fact: Director of Information Technology (DIT) is primarily responsible for cybersecurity

fact: DIT has over 20 years of experience in information security, risk management, and compliance

reasoning: The paragraph's primary content is about who is responsible for cybersecurity (the DIT), their qualifications, reporting lines (Audit Committee → CEO → DIT), and support structure — classic Management Role content. Person-removal test collapses it. Specificity reaches Level 4 because 'over 20 years of experience' is a verifiable lower bound checkable against a resume.

thinking:
Let me analyze this paragraph.

Category: This describes the governance chain (Board → Audit Committee → CEO → DIT) and the DIT's role, qualifications, and support structure. The primary question answered is "How is management organized to handle cybersecurity?" - it's about who is responsible (DIT), their qualifications (20 years experience), and reporting lines. By the person-removal test, removing the DIT's details leaves almost nothing substantive. → Management Role.

Specific facts:
- "Director of Information Technology (DIT)" - this is a Director-level title WITHOUT a security qualifier (it's IT, not "IT Security" or "Information Security").

The title itself doesn't meet the firm-specific threshold since the rules exclude plain "Director of IT" or "Director of Information Technology" without a security qualifier. However, the "over 20 years of experience in information security" is a concrete, verifiable lower bound that pushes this to Level 4. The audit committee oversight and CEO direction are standard governance structures, not firm-specific.


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph makes explicit materiality assessments — no material incident in 2023, not aware of risks reasonably likely to materially affect business, and does not believe results have been materially adversely affected — all of which are conclusions about whether cybersecurity affects business outcomes, squarely SI under Rule 5. The negative assertions ('did not experience a material cybersecurity incident') are self-reported claims about absence and not externally verifiable; the cross-references to risk factor headings are N/O-type content; no domain terms, firm-specific facts, or verifiable claims are present, yielding Level 1.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Analyzing this paragraph from Blue Owl Capital Corp II's 10-K filing.

The paragraph makes materiality assessments: "did not experience a material cybersecurity incident", "not aware of any cybersecurity risks that are reasonably likely to materially affect", "do not believe that our business strategy, results of operations or financial condition have been materially adversely affected". These are backward-looking and forward-looking materiality conclusions → SI per Rule 5.

The second half cross-references risk factors for hypothetical future impacts.

Category: Strategy Integration - the paragraph is primarily stating conclusions about whether cybersecurity has/will affect business outcomes.

The negative assertions are self-reported claims about absence rather than externally verifiable facts, and the cross-references to risk factors don't provide domain-specific details or firm-specific evidence. This reads as generic boilerplate.


content_category: Third-Party Risk

category_confidence: medium

reasoning: The paragraph is organized entirely around third-party relationships: the first two sentences describe engaging auditors and experts to validate/design/monitor the program (which alone would be RMP), but the longest final sentence details specific requirements imposed ON third-party service providers (certification of security measures, breach reporting obligations), making vendor oversight the central topic → TP. All language is generic ('appropriate security measures,' 'reasonable security measures,' 'third party experts') with no domain terms passing the ERM test, no named firms, and no verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Third-party auditors validate risk management, third-party experts help design/implement/monitor/test cybersecurity, and requirements imposed on third-party service providers regarding security measures and breach reporting.

Category: This has both RMP elements (third parties hired to serve the company - auditors, experts) and TP elements (requirements imposed on vendors). The last sentence is clearly about requirements imposed ON vendors. Let me assess which is central.

First two sentences: third parties helping the company (assessors, experts) → RMP per Rule 3

Last sentence: requirements imposed on third-party service providers → TP per Rule 3

The paragraph splits between the company's use of third parties for its own program and the vendor requirements it imposes. While the last sentence specifically addresses vendor oversight, the bulk of the content focuses on third parties serving the company's risk management function, so this leans toward RMP despite the mixed nature. I'm going back and forth on this, but I think the deciding factor is that the paragraph's core focus is how the company manages third-party cyber risk—both the assistance they receive and the requirements they impose. The vendor certification sentence carries the most weight and specificity, so Third-Party Risk feels like the right classification. Let me check if there are any specific facts mentioned beyond the generic reference to "independent third party auditors."

The language throughout is pretty boilerplate—"third party experts," contractual certifications about security measures, monitoring and testing safeguards. None of these terms are domain-specific enough to pass the ERM threshold. This is Level 1 generic boilerplate.


content_category: Incident Disclosure

fact: ransomware virus — specific threat type

specificity_confidence: medium

reasoning: The paragraph describes a real cybersecurity incident (ransomware attack), its scope, containment, and remediation, making Incident Disclosure the clear category. The subordinate statement about no significant financial impact supports the incident narrative rather than constituting a standalone materiality assessment. Specificity reaches Level 2 via 'ransomware virus' (a specific threat type passing the ERM test), but no named firms, specific dates, verifiable certifications, or hard numbers push it higher — 'several machines' and 'in the last decade' are soft quantities.

thinking:
Incident disclosure with some strategy integration elements. Let me classify.

Category: This describes a real cybersecurity incident - ransomware, what happened, impact, remediation. Primary question: "What happened?" → Incident Disclosure. The financial impact statement is subordinate to the incident narrative.

Specificity: Let me scan for facts.
- "one cybersecurity incident in the last decade" - quantified timeframe
- "ransomware virus" - domain term
- "encrypted several machines" - describes the attack
- "corporate network" - generic
- "restore them from backup" - generic

"One cybersecurity incident in the last decade" - this is a quantified claim but it's a negative-ish self-assertion about incident count.

Actually, it's a positive claim: they experienced one incident. That's specific and quantifiable. "Ransomware virus" is a domain-specific term. The materiality statement about financial impact fits within the incident context. The claim about one incident in a decade is self-reported and hard to verify externally—I can't confirm the absence of other incidents. The incident itself is real, but there's no specific date, forensic firm name, or detailed numbers beyond "several machines." So "ransomware" lands at Level 2 specificity.

The timeframe "in the last decade" is vague without exact dates, and there are no named firms or verifiable certifications backing this up. I'm settling on Domain-Adapted (Level 2) for the ransomware terminology as the key specificity marker here.


content_category: Board Governance

reasoning: The paragraph describes the Board's delegation of cybersecurity oversight to the Audit Committee, squarely answering how the board oversees cybersecurity → BG. No domain terms, no firm-specific facts (Audit Committee is generic), and no verifiable claims, leaving this at Level 1.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity, delegation to Audit Committee. This is Board Governance.

Specificity: "Audit Committee" is generic (every company has one). No domain terms, no firm-specific facts, no verifiable claims. Level 1.


reasoning: The paragraph's core assertion is a materiality assessment: 'we have not identified risks...that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition' — this is the SEC Item 106(b)(2) backward+forward-looking conclusion, placing it squarely in Strategy Integration per Rule 5. No domain terminology, firm-specific facts, or verifiable claims are present; the SEC definition is boilerplate context and the cross-reference to Risk Factors adds no substance.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. A general statement about facing ongoing material risks from cybersecurity threats, with a definition from the SEC, and a cross-reference to Risk Factors.
2. A materiality assessment: "we have not identified risks from known cybersecurity threats... that have materially affected or are reasonably likely to materially affect us"

The second part is a clear materiality assessment (both backward and forward-looking) → Strategy Integration per Rule 5.

Specificity: The cross-reference to Risk Factors and the SEC definition are generic. The materiality statement is a negative self-assertion. "Could adversely impact" is speculation.

The materiality conclusion itself follows the right framework, but it's unsubstantiated—no domain-specific details, no company-specific facts, nothing I can actually verify. This lands at Level 1.


content_category: Risk Management Process

reasoning: The paragraph primarily answers what the cybersecurity program does — investments, processes, technologies, and capabilities for risk management — making it RMP. The governance mention at the end is subordinate. Despite length, the language is entirely generic: 'significant investments,' 'multiple and varied processes,' 'continuously assessing and enhancing' — all interchangeable with any ERM program description. 'Protection, detection, response, and recovery' echoes NIST CSF but is not explicitly named and is used generically enough that an ERM professional could write it. Audit Committee is not firm-specific. No domain terms pass the ERM test, no firm-unique facts, no verifiable claims.

thinking:
Let me analyze this paragraph.

Content category: This describes what the cybersecurity program does - risk management integration, investments, processes, technologies, capabilities. It mentions governance structure at the end but the bulk is about program activities. RMP.

Specificity: Let me scan for facts.
- "connected vehicles" - this is somewhat firm-specific (they're a vehicle company) but it's just describing what they protect, not a cybersecurity domain term
- "avoidance, identification, assessment, mitigation, and remediation" - generic process language

- "protection, detection, response, and recovery capabilities" - these align with NIST CSF functions, though not explicitly stated as such. In this combination they're fairly cybersecurity-specific vocabulary, though an ERM professional could theoretically use similar language in other contexts
- "Audit Committee" - generic, every company has this
- "enterprise risk management program" - generic

Looking at the full paragraph again, the language is mostly boilerplate. Phrases like "significant investments," "multiple and varied processes," and "continuously assessing and enhancing" are generic enough that an ERM professional could write them without cybersecurity expertise. The "protection, detection, response, and recovery" phrasing echoes NIST CSF but is used generically here without specificity or firm-specific facts. "Connected vehicles" is somewhat contextual to their business but isn't domain terminology. I'm settling on Level 1 - the paragraph lacks verifiable claims and concrete details.


reasoning: The paragraph's core substantive claim is the backward-looking materiality assessment ('To date we have not identified any prior cybersecurity incidents that have materially affected or are reasonably likely to materially affect us'), which triggers SI under Rule 5. Despite surrounding disclaimer language and a cross-reference to Item 1A, the materiality conclusion is the primary disclosure. No domain terms passing the ERM test, no firm-specific facts (company name and general business description are not qualifying), and no externally verifiable claims—the negative materiality assertion is a self-reported claim about absence—so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: Mix of strategy integration (materiality assessment), cross-reference to risk factors, and forward-looking disclaimers.

The key sentence: "To date we have not identified any prior cybersecurity incidents that have materially affected or are reasonably likely to materially affect us" → This is a materiality assessment (SI per Rule 5).

There's also a cross-reference to Risk Factors and general disclaimers, but the materiality assessment is the substantive core.

Specificity: The materiality statement "have not materially affected" is a negative self-assertion - not externally verifiable.

Looking at the next section, I see references to Okta being an attractive target and mentions of past incidents, but these are vague and lack specificity. The business description as a "provider of identity and security solutions" is just generic positioning. There are no domain-specific terms that would satisfy the ERM test, no firm-specific facts beyond what any company in this space would say, and no verifiable claims. The whole paragraph boils down to standard boilerplate language wrapped around a materiality conclusion.


content_category: None/Other

reasoning: This paragraph is a cross-reference directing readers to Item 1A risk factors for materiality discussion, with no substantive cybersecurity disclosure of its own. Per Rule 5, cross-references like 'risks that may materially affect us, see Item 1A' → N/O. No specific facts elevate specificity above Level 1.

thinking: Cross-reference to Item 1A risk factors. This is pointing elsewhere for materiality discussion.


fact: zero-day vulnerability

fact: managed file transfer software MOVEit

fact: Form 8-K filed on July 14, 2023

fact: on or about May 31, 2023 informed of vulnerability

fact: First National 1870 division

fact: Guardian Mortgage division

reasoning: The paragraph describes a real cybersecurity incident — the MOVEit zero-day vulnerability — with timeline, affected software, and impacted divisions, making it Incident Disclosure. Specificity is Quantified-Verifiable due to specific dates (July 14, 2023; May 31, 2023), the named software product (MOVEit), and the verifiable 8-K filing.

thinking: Incident disclosure with specific dates, named software, named divisions.


reasoning: The paragraph contains a backward-looking materiality assessment ('we do not believe that any prior cybersecurity-related threats or incidents have materially affected our company'), which is SI per Rule 5. The remainder discusses third-party requirements, but the materiality conclusion is the more significant disclosure. No domain terms pass the ERM test, no firm-specific facts, and the negative materiality assertion is not externally verifiable, leaving this at Level 1.

thinking:
Let me analyze this paragraph.

It has three parts:
1. "Like other technology companies, we have faced and expect to face cybersecurity threats" - generic
2. "we do not believe that any prior cybersecurity-related threats or incidents have materially affected our company" - SI materiality assessment (backward-looking)
3. Third-party service provider requirements - TP content

The materiality assessment is a clear SI statement per Rule 5. The third-party content is also substantial. Which is the primary focus?

The paragraph has roughly equal parts SI and TP. The materiality statement is a key disclosure.

The TP portion describes requirements imposed on vendors, but the SI materiality assessment is the definitive disclosure here—it's a clear backward-looking conclusion that any prior threats haven't materially affected the company. That makes SI the primary category, though the TP content is substantial enough to warrant consideration.

Looking at the actual text, the TP sentence is longer, but the materiality conclusion carries more weight as a disclosure element. I'm going with SI, moderate confidence.

Now examining the specificity of each claim: the materiality statement is a negative self-assertion that isn't independently verifiable, while the third-party requirements are mostly generic process descriptions—certifying ability to implement reasonable security measures, compliance with applicable laws, and prompt breach reporting. These lack concrete detail.

There are no domain-specific terms that would distinguish this from standard vendor management language, no firm-specific facts, and nothing verifiable. This is Level 1 boilerplate.


reasoning: The paragraph describes the Board's oversight of cybersecurity risks and delegation to its Audit Committee, directly answering how the board oversees cybersecurity. No domain-specific terms pass the ERM test, and Audit Committee is a generic governance structure every public company has, so specificity remains Level 1.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity risks, delegation to Audit Committee. This is Board Governance.

Specificity: "Audit Committee" is generic (every company has one) → not firm-specific. No domain terms that pass ERM test. Generic language about oversight. → Level 1.


content_category: Management Role

fact: Executive risk committee (named management-level committee)

fact: Committee comprised of Chief Financial Officer, Chief Legal Officer, and Senior Vice President, Engineering Operations

fact: Senior Vice President, Engineering Operations (VP+ role with cybersecurity portfolio)

fact: Cybersecurity team members hold computer science, cybersecurity assurance or other cybersecurity degrees

reasoning: The paragraph primarily describes the management-level executive risk committee's composition (CFO, CLO, SVP Engineering Operations), the cybersecurity team's qualifications, and committee members' expertise — all organizational/role content that collapses under the person-removal test, making it MR. Specificity is Firm-Specific due to the named committee and specific VP+ titles; 'decades of technical experience' is a soft number insufficient for Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes management-level committee structure, membership, team composition, and qualifications. The executive risk committee is a management-level committee. Using Rule 1: management-level committees → MR if about structure/membership. The paragraph describes who's on the committee (CFO, CLO, SVP Engineering Operations), the cybersecurity team composition and qualifications, and committee expertise. Person-removal test: remove all person-specific content and very little substantive program description remains. → MR.

Specificity:

The executive risk committee is a named, firm-specific body with defined roles including the CFO, CLO, and SVP Engineering Operations. The cybersecurity team's qualifications—computer science, cybersecurity assurance degrees, and decades of technical experience—are firm-specific details, though "decades" is a soft metric rather than a hard number.


reasoning: The paragraph describes the company's Incident Response Plan — what it does (framework for responding, escalation, coordination, annual evaluation) — making it about program activities (RMP). Person-removal test: removing the COO reference leaves the plan description intact. No domain terms pass the ERM test: 'incident response plan' is explicitly generic, 'cybersecurity incidents' is topic-level, and cadences like 'at least annually' are boilerplate. COO is a generic C-suite role, not a security-qualified VP+ title, so it's not firm-specific.

thinking:
Let me analyze this paragraph.

Content: Describes an Incident Response Plan - its purpose, coordination through COO, management involvement, cross-organizational coordination, annual evaluation.

Category: This is about what the cybersecurity program does (incident response planning, framework for responding). The COO is mentioned as coordinating, but the main content is about the plan itself. Person-removal test: remove "Chief Operations Officer" - substantive description of the IRP remains. → RMP

Specific facts:
- "Incident Response Plan" - generic term, every company has one. L1.

- "Chief Operations Officer" coordinating the plan - COO is a generic C-suite role, not a security-specific VP+ title. Not firm-specific. L1.
- "evaluated at least annually" - generic cadence, L1.
- "notification of and escalation to the appropriate management committees and Bank Board" - generic process description. L1.

The plan itself isn't given a distinguishing name like "Cyber Incident Response Plan (CIRP)" - it's just called "Incident Response Plan," which is standard across organizations. Combined with the generic roles and processes involved, this doesn't contain firm-specific details.

Looking at the language overall, there are no domain-specific cybersecurity terms that would elevate this beyond boilerplate. "Incident response plan" is explicitly listed as L1, and terms like "escalation" and "notification" are too generic. This is clearly Level 1 - Generic Boilerplate.


fact: Named internal program: Incident Response Plan (IRP)

fact: Named committee: Incident Response Team (IRT)

fact: Named committee: DPT with role in incident response

fact: Chief Information Officer on the IRT

fact: Incident response phases: containment, review, escalation, recovery, remediation

reasoning: The paragraph describes the incident response plan processes (containment, escalation, recovery) and committee structure for handling incidents — applying the person-removal test, substantive program description remains, so RMP. Firm-specific due to named programs (IRP), named committees (IRT, DPT), and CIO role on the IRT.

thinking:
Let me analyze this paragraph.

Content: Describes the Incident Response Plan (IRP), the role of DPT and IRT committees, escalation processes, containment/review/recovery processes, and reporting to senior leadership and Audit Committee.

Category: This describes what the cybersecurity program does (incident response planning, processes). The person-removal test: remove CIO title - substantive program description remains (IRP processes, escalation procedures, containment/review/recovery). → RMP

Specific facts:
- "Incident Response Plan" / "IRP" - named internal program → firm-specific

- "DPT" and "Incident Response Team" / "IRT" are named committees specific to this firm, while the CIO role represents a VP+ level position
- "Audit Committee" appears in most organizations, so it's not distinctive
- The incident response phases like containment, review, escalation, and recovery are standard industry terminology

This lands at Level 3 specificity given the named programs and governance structure.


fact: CFO directs cybersecurity program

fact: CTO directs cybersecurity program

fact: CTO has over 26 years of information technology experience

type: quantified

fact: CTO's prior roles: Director of Technology, Information Technology Manager, Technical Manager, Systems Analyst

reasoning: The paragraph focuses on who leads the cybersecurity program (CFO, CTO), their qualifications, career history, and team composition — applying the person-removal test leaves almost nothing, confirming MR. The CTO's 'over 26 years' of experience is a verifiable lower-bound claim, elevating to Level 4.

thinking:
Classify this paragraph.

Category: This is about management roles - CFO, CTO, their responsibilities, qualifications, experience, team composition. Person-removal test: remove names/titles/qualifications and little substantive program description remains. → MR

Specific facts:
- CFO (named role) → firm-specific
- CTO (named role) → firm-specific
- "over 26 years of extensive information technology experience" → quantified-verifiable (lower bound, ≥26 years)
- Director of Technology, Information Technology Manager, Technical Manager, Systems Analyst (career history) → firm-specific

- "certified and experienced information security professionals" → lacks sufficient specificity to qualify as a domain term

Specificity: Level 4 due to "over 26 years"


reasoning: The paragraph's central topic is managing risks associated with third-party service providers — oversight of vendors via compliance monitoring — making TP the clear category. The language ('weekly calls,' 'monitor compliance,' 'mitigating measures') is entirely generic ERM vocabulary with no cybersecurity domain terms, no firm-specific facts (generic cadences like 'weekly' don't qualify), and no verifiable claims, leaving specificity at Level 1.

thinking:
Classify this paragraph.

Content: About managing third-party service provider risks through weekly calls and compliance monitoring.

Category: Third-Party Risk - this is centrally about how third-party cyber risks are managed.

Specific facts:
- "weekly calls" - a specific cadence but generic (not a hard number or verifiable)
- Actually, "weekly calls with its providers" is a firm-specific practice detail

Wait, let me think about specificity:
- "weekly" is a generic cadence → not firm-specific per rules
- "compliance monitoring" → generic ERM language

- No domain terms, no named roles, no verifiable facts. The language here is all standard boilerplate—"third-party service providers," "compliance," and "mitigating measures" are typical ERM terminology without any distinguishing details. This falls into generic boilerplate at Level 1.


reasoning: The paragraph answers how the board oversees cybersecurity — delegation to the Audit Committee, briefing cadence, and senior management updates — placing it squarely in Board Governance. No domain-specific terminology, firm-specific facts (Audit Committee is generic), or verifiable claims are present, keeping it at Level 1.

thinking:
Classify this paragraph.

Category: Board Governance - describes how the board oversees cybersecurity through the Audit Committee, briefing frequency.

Specific facts:
- "Audit Committee" - generic, every company has one → NOT firm-specific
- "at each Audit Committee meeting" - cadence but generic
- "senior management" - generic

No domain terms that pass ERM test. No firm-specific facts. No verifiable facts.

Level 1.


fact: SEC investigation into data breaches resulting from failures in Progress software

fact: February 26, 2024 — date SEC request to preserve documents was received

fact: Progress software identified as source of vulnerability

fact: FirstSun named as subject of SEC document preservation request

reasoning: The paragraph describes a real cybersecurity breach including public disclosure, customer notifications, and an SEC investigation, making it Incident Disclosure. The specific date (February 26, 2024), named software (Progress), and named regulatory body (SEC) with a specific investigative action are externally verifiable, elevating to Quantified-Verifiable.

thinking: Incident disclosure about a real breach, SEC investigation, specific date.


fact: program maturity assessments

reasoning: The paragraph primarily describes what the cybersecurity program does — periodic maturity assessments, IT risk assessments, and third-party security risk assessments — making it RMP. The Audit Committee mention is subordinate context. 'Program maturity assessments' is a domain-specific concept (assessing program maturity against a framework) that passes the ERM test, elevating to Level 2, though the rest is fairly generic process language.

thinking:
Classify this paragraph.

Category: The paragraph discusses how cybersecurity risk management is integrated into ERM, mentions Audit Committee oversight briefly, and describes processes (maturity assessments, IT risk assessments, third-party security risk assessments). The primary question answered is "What does the cybersecurity program do?" → RMP. The Audit Committee mention is subordinate. The heading says "Enterprise Risk Management Process Integration" which points to RMP/SI territory.

Actually, let me reconsider. The paragraph talks about ERM integration and processes. The main content is about what the program does (assessments). RMP.

Specificity:

Looking at the terminology, "program maturity assessments" is clearly a domain-specific cybersecurity practice that meets the ERM threshold, while the other terms like IT risk assessments and third-party security assessments are more generic process descriptions. The Audit Committee reference is standard boilerplate. That puts this at Level 2.


reasoning: The paragraph centers on cybersecurity insurance as a financial risk management tool, directly addressing how cybersecurity affects the company's financial posture — fitting Strategy Integration. No domain-specific terminology, firm-unique facts, or verifiable claims are present; the language about maintaining insurance and coverage limitations is generic boilerplate any company could produce.

thinking:
Cybersecurity insurance discussion → Strategy Integration. Mentions insurance to manage financial risk, with caveats.

Specific facts: "cybersecurity insurance" is a strategy/financial tool. No domain terms that pass ERM test. No firm-specific facts beyond company name. No verifiable claims.

This is generic - any company could write this. Level 1.


reasoning: The paragraph describes what the cybersecurity program does—risk assessments, training, tools, incident response plan, monitoring—making it clearly RMP. All language is generic process description ('periodic risk assessments,' 'employee awareness training,' 'security analytical and assessment tools,' 'incident response plan') that any ERM professional could write; no domain-specific terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Category: Describes what the cybersecurity program does - risk assessments, training, tools, incident response plan, monitoring. This is RMP.

Specificity: Let me check for specific facts.
- "periodic risk assessments" - generic
- "employee awareness training initiatives" - generic
- "security analytical and assessment tools" - generic
- "cybersecurity incident response plan" - generic (no distinguishing name)
- "incident classification" - borderline domain term but fairly generic
- "internal and external resources" - generic

The ERM test: Could a non-security ERM professional write this? Yes, mostly.

The language around tools and incident procedures is too vague and generic - this reads like standard boilerplate without any domain-specific depth or distinguishing details. Level 1 classification.


reasoning: The paragraph is a risk disclaimer acknowledging the company lacks resources for cybersecurity, with speculative 'could be damaged' language. No substantive cybersecurity program, measures, or assessments are described—per Rule 6, a company with no program and only speculative risk language maps to N/O. No specific facts elevate specificity above Level 1.

thinking:
This is a small company (Palisades Venture Inc.) admitting they lack resources for cybersecurity. Let me classify.

Content: Says cybersecurity is costly, company lacks manpower/expertise/resources, no guarantees. This is essentially saying they have no program - pure disclaimer/speculation. No actual measures described.

Category: This is essentially a "we can't do cybersecurity" statement with speculative risk language. Per Rule 6, no substantive cybersecurity disclosure. N/O? Or SI since it's about business/financial impact?

It's more of a risk disclaimer - "could be damaged" is speculation.

The statement about lacking manpower, expertise, and financial resources is really just a negative assertion about their posture without describing any actual cybersecurity measures. This fits N/O under Rule 6 - a company with no program admitting it. I'll classify this as Generic Boilerplate for N/O.


reasoning: The paragraph answers how the board oversees cybersecurity — board expertise, reporting mechanisms, update frequency — making it clearly Board Governance. All language is generic governance boilerplate ("regularly updated," "established reporting mechanisms," "strategic decisions") with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Category: Board Governance - describes board oversight of cybersecurity risks, board member expertise, briefing frequency/scope.

Specificity: No domain terms beyond generic cybersecurity language. No firm-specific facts (no named roles beyond "Board of Directors" which is generic). No verifiable claims. "incident response" - does this pass the ERM test? "Incident response" without cybersecurity qualifier is listed as commonly confused L1 term. Everything here is generic governance language.

Level 1.


fact: CISO role

fact: Security Governance Committee

fact: CISO has over 20 years of cybersecurity and technology management experience

reasoning: The paragraph describes who serves on the Security Governance Committee and the CISO's qualifications, making it about management roles and organization. 'Over 20 years' is a verifiable lower bound on the CISO's experience, elevating to Level 4.

thinking:
Classify this paragraph.

Content: About CISO and Security Governance Committee membership, plus CISO's experience.

Category: This is about management roles - who is on the committee, qualifications of CISO. MR.

Specific facts:
- CISO (named_role, firm-specific)
- Security Governance Committee (named_committee, firm-specific)
- "over 20 years of cybersecurity and technology management experience" (quantified, verifiable - lower bound)


reasoning: The paragraph's central topic is how the company oversees cybersecurity risks from third parties (vendors, service providers, external users), making Third-Party Risk the clear category. The language is entirely generic — 'comprehensive, risk-based approach to assessing and overseeing' could describe any enterprise risk domain — with no domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

The paragraph is about how the company manages third-party cybersecurity risks - vendors, service providers, external users. This is centrally about third-party risk management.

Specificity: "comprehensive, risk-based approach to assessing and overseeing cybersecurity risks presented by third parties" - this is generic language. No domain terms that pass the ERM test. No firm-specific facts. No verifiable claims. This is Level 1.


fact: Namecheap identified as hosting provider

fact: GoDaddy identified as hosting provider

fact: Cloudflare identified as hosting provider

reasoning: The paragraph identifies the company's cybersecurity risk landscape (websites only) and describes how that risk is managed through third-party hosting — this is a risk assessment and program description (RMP), with third parties as implementation detail rather than vendor oversight requirements (TP). Naming Namecheap, GoDaddy, and Cloudflare as specific hosting providers constitutes externally verifiable claims, elevating specificity to Level 4.

thinking:
Small company, minimal cybersecurity disclosure. Let me classify.

Category: This describes their cybersecurity risk and how they manage it (via third-party hosting). It's about third-party risk management but also about their overall risk posture. The central topic is actually about their minimal risk profile and reliance on third parties. Given the brevity, this is essentially saying "our only cyber risk is websites, and we use reputable hosts." This could be RMP (describing their program/risk landscape) or TP (third-party reliance). The central topic seems to be about identifying their risk and noting third parties handle it. It's a mix but I'd lean RMP since it's describing their overall risk assessment first, with third parties as implementation detail.

