fact: Chief Information Officer briefs the Board

fact: Senior Vice President Internal Audit provides updates to Audit Committee

reasoning: The paragraph answers how the board oversees cybersecurity—Board briefings, Audit Committee support, information flow—making it clearly Board Governance. The CIO (a VP-level cybersecurity-adjacent role listed as firm-specific) and SVP Internal Audