), which is characteristic of Management Role. It achieves Level 4 specificity through multiple externally verifiable claims: specific experience thresholds ('over two decades,' 'over 15 years') and specific educational credentials (technical undergraduate degree, graduate business degree).


fact: over 24 years of experience in information technology and information security

fact: served as Chief Information Security Officer of a healthcare company

fact: holds undergraduate and graduate degrees in computer science

fact: over 50 years of collective experience managing enterprise risks

reasoning: The paragraph answers how management is organized by detailing the qualifications, credentials, and experience of specific leadership roles (VP of IT, NVP of Finance) and the Cybersecurity Response Committee. It is classified as Management Role because removing person-specific content (titles, experience, degrees) collapses the paragraph. Specificity is Level 4 due to multiple verifiable claims: quantified years of experience (24 and 50), specific educational credentials (degrees in computer science), and a verifiable previous position (CISO at a healthcare company).


fact: Chief Financial Officer oversees the information security program (C-level cybersecurity leadership)

fact: Vice President of IT oversees the information security program (VP-level cybersecurity leadership)

fact: Information Security Manager role exists in the reporting chain

fact: Weekly reporting cadence from Information Security Manager to VP of IT

fact: Quarterly reporting cadence from VP of IT to CFO and to Board

fact: Annual board overview of the information security program

fact: United States Computer Emergency Readiness Team (US-CERT) alerts processed (domain-specific threat intelligence source)

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity, detailing specific leadership roles (CFO, VP of IT, Information Security Manager), reporting lines between them (weekly, quarterly), and management-level cadences rather than describing board-level oversight mechanisms (BG) or program activities without organizational context (RMP). Specificity is Firm-Specific due to the identification of distinct executive officers responsible for cybersecurity and precise operational cadences (weekly, quarterly, annual), though it lacks externally verifiable data points like headcounts, dates, or certifications that would elevate it to Quantified-Verifiable.


fact: CIO (Chief Information Officer)

fact: Head of Operational Risk

fact: Non-Financial Risk Committee

fact: Firm Risk Committee

fact: BOTC

fact: dedicated management-level cybersecurity risk committees

reasoning: The paragraph describes the governance chain and information flow regarding cybersecurity risks from management-level committees up through Morgan Stanley's risk committees to the Company Board, answering how the board oversees cybersecurity. Specificity is driven by firm-specific organizational details including senior leadership titles (CIO, Head of Operational Risk) and named internal committees (Non-Financial Risk Committee, Firm Risk Committee, BOTC).


reasoning: While the paragraph opens with generic process descriptions (assessments, testing, audits), its primary purpose is to state a conclusion about materiality: that the company has not experienced a material cybersecurity event, which Rule 5 explicitly classifies as Strategy Integration. The paragraph also references whether risks are 'reasonably likely to materially affect' business strategy and financial condition. For specificity, the paragraph contains only generic ERM terminology ('assessments,' 'testing,' 'audits,' 'reviews') that would apply to any risk type and fails the ERM test for domain expertise; it lacks specific security practices, firm-unique organizational details, or quantifiable facts.


fact: Chief Operations Officer coordinates the Incident Response Plan

reasoning: The paragraph primarily describes the company's Incident Response Plan and its operational mechanics (framework, coordination, evaluation frequency), which falls under Risk Management Process. While it mentions the Chief Operations Officer and Bank Board, these describe how the process flows rather than governance oversight structure. The specificity is Firm-Specific due to the identification of the Chief Operations Officer as the specific coordination point for the incident response plan, distinguishing this organization's structure from generic descriptions.


reasoning: The paragraph describes the governance chain and escalation process from the cybersecurity team through the CFO to the CEO, Audit Committee, and Board of Directors, answering how the board is informed of cybersecurity issues. It contains only generic references to standard governance roles (CFO, CEO, Audit Committee) without firm-specific details, domain-specific terminology, or verifiable facts.