The paragraph does emphasize specific third-party vendors—Namecheap, GoDaddy, and Cloudflare—which makes the third-party aspect more prominent than I initially thought. Since they're naming concrete firms, that's verifiable information pointing to Level 4 specificity. I'll stick with RMP as the category since the focus is on how they've assessed and managed their risk posture, with the vendors being the mechanism for that management.


fact: ransomware

fact: malware

fact: phishing attempts

reasoning: The paragraph opens with a materiality assessment ('not aware of any material cybersecurity incidents that impacted the Company in the last three years'), which is a backward-looking negative assertion triggering SI under Rule 5. The remainder is speculative risk language and a cross-reference to Item 1A. Specificity reaches Level 2 via specific threat types (ransomware, malware, phishing) that pass the ERM test, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: States no material incidents in last three years, then discusses routine risks (ransomware, malware, etc.), and cross-references Item 1A.

Category: The opening statement "we are not aware of any material cybersecurity incidents" is a materiality assessment → SI per Rule 5. The rest is speculation/risk factors and a cross-reference. The SI assessment is the key substantive content.

Wait - let me re-check. "Not aware of any material cybersecurity incidents that impacted the Company in the last three years" → negative assertion about material impact → SI per Rule 5.

The negative assertion about material incidents isn't externally verifiable under the rules, and while the threat types mentioned—ransomware, phishing, malware—are domain-specific terms that an ERM professional would recognize, there are no firm-specific facts or verifiable claims here, so this lands at Level 2 minimum.


reasoning: This paragraph describes the company's IT/OT infrastructure and how it supports business operations (refining, pipelines, terminals, accounting) but does not address any cybersecurity measure, process, governance structure, or risk management activity — it is purely a technology-environment preamble. As N/O, specificity defaults to Generic Boilerplate.

thinking:
Classifying this paragraph about Delek US Holdings.

The paragraph describes their IT/OT infrastructure and how it supports operations. It's not really about cybersecurity program activities, governance, or management roles. It's describing the technology environment/context.

This is general IT infrastructure description - not answering any of the six cybersecurity questions directly. It mentions OT (operational technology) which is a domain term, and describes refinery processes, pipelines, terminals - but these are business operations, not cybersecurity measures.

Wait - OT (operational technology) is a domain-relevant term in cybersecurity context.

But this is still just context-setting about their technology environment without any actual cybersecurity measures, processes, or assessments described. The mention of OT systems doesn't change that - it's infrastructure description, not a cybersecurity disclosure. By Rule 6, this qualifies as N/O since there's no substantive cybersecurity content, making it generic boilerplate.


fact: Chief Information Officer (CIO) presents cybersecurity topics to the Audit Committee

reasoning: The paragraph describes how the Audit Committee and full Board receive cybersecurity reports, briefings, and updates from management, which is squarely about board-level oversight structure → Board Governance. The mention of the Chief Information Officer (a VP-level cybersecurity leadership role per the rules) as a presenter elevates specificity to Firm-Specific, though the rest of the paragraph uses generic oversight language.

thinking:
Board governance - describes how the Audit Committee and Board oversee cybersecurity through reports, briefings, and presentations.

Specific facts: CIO, CFO mentioned as presenters, Audit Committee (generic), internal security staff, external experts.

CIO and CFO are generic roles every company has. "internal security staff" is generic. "external experts" is generic.

Wait - CIO is Chief Information Officer. Per the rules, generic governance roles that exist at every company (Board, Audit Committee, CEO, CFO, General Counsel) are NOT firm-specific.

But actually, the rules explicitly call out cybersecurity leadership roles at VP level or above like CISO, CTO, and CIO as firm-specific. So CIO does count as firm-specific, even though CFO is just a generic governance role.

The domain language here—"cyber risk management program," "IT internal controls," "internal control over financial reporting"—leans more toward audit and ERM terminology than cybersecurity-specific language. So those don't add much firm-specificity.

This means CIO is the key firm-specific element, putting this at Level 3.


fact: obtains and reviews attest reports covering cyber-related controls at third parties

fact: designs and implements complementary user entity controls

reasoning: The paragraph frames third-party oversight as one component of the company's broader security program (general IT security → third-party risks → measures), making it RMP per Rule 3 rather than TP-central. 'Attest reports covering cyber-related controls' and 'complementary user entity controls' are SOC-reporting domain terms that pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes general IT security measures, then focuses on third-party risk management with specific practices.

Category: The paragraph starts with general security but the latter half focuses specifically on third-party risk management - obtaining attest reports, implementing complementary user entity controls, contractual safeguards. The third-party content is substantial and specific. But is it the CENTRAL topic? The paragraph is roughly split between general security measures and third-party risk. The third-party section is detailed and specific. I'd say it's a mix of RMP and TP, but the most distinctive/specific content is about third-party oversight.

Looking at Rule 3 again - third parties mentioned as one component of an internal program should be categorized as RMP. The paragraph does frame third-party oversight within the company's broader security approach, even though the third-party content is detailed and takes up significant space. The overall structure starts with general IT reliance and security protocols, then weaves in third-party risks and oversight measures. Given this framing, RMP is the right fit.

Specificity: "attest reports covering cyber-related controls"

—this is domain-specific terminology from SOC auditing that demonstrates cybersecurity expertise. "Complementary user entity controls" is similarly a technical term from SOC reporting frameworks. Both pass the ERM test and indicate Level 2 specificity. The other phrases like "contractual safeguards" and "security protocols, controls, and systems" are too generic. No firm-specific identifiers or verifiable claims are present.


reasoning: The paragraph's central topic is how the company collaborates with third-party vendors on cybersecurity, making TP the best fit. No domain-specific terminology (fails ERM test), no firm-specific facts, and no verifiable claims — generic cadences like 'semi-annual or annual' are not specific enough to elevate beyond Level 1.

thinking:
Classify this paragraph.

Content: About collaboration between IT department and third-party vendors on cybersecurity. The central topic is managing third-party cyber risks through collaboration.

Category: This is about how they work with vendors on cybersecurity. The central topic is third-party collaboration. But is it TP or RMP? The paragraph describes how the company coordinates with vendors - this seems like vendor oversight is the central topic → TP.

Actually, re-reading: "works collaboratively with our third-party vendors to coordinate a mutually beneficial approach to cybersecurity" - this is about coordinating with vendors on cybersecurity.

It's vendor-focused as the central topic → TP.

Specificity: The language lacks domain-specific terminology that would meet the ERM test. Terms like "Information Technology department," "rolling basis," and "semi-annual or annual basis" are all generic. There are no firm-specific details—no named executives at VP level or above, no identified committees, and no verifiable claims that could be fact-checked.

Level 1.


fact: third-party security scoring system to evaluate security posture of current and potential parties

reasoning: The paragraph is centrally about managing third-party/vendor cybersecurity risks, including oversight processes and security standards imposed on vendors, making it Third-Party Risk. The mention of a 'third-party security scoring system' to evaluate security posture demonstrates domain knowledge (referencing vendor risk rating tools like BitSight/SecurityScorecard), elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Category: This is centrally about third-party risk management. The heading says "Managing Third Party Risk" and the content describes processes for overseeing vendors/service providers. → Third-Party Risk

Specific facts:
- "third-party security scoring system" - this is a domain term (security scoring/rating platforms like BitSight, SecurityScorecard)
- "minimum security and control standards" - generic
- "continuous compliance" / "ongoing monitoring" - generic

The mention of a "third-party security scoring system" shows domain knowledge - an ERM professional wouldn't naturally reference this. Level 2.

There are no firm-specific facts or named roles, committees, or tools mentioned, and no verifiable claims that would push this higher.


reasoning: The first sentence is a direct materiality assessment (backward-looking 'have not materially affected' and forward-looking 'reasonably likely to materially affect') → SI per Rule 5. The remainder is generic speculation ('could be significant') and cross-references to Item 1A. No domain terms, firm-specific facts, or verifiable claims elevate specificity above Level 1.

thinking: SI materiality assessment in first sentence, cross-reference in latter part.


fact: GISO (Group Information Security Officer) role

fact: Chief Information Security Officer (CISO) role

fact: cybersecurity maturity assessments

reasoning: Per Rule 3, third parties hired to serve the company (service vendors, assessors performing audits) are classified as RMP rather than TP; the paragraph describes program activities enabled by external partners. The GISO and CISO are firm-specific named security roles elevating specificity to Level 3, with 'cybersecurity maturity assessments' as a supporting domain term.

thinking:
Classify this paragraph.

Content: Describes third-party engagement - vendors for protection and experts for assessments. The central topic is third-party engagement but these are third parties hired to serve the company (assessors, pen testers) → per Rule 3, this is RMP not TP. Actually, let me re-read Rule 3 more carefully.

"Third parties hired to serve the company (assessors, pen testers) → RMP. Requirements imposed ON vendors → TP."

This paragraph describes third parties hired to serve LILA (cybersecurity service vendors, assessment experts). So this is RMP.

Wait - the first sentence mentions "third-party cybersecurity service and product vendors to provide protection of our networks" - these are vendors providing services TO the company. The second sentence is about third-party experts performing assessments.

Both are third parties serving the company → RMP per Rule 3. Now I'm identifying the firm-specific elements: GISO and CISO are named roles, cybersecurity maturity assessments is a domain term, while Audit Committee is generic. The CISO reports to the executive team and Audit Committee. This gives me Level 3 - Firm-Specific.


reasoning: The paragraph describes how the Board delegates cybersecurity oversight to its Audit Committee, squarely answering the board governance question. All entities mentioned (Board of Directors, Audit Committee, ERM program, internal controls) are generic governance constructs present at every public company, with no domain-specific terms, firm-unique facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: Board delegates cybersecurity oversight to Audit Committee. This is about board/committee oversight structure → Board Governance.

Specificity: Let me check for facts.
- "Board of Directors" - generic, every company has one
- "ERM program" - enterprise risk management, generic
- "Audit Committee" - generic, every company has one
- "internal controls" - generic

No domain terms that pass the ERM test. No firm-specific facts.

Since there are no verifiable claims here, this rates as Level 1.


reasoning: The paragraph describes what the cybersecurity program does—processes to identify, assess, and manage risks to various systems and data—making it RMP. The language is entirely generic ERM boilerplate ('identify, assess and manage material risks,' listing broad asset categories); swapping 'cybersecurity' for any other risk domain would still work, with no domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Describes implementation of information security processes to identify, assess, and manage material risks from cybersecurity threats. Lists what's protected (networks, hosted services, communications, hardware, software, data types).

Category: This is about what the cybersecurity program does → RMP. It describes processes to identify, assess, and manage risks.

Specificity: Let me check for specific facts.
- "identify, assess and manage material risks" → generic ERM language, L1
- "third party hosted services" → generic
- "intellectual property, confidential information" → generic
- The whole paragraph is generic boilerplate about having processes.

No domain-specific terminology that would satisfy the ERM test, no company-specific facts, and no claims I could actually verify. This lands at Level 1.


reasoning: The paragraph centrally addresses how third-party vendor cybersecurity risks are managed—risk assessments of vendors and breach notification requirements—making Third-Party Risk the primary category. The language is entirely generic (risk assessments, processes to identify risks, prompt notification) with no domain-specific terms passing the ERM test, no firm-specific details, and no verifiable claims.

thinking:
Classify this paragraph about third-party vendor cybersecurity risk management.

Category: This is centrally about how third-party cyber risks are managed - vendor risk assessments and notification requirements. → Third-Party Risk

Specificity: "cybersecurity risk assessments" - generic process description. "promptly notify us of any actual or suspected breach" - contractual requirement but generic language. No domain terms that pass the ERM test, no firm-specific facts, no verifiable claims. This is Level 1 - any ERM professional could write this about non-cyber vendor risk too.


fact: cloud-based technology to scan and analyze for vulnerable software or misconfigurations (vulnerability scanning)

fact: cybersecurity questionnaire for assessing key third-party controls

reasoning: The paragraph splits between describing internal security software (RMP) and third-party vendor oversight processes (TP); the most detailed, actionable content—cybersecurity questionnaire, contractual security controls, monitoring, and discontinuation standards—describes requirements imposed ON vendors, making TP the primary category. Specificity reaches Level 2 via domain terms like vulnerability scanning and cybersecurity questionnaire, but no firm-specific or verifiable facts push it higher.

thinking:
Let me analyze this paragraph.

Content: Describes security software (cloud-based scanning for vulnerabilities/misconfigurations), mentions systems developed internally or by third parties, then details third-party cybersecurity controls (questionnaire, contractual security controls, monitoring, ability to discontinue).

Category: The paragraph splits between RMP (security software, scanning) and TP (vendor oversight). The second half focuses on third-party controls - questionnaire, contractual requirements, monitoring, discontinuation. Let me assess which dominates. First sentence is about security software (RMP). Second sentence is transitional. Third sentence is entirely about third-party oversight.

The first part covers their own security tools, but the substantive detail really centers on vendor oversight—the questionnaire, contractual controls, monitoring, and discontinuation standards. That third-party content is more developed and specific, so I think TP is the dominant category here, even though the opening mentions their own security infrastructure. The language here points to vendor management rather than internal risk—vulnerability scanning and cybersecurity questionnaires are standard vendor assessment practices. I'm not seeing specific tool names, roles, or metrics, so this stays at Level 2 specificity.


fact: Director of Information Technology role

fact: More than 20 years' experience in financial services

fact: Information security and cybersecurity risk management expertise

fact: Degree from the University of California, Santa Barbara

fact: Certified Information Systems Security Professional (CISSP) from ISC2 Organization

reasoning: The paragraph is entirely about who manages cybersecurity—their title, qualifications, credentials, and responsibilities—collapsing to near-nothing under the person-removal test, making it MR. Specificity is Level 4 due to multiple externally verifiable facts: CISSP certification (checkable via ISC² registry), degree from UC Santa Barbara, and a lower-bound claim of 'more than 20 years' experience.

thinking:
Let me analyze this paragraph.

Content: Describes the Director of IT's qualifications, experience, certifications, and responsibilities. This is about a management role - who is responsible, their qualifications, their experience.

Category: Management Role (MR) - person-removal test: remove all person-specific content and almost nothing remains. The paragraph is entirely about the role, qualifications, and credentials.

Specific facts:
- "Director of Information Technology" - this is a Director-level title without a security qualifier, so per rules it's NOT firm-specific. Wait - "Director of Information Technology" without security qualifier → NOT firm-specific per the rules.

- The candidate has over 20 years in financial services, holds a CISSP certification from ISC², and studied Business Administration at UC Santa Barbara. These are all verifiable credentials that push this clearly into Level 4.


reasoning: This is a generic commitment statement about protecting IT assets and data with no substantive cybersecurity disclosure — no processes, measures, governance structures, or program details are described. It reads as a preamble/mission statement. Specificity is Level 1 as there are no domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

This is a generic commitment statement about protecting IT assets and data. No specific cybersecurity measures, no domain terms, no firm-specific facts.

Category: None/Other or RMP? It's just a commitment statement with no substantive disclosure. But it does mention protecting IT assets... it's extremely generic though. Let me think - "What does the cybersecurity program do?" - it doesn't really answer that, it just states a commitment. It's borderline N/O vs RMP. Given Rule 6, this has no actual cybersecurity measure described. It's a generic mission statement. I'll go N/O.

Reconsidering - even though it lists protected assets like IT systems, data, operations, employees, customers, suppliers, IP, and products, there's still no actual process or measure disclosed, just a broad commitment. This stays N/O with generic boilerplate specificity.


reasoning: This is a single generic sentence about the threat environment with no substantive cybersecurity disclosure—no program details, governance, or specific measures. No domain terms or firm-specific facts elevate specificity above Level 1.

thinking: Short, generic statement about threat environment with no cybersecurity substance.


fact: Chief technology officer is responsible for information security team and cybersecurity program

fact: CTO has over a decade of industry experience

fact: Team members held similar positions at large technology companies

reasoning: The paragraph primarily describes who is responsible for cybersecurity (CTO), their qualifications, team composition, and reporting lines to senior management and the audit committee — all MR content. While reporting to the board is mentioned, the grammatical subject throughout is the CTO/team and their role, not the board's oversight. Specificity reaches Level 4 because 'over a decade of industry experience' for an identifiable CTO (Braze's CTO can be looked up) sets a verifiable lower bound (≥10 years).

thinking:
Let me analyze this paragraph.

Category: This describes the CTO's role, the information security team, reporting lines, and qualifications. The person-removal test: remove CTO, team qualifications, reporting lines — what remains? "regular reports on cybersecurity program, material cybersecurity risks and mitigation strategies" and "incident response processes" and "updates on material cybersecurity threats and incidents." The bulk is about WHO is responsible, their qualifications, reporting structure. But it's mixed — governance chain describing oversight structure.

The paragraph covers: CTO responsibility, team qualifications, reporting to senior management and audit committee, incident reporting to board.

So this is a governance-chain paragraph where the CTO's role and qualifications dominate the first half, but then it shifts into reporting structure and board oversight. The management responsibility piece is primary here, though the reporting lines to the audit committee and board are also significant. I'm seeing this as primarily about management's organizational role and accountability rather than just the oversight structure itself.

On the specificity front, the CTO is a named firm-specific role at VP+ level, while the information security team is more generic. The "over a decade" language is a soft lower bound—it's verifiable in principle as more than 10 years, though somewhat vague.

Since Braze is named, the CTO can be identified, which makes "over a decade of industry experience" count as quantified-verifiable. The team's background at large tech companies is firm-specific, but the audit committee reference is generic. So I'm marking the CTO as Level 3 and the experience claim as Level 4.


reasoning: The paragraph's central topic is assessing third-party vendors for security commitments, making TP the primary category. The language ('data security, availability, and confidentiality,' 'calibrated to the identified risk level') is generic ERM vocabulary with no domain-specific terms, firm-specific facts, or verifiable claims, keeping it at Level 1.

thinking:
Classify this paragraph.

Content: About assessing third-party vendors for cybersecurity commitments. This is centrally about vendor oversight → Third-Party Risk.

Specificity: "data security, availability, and confidentiality" - these are generic terms any ERM professional would use. "risk level associated with each vendor" - generic. No domain terms, no firm-specific facts, no verifiable claims. Level 1.


reasoning: The paragraph's primary purpose is a backward-looking materiality assessment ('have not experienced any material cybersecurity incidents, and expenses incurred from cybersecurity incidents were immaterial'), fitting SI under Rule 5. The second sentence is a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims are present—the negative assertion about no material incidents is a self-reported claim about absence (not externally verifiable), and the date/timeframe is reporting-period context.

thinking:
Let me analyze this paragraph.

The paragraph states no material incidents in three years and directs to Item 1A for more. The first sentence is a backward-looking materiality assessment ("have not experienced any material cybersecurity incidents, and expenses incurred from cybersecurity incidents were immaterial"). The second sentence is a cross-reference.

Category: Strategy Integration - it's stating a conclusion about whether cybersecurity has affected business outcomes (Rule 5: "Have not experienced any material cybersecurity incidents" → SI).

Specificity: The "have not experienced any material cybersecurity incidents" is a negative self-assertion - NOT externally verifiable per the rules.

The reporting period reference to December 31, 2023 is just temporal framing with no substantive content—no domain-specific language, no company-specific details, nothing that can be independently verified. This falls squarely into Level 1 Generic Boilerplate.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not materially affected') and a forward-looking assessment ('reasonably likely to materially affect'), which are SI per the materiality rule. No domain terms, firm-specific facts, or verifiable claims are present — the year '2023' anchors a negative self-assertion which is not externally verifiable, and the cross-reference and disclaimer language are generic boilerplate.

thinking: SI materiality rule applies here.


fact: Cybersecurity management team

fact: Brian Fellon, named individual in cybersecurity leadership

fact: Vice President, Chief Information Officer and Chief Information Security Officer (VP, CIO and CISO)

fact: Appointed by the Board of Directors in September 2024

fact: Reports to Chief Financial Officer

fact: 28 years of experience in information technology

fact: Director of Information Technology at Puget Sound Energy in Bellevue, Washington from 2016 to September 2024

reasoning: The paragraph centers on Brian Fellon's role, qualifications, career history, and reporting line — applying the person-removal test leaves almost nothing substantive, confirming MR. Specificity reaches Level 4 via multiple verifiable facts: 28 years of experience, named prior employer (Puget Sound Energy) with specific dates (2016–September 2024), and a named individual with a specific appointment date.

thinking:
Classify this paragraph.

Category: This is about Brian Fellon's role, qualifications, career history, reporting lines. Person-removal test: remove all person-specific content and almost nothing remains except "management team has primary responsibility for cybersecurity risk management program and supervises internal personnel and external consultants." That's thin. This is MR.

Specific facts:
- "Cybersecurity management team" - named_team (firm-specific)
- Brian Fellon named individual
- VP, CIO and CISO - named_role (firm-specific)

- Reports to CFO - firm-specific reporting line
- 28 years of experience in IT - quantified, verifiable
- September 2024 appointment - specific_date, verifiable
- Director of Information Technology at Puget Sound Energy - named_firm, verifiable
- 2016 to September 2024 at Puget Sound Energy - verifiable
- Bellevue, Washington - verifiable

Level 4.


fact: confidentiality, integrity, and availability (CIA triad)

reasoning: The paragraph describes the company working toward integrating a cybersecurity risk management program into its broader ERM framework, which is about what the program does (RMP). The mention of 'confidentiality, integrity, and availability' invokes the CIA triad, a foundational information security concept that passes the ERM test, elevating specificity to Level 2, though the rest is generic aspirational language.

thinking:
Classify this paragraph.

Content: "actively working towards the integration of a cybersecurity risk management program into its comprehensive risk management framework to protect the confidentiality, integrity, and availability of its critical systems and information."

This is about what the cybersecurity program does (or is working toward) - RMP. It's about ERM integration.

Specificity: "confidentiality, integrity, and availability" - this is the CIA triad, a domain concept. Does it pass the ERM test? The CIA triad is specific to information security. A non-security ERM professional wouldn't naturally use "confidentiality, integrity, and availability" as a specific grouping.

The CIA triad is a foundational infosec concept that an ERM professional wouldn't typically group together this way, so I'm marking this as Level 2 - domain-specific language.


fact: Multi-factor authentication (MFA)

fact: 2019 wire fraud scheme involving compromised employee email and fraudulent wire transfer

fact: Cross-reference to Legal Proceedings section for more information on the incident

reasoning: The paragraph describes an actual 2019 wire fraud incident—its mechanism (compromised email, fraudulent wire transfer), attribution of fault to the bank, and remediation—making Incident Disclosure the primary category. The 2019 date tied to a real, specific event referenced in Legal Proceedings is externally verifiable (court/legal records), elevating to Level 4; MFA is a domain term at Level 2.

thinking:
Let me analyze this paragraph.

Content: Describes an actual 2019 wire fraud incident, its details, and remediation steps taken afterward. This is primarily about what happened in a cybersecurity incident.

Category: Incident Disclosure - describes a real event (2019 wire fraud), timeline, nature, response/remediation.

Specific facts:
- 2019 wire fraud scheme (specific date + real event)
- MFA implementation (domain term)
- "in 2019" - specific timeframe tied to real incident
- Wire fraud scheme - specific incident type
- Multi-factor authentication (MFA) - domain term

- The year 2019 combined with the wire fraud scheme creates a verifiable, specific event that could be cross-referenced through legal proceedings, which pushes this to Level 4 specificity.
- MFA functions as domain-specific terminology, contributing to Level 2 technical precision.


reasoning: The paragraph contains a backward-looking materiality assessment ('To date, we have not experienced any significant impacts from cybersecurity threats'), which under Rule 5 maps to Strategy Integration. The remaining content is speculative 'could have' language and a cross-reference to Item 1A, neither of which elevate specificity — the negative assertion is a self-reported claim about absence and is not externally verifiable, and no domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

The paragraph states they haven't experienced significant impacts from cybersecurity threats (a materiality assessment), includes speculative "could have" language, and cross-references Item 1A.

"To date, we have not experienced any significant impacts from cybersecurity threats" — this is a backward-looking materiality assessment → SI per Rule 5. Note it says "significant" not "material" but it's still an assessment of whether cyber has affected business outcomes.

"could have a material impact" — speculative, not SI.

Cross-reference to Item 1A — N/O element.

The primary content is the materiality assessment plus speculation.

The SI assessment is there, but the language is vague and unverifiable—just a negative claim without specifics, domain expertise, or concrete facts. The rest is boilerplate speculation and a reference to another section.


reasoning: The paragraph discusses general IT investments for business purposes (customer experience, compliance, growth) with no substantive cybersecurity disclosure — it reads as a generic business strategy statement. None/Other paragraphs always receive Generic Boilerplate.

thinking:
Classify this paragraph.

This is about IT investment and business strategy. No cybersecurity-specific content. Let me check the categories.

The paragraph discusses IT investments for business purposes (customer experience, compliance, internal controls, efficiency, new products, growth). There's no cybersecurity content here - no mention of security programs, risks, incidents, governance, etc.

This is None/Other - no substantive cybersecurity disclosure.

Specificity: Generic Boilerplate (N/O always gets Generic Boilerplate).


fact: Named internal program: Security Incident Response Plan ("SIRP")

fact: encryption protocols

fact: multi-factor authentication

fact: data loss prevention controls

reasoning: The paragraph describes the company's incident response plan, data protection measures, and business continuity testing — all program activities → RMP. The named 'Security Incident Response Plan (SIRP)' with a distinguishing acronym is a firm-specific identifier, elevating to Level 3, supported by domain terms like encryption, MFA, and DLP.

thinking:
Let me analyze this paragraph.

Content: Describes their Security Incident Response Plan (SIRP), partnerships with insurance/regulatory/law enforcement, vendor engagement during incidents, data protection measures (encryption, MFA, DLP), and business continuity/disaster recovery plans.

Category: This is about what the cybersecurity program does - RMP. There's some third-party mention but it's part of the broader program description.

Specificity:
- "Security Incident Response Plan ("SIRP")" - named internal program with distinguishing identifier → firm-specific (Level 3)
- "encryption protocols" - domain term

- "multi-factor authentication" and "data loss prevention controls" are standard security terminology, but the SIRP itself with that specific acronym marks this as a named internal program at Level 3. Business continuity and disaster recovery measures don't meet the ERM threshold and fall to Level 1.


reasoning: The paragraph describes the external regulatory landscape (state cybersecurity laws, data privacy regulations) rather than the company's own cybersecurity program; the only company action is the entirely generic 'we actively monitor legislative and regulatory developments to ensure compliance,' which lacks substantive cybersecurity disclosure. As N/O, specificity defaults to Generic Boilerplate.

thinking:
Classify this paragraph.

This is about regulatory compliance monitoring related to cybersecurity laws. It doesn't describe board oversight, management roles, specific risk management processes, third-party risk, incidents, or strategy integration in a meaningful way. It's mostly about the regulatory landscape and a generic statement about monitoring compliance.

Category: This is borderline RMP/N/O. The only cybersecurity-related content is "we actively monitor legislative and regulatory developments to ensure compliance" which is very generic. The paragraph is mostly about the regulatory environment. But it does mention "cybersecurity programs, data encryption, and breach notification" as regulatory requirements - these are about external regulations, not about what the company does.

The company's actual action boils down to monitoring regulatory developments, which is generic compliance work rather than a description of their cybersecurity program. Even though terms like "data encryption" and "breach notification" appear, they're framed as regulatory requirements the company must follow, not as actions the company takes. This pushes it toward N/O rather than RMP.

Category: N/O → Generic Boilerplate.


fact: security threat intelligence system

fact: vulnerability management tools

fact: patch management standard

fact: Security Operations Center (SOC)

fact: event correlation

reasoning: The paragraph describes specific cybersecurity program activities — threat intelligence collection, vulnerability management, patch management, and SOC operations — making it clearly RMP. Multiple domain terms (threat intelligence, vulnerability management, patch management, SOC, event correlation) pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts push it higher.

thinking:
Classify this paragraph.

Content: Describes security threat intelligence system, vulnerability management tools, patch management standard, and Security Operations Center (SOC). This is about what the cybersecurity program does → RMP.

Specific facts:
- "security threat intelligence system" → domain_term (threat intelligence)
- "vulnerability management tools" → domain_term
- "patch management standard" → domain_term
- "Security Operations Center" → domain_term (SOC)
- "event correlation" → domain_term
- "incident response capabilities" → domain_term (though generic-ish, but in context of SOC)

- All these terms pass the ERM test as standard cybersecurity domain terminology with no firm-specific details or verifiable claims beyond a generic program description.

Level 2.


fact: Technology committee of the board of directors oversees cybersecurity risk management

reasoning: The paragraph describes the board's oversight structure for cybersecurity, including delegation to the Audit Committee and technology committee, making it Board Governance. The 'technology committee' is a non-generic board-level committee (not every company has one), elevating specificity to Firm-Specific; the remaining language about management responsibilities is standard governance boilerplate.

thinking:
Classify this paragraph.

Category: Board oversight structure - board, Audit Committee, technology committee oversight of cybersecurity. Also mentions management responsibilities but in context of governance chain. BG.

Specificity: "Audit Committee" is generic (every company has one). "technology committee" - this is a named committee that's somewhat firm-specific. Let me check - "technology committee of our board of directors" - this is a board-level committee, not every company has a technology committee. That's firm-specific.

Wait - the rules say "named non-generic committees (Cybersecurity Committee, Technology Risk Committee — not 'Audit Committee' which every company has)".

The "technology committee" counts as firm-specific since it's a board-level committee that not all companies maintain, while the rest of the language is standard governance terminology.


fact: Director responsible for information security program (Director-level role with security qualifier)

reasoning: The paragraph describes who is responsible for the information security program (the Director), their qualifications ('extensive experience'), and their review activities with the CFO — primarily answering 'how is management organized?' → MR. The Director role with explicit information security program responsibility qualifies as a firm-specific named role, but no verifiable claims (experience is described with soft language 'extensive'), keeping this at Level 3.

thinking:
Let me analyze this paragraph.

This appears to be a fragment (starts with "is responsible for") likely continuing from a previous paragraph that named a Director role.

Category: The paragraph describes a role's responsibilities and qualifications. The "Director" (likely Director of IT or similar) is responsible for the information security program. It mentions their experience and that they regularly review risks with the CFO. Using the person-removal test: remove the Director's qualifications and role description - what remains is "development, operation, and maintenance of our information security program and controls" and "regularly review potential risks and measures implemented by the Company to identify and mitigate cyber security risks." These are generic process descriptions.

But I'm noticing the paragraph actually focuses on who holds the role and what they're qualified to do, not just the generic processes. Even after removing person-specific details like the Director's background and CFO involvement, the core content is still about the role itself and its responsibilities. The specificity question is whether "Director" with a security qualifier counts as firm-specific - the instructions suggest Director-level titles with security qualifications do meet that threshold, though I need to verify exactly what title is being used here. The Director role here is tied to the information security program, which qualifies it as firm-specific even though the full title isn't visible in this section. There are no concrete facts or verifiable details—just vague language like "extensive experience"—so this lands at Level 3.


fact: security questionnaires

fact: controls evidence reviews

fact: application vulnerability assessments

fact: public internet presence monitoring

fact: NIST

type: framework

fact: ISO

fact: HIPAA

fact: Payment Card Industry standards (PCI)

reasoning: The paragraph centrally addresses requirements imposed ON suppliers—contractual security compliance, periodic audits, and remediation—making Third-Party Risk the clear category. Multiple domain-specific terms (application vulnerability assessments, controls evidence reviews, public internet presence monitoring) and named frameworks (NIST, ISO, HIPAA, PCI) demonstrate cybersecurity domain expertise, but the frameworks are referenced as alignment targets rather than held certifications, keeping this at Level 2.

thinking:
Let me analyze this paragraph.

Content: This is about requirements imposed ON vendors/suppliers regarding cybersecurity. Contractual requirements, security audits, risk assessments of suppliers, etc. This is centrally about third-party/vendor oversight → Third-Party Risk.

Specific facts:
- Security questionnaires, security capabilities and maturity assessments, controls evidence reviews, application vulnerability assessments, public internet presence monitoring - domain terms
- NIST, ISO, HIPAA, PCI standards - frameworks/domain terms
- Right to audit, background checks - somewhat specific contractual terms

Specificity: Multiple domain terms (application vulnerability assessments, controls evidence reviews, public internet presence monitoring) pass the ERM test.

The frameworks like NIST, ISO, HIPAA, and PCI are referenced as vendor alignment standards rather than certifications the company holds, which puts this at Domain-Adapted level. References to "The Cigna Group's" data and network are just company mentions without revealing specific organizational structure or details, so the overall specificity stays at Level 2 given the concentration of domain terminology and framework references.


reasoning: The paragraph describes the Board's oversight structure via the Audit Committee interacting with management, answering 'how does the board oversee cybersecurity?' → Board Governance. No domain terms pass the ERM test, 'Audit Committee' is generic (every company has one), and 'Director of Information Technology' is a director-level title without a security qualifier, so no facts elevate above Level 1.

thinking:
Classify this paragraph.

Content: Board's oversight supported by Audit Committee, which interacts with Manager's Director of IT and other management who implement/oversee cybersecurity program.

Category: Board Governance - describes how the board oversees cybersecurity via Audit Committee.

Specific facts:
- "Audit Committee" - generic, every company has one → not firm-specific
- "Director of Information Technology" - Director-level without security qualifier → not firm-specific per rules
- "Manager" - this is an externally managed REIT structure

This is basically describing the oversight chain from Board → Audit Committee → Manager's IT Director. It's BG.

The language lacks domain-specific terminology and contains no firm-specific details—Audit Committee is standard across companies, and a Director of IT without a security focus doesn't meet the specificity threshold. This lands at Level 1.


reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing policies, processes, risk assessment, incident response planning, and use of third-party assessors (hired to serve the company → RMP per Rule 3). All language is generic process description ('assessing, identifying, and managing material risk,' 'incident response plan,' 'third parties to assess effectiveness') that any ERM professional could write without cybersecurity domain knowledge, and no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Category: This describes what the cybersecurity program does - policies, processes, risk assessment, incident response plan, third-party assessors. Primary question: "What does the cybersecurity program do?" → RMP. Third parties are mentioned but as part of the internal program (assessors hired to serve the company), not vendor oversight requirements → RMP per Rule 3.

Specificity: Let me scan for facts.
- "cyber incident response plan" - this is generic incident response plan language, L1

- "cybersecurity assessors" and references to "security, confidentiality, integrity, and availability" are all standard boilerplate terminology with no firm-specific details, named roles, or verifiable claims - everything points to L1.


fact: Security Committee oversees cybersecurity risk management

fact: Chief Security Officer (CSO) role

fact: Cyber Risk Advisory Committee oversees IT strategy and cybersecurity governance

reasoning: Governance-chain paragraph describing how the board, Security Committee, CSO, and Cyber Risk Advisory Committee oversee cybersecurity — primarily answering how the board oversees cybersecurity, defaulting to BG. Firm-specific due to named non-generic committees (Security Committee, Cyber Risk Advisory Committee) and CSO role, but no verifiable claims.

thinking:
Let me analyze this paragraph.

Category: This describes oversight structure - Board, Security Committee, CSO, Cyber Risk Advisory Committee. It's a governance-chain paragraph. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. The paragraph describes how the board oversees cybersecurity through committees and how information flows up. BG.

Specific facts:
- "Security Committee" - named committee (firm-specific)
- "Chief Security Officer (CSO)" - named role at VP+ level (firm-specific)
- "Chairman of the Board" - generic

- "Cyber Risk Advisory Committee" - named non-generic committee (firm-specific)

No verifiable claims present. Specificity: Firm-Specific (Level 3).


fact: incident response lifecycle

fact: No material cybersecurity incidents in the last 24 months

fact: Leased office physically broken into through a firemen's access conduit

fact: Fiscal year ended September 30, 2025

reasoning: The paragraph opens with RMP content (IRP description) but the dominant frame is materiality assessment: 'no material cybersecurity incidents in the last 24 months' is a backward-looking SI assertion per Rule 5, and the physical break-in is described primarily to conclude it 'did not result in a material impact on our operations, financial condition or results of operations.' Specificity reaches Level 3 due to firm-specific incident details (break-in through firemen's access conduit at leased office) that distinguish this company's disclosure; the 24-month negative assertion is not externally verifiable, so it stays at Level 3.

thinking:
Let me analyze this paragraph.

Content: Describes an incident response plan, mentions no material cyber incidents in 24 months, then describes a physical break-in that wasn't material.

Category: The paragraph has multiple elements:
1. Incident response plan description (RMP)
2. "No material cybersecurity incidents in last 24 months" (SI - negative assertion about materiality)
3. Physical break-in disclosure (ID - actual incident)

The physical break-in is a real event described in detail. But it's a physical security incident, not cybersecurity. The paragraph says "isolated physical security incident." The materiality assessment ("no material cybersecurity incidents") is an SI statement per Rule 5.

I'm reconsidering the structure here. The core of this is really three parts: the incident response plan description, a negative materiality statement about cyber incidents, and then the physical incident itself. Since they explicitly call out the physical break-in as a "physical security incident" rather than a cyber one, and they note it didn't materially impact operations, the materiality assessments are what's driving the classification. Both the "no material cybersecurity incidents" claim and the physical incident's lack of material impact are SI-type statements. The materiality language is the dominant frame here—the incident itself is secondary to the assessment that it had no material impact. Rule 5 about not experiencing material cybersecurity incidents clearly applies, and even the physical break-in is presented through a materiality lens rather than as a detailed incident description. I'm settling on Strategy Integration as the best classification.

Now I'm evaluating the specificity of the language used. Most of the incident response terminology is generic—"incident response plan," "incident response team"—but there are some firm-specific details that stand out: the physical break-in through a firemen's access conduit and the subsequent remediation of that conduit. These concrete details about what actually happened at this organization push toward higher specificity, even though the broader incident response framework language stays at a generic level.

The 24-month timeframe is a specific number, but it's tied to a negative assertion about no material incidents, which doesn't meet the verifiable standard. The fiscal year end date provides reporting context but isn't a cybersecurity-specific fact. Weighing the firm-specific incident details against the generic terminology and unverifiable assertions, I'm landing on Level 3—Firm-Specific.


reasoning: The first sentence is a backward-looking and forward-looking materiality assessment ('have not...materially affected or are reasonably likely to materially affect'), which is the SEC Item 106(b)(2) formula → SI. The remainder is generic disclaimer and cross-reference to Risk Factors. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: SI materiality assessment paragraph.


reasoning: The paragraph mentions maintaining cybersecurity insurance and that costs may not be fully insured, which are business/financial strategy elements (SI), though mixed with speculative risk language ('could have a material adverse effect' — not SI per Rule 5) and a cross-reference to Risk Factors (N/O). The insurance discussion tips the balance toward SI. Specificity is Level 1 because 'cybersecurity insurance' is a standard ERM concept (fails the ERM test), and all other language is generic boilerplate ('protect stakeholders,' 'business continuity,' 'material adverse effect').

thinking:
Let me analyze this paragraph.

Content: concluding paragraph with generic aspirational language, speculative risk language ("could have a material adverse effect" - this is speculation per Rule 5), mentions cybersecurity insurance, and a cross-reference to Risk Factors.

Category: The mention of cybersecurity insurance is a Strategy Integration element. The "could have a material adverse effect" is speculation (not SI per Rule 5). The cross-reference is N/O. But the insurance mention is a real business measure. Let me think... "maintains cybersecurity insurance" is a factual claim about a business strategy element. "costs related to cybersecurity threats or disruptions may not be fully insured" is also about financial strategy.

The insurance discussion does touch on strategy integration, but this paragraph is really just boilerplate conclusion wrapped around speculation and a cross-reference. The insurance content is there, but it's not the main point—it's buried in a mostly generic wrap-up. The speculative language alone disqualifies most of this from being SI, and the cross-reference is clearly N/O.

Now I'm questioning whether "maintains cybersecurity insurance" even counts as firm-specific. It's a business measure, sure, but it's not domain-adapted or particularly distinctive—many companies claim the same thing. The real test is whether removing the company name would still leave you with useful detail, and in this case, it wouldn't. This feels more like generic boilerplate than a concrete firm-specific fact. Looking at this paragraph, it's mostly wrapping up with disclaimers and references, but the insurance mention does constitute substantive SI content, so I'll classify it as SI with moderate confidence—though the specificity remains at Level 1.


reasoning: This paragraph sets the threat landscape context — listing attack types Okta faces and stating a commitment to protection — but does not answer any of the six substantive questions (no program activities, governance structure, management roles, incident details, or materiality assessment). None/Other paragraphs always receive Generic Boilerplate.

thinking:
Classifying this paragraph from Okta's 10-K Item 1C.

Category: This describes the threat landscape facing Okta but doesn't answer any of the six substantive questions directly. It's general context about threats and a commitment statement. No specific program activities, no governance, no management roles, no incident details, no materiality assessment. This is closer to N/O or RMP. Actually, it mentions specific threat types but doesn't describe what the program DOES. It's contextual/introductory. But it does mention specific cybersecurity threats... Let me think about this more carefully.

The paragraph says Okta faces various attacks, lists threat types, and states commitment to protecting systems.

It doesn't describe any actual process, governance, or management structure—just the threat environment and a general commitment. Even though it names specific threats like malware, ransomware, phishing, and nation-state actors, it's not explaining what measures Okta takes in response. This is contextual framing rather than substantive disclosure, so I'd classify it as None/Other.

Since None/Other always gets Generic Boilerplate per the rules, that's my classification.


fact: CISO role referenced as source of cybersecurity information flow

reasoning: The paragraph describes how cybersecurity information flows from management up to the Audit Committee and Board, making it primarily about oversight structure (BG). The mention of CISO elevates specificity to Firm-Specific, though the rest (Audit Committee, quarterly cadence, generic channels) is boilerplate governance language.

thinking:
Classify this paragraph.

The paragraph describes how information flows from CISO upward through channels to the Audit Committee and Board. This is about oversight structure - how information reaches the board. That's Board Governance.

Specific facts:
- CISO (named role, firm-specific)
- "risk response forms" - part of formal security risk process
- Audit Committee - generic, every company has one
- Board - generic
- "quarterly basis" - generic cadence

CISO is a firm-specific role (VP-level or above). "risk response forms as part of our formal security risk process" - this is a named internal process element but fairly generic.

The CISO reference pushes this to Level 3 specificity since it's a firm-specific role.


fact: Critical Threat Committee — named non-generic committee responsible for evaluating materiality and disclosure

reasoning: The paragraph describes the governance chain for escalating cybersecurity incidents to the Board of Directors, including materiality evaluation criteria, disclosure obligations, and notification protocols — all oversight structure → Board Governance. The 'Critical Threat Committee' is a firm-specific named committee that elevates specificity to Level 3; the Audit Committee and Chairman of the Board are generic governance roles present at every company.

thinking:
Let me analyze this paragraph.

Content: Describes the Critical Threat Committee's responsibilities for evaluating materiality of cybersecurity incidents, disclosure obligations, and how information flows to the Board of Directors and Audit Committee.

Category: This is about oversight structure - how information flows from the Critical Threat Committee to the Board. The Critical Threat Committee evaluates materiality and determines disclosure obligations, then briefs the Board. This is governance-chain describing oversight structure → Board Governance.

Wait - "Critical Threat Committee" - is this a management-level committee or board-level? It briefs the Board of Directors, so it's below the board.

It's a management-level committee, but since it's describing the oversight structure and how materiality evaluation flows up to the Board and disclosure process, this falls under Board Governance per the default rule. The key specificity marker here is the "Critical Threat Committee" name itself—that's firm-specific terminology, which puts this at Level 3 specificity, even though the materiality evaluation process and securities law disclosure obligations are generic concepts.


reasoning: The paragraph describes how the Audit Committee receives cybersecurity reports from management—classic board oversight/information-flow content → Board Governance. No domain terms passing the ERM test, no firm-specific facts (Audit Committee is generic), and no verifiable claims, leaving this at Level 1.

thinking:
Classify this paragraph.

Category: Board Governance - describes how the Audit Committee receives reports from management about cybersecurity risks and incidents. This is about information flow to the board.

Specific facts: "Audit Committee" is generic (every company has one). No domain terms that pass ERM test. No firm-specific facts. No verifiable claims.

Specificity: Generic Boilerplate (Level 1).


reasoning: This paragraph is a forward-looking disclaimer about no assurance of program effectiveness, combined with a cross-reference to Risk Factors — no substantive cybersecurity disclosure. No specific facts elevate specificity above Level 1.

thinking: This is a disclaimer/caveat paragraph with a cross-reference to Risk Factors. No substantive cybersecurity disclosure.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not been materially affected'), which is an SI assessment per Rule 5. The cross-reference to Item 1A is secondary. No specific facts elevate specificity: 'last three fiscal years' is a soft timeframe, and the negative materiality assertion is a self-reported claim about absence, not externally verifiable.

thinking: Materiality assessment + cross-reference.


fact: security event monitoring and detection

fact: extended detection and response (XDR)

fact: vulnerability scanning

fact: phishing simulations

fact: penetration tests

reasoning: The paragraph enumerates cybersecurity program activities (monitoring, XDR, vulnerability scanning, phishing simulations, pen testing), clearly answering 'what does the program do?' → RMP. Multiple domain-specific terms pass the ERM test for Level 2, but no firm-specific roles or verifiable claims push it higher.

thinking:
Classify this paragraph.

Content: Lists cybersecurity program components including security event monitoring, XDR, vulnerability scanning, training, phishing simulations, incident response team, and third-party audits/pen tests.

Category: RMP - describes what the cybersecurity program does.

Specific facts:
- "security event monitoring and detection" - domain term
- "extended detection and response" (XDR) - domain term
- "vulnerability scanning" - domain term
- "phishing simulations" - domain term
- "penetration tests" - domain term
- "security awareness and privacy training" - borderline, but training is generic... though "phishing simulations" is clearly domain

- Third parties are mentioned but as serving the company (assessors, pen testers) → RMP per Rule 3.

No firm-specific facts (no named roles, no specific committees). No verifiable claims. This is domain-adapted content at Level 2 specificity.


reasoning: This is a forward-looking disclaimer and cross-reference to the Risk Factors section, with no substantive cybersecurity disclosure. No specific facts of any kind are present.

thinking: Forward-looking disclaimer + cross-reference to Risk Factors. No substantive cybersecurity disclosure.


reasoning: The paragraph describes what the cybersecurity program does—risk assessment, policy development, training, and third-party engagement—answering the RMP question. Third parties are mentioned but only as one component, not the central topic. Every term used (risk assessment, policies and procedures, risk mitigation, cybersecurity training, enterprise risk management) would be natural for any ERM professional; no domain-specific terminology, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Category: This describes what the cybersecurity program does - risk assessment, policies, training, third-party engagement. The primary question answered is "What does the cybersecurity program do?" → RMP. Third parties are mentioned but not the central topic.

Specificity: Let me scan for facts.
- "enterprise risk management assessments" - generic ERM language
- "identifying material cybersecurity risks, prioritizing risks and analyzing risk mitigation" - generic process description
- "policies and procedures" - generic
- "cybersecurity training" - generic
- "consultants and other third parties" - unnamed

- Everything here is boilerplate process language with no domain-specific terminology, firm-specific details, or verifiable claims → Level 1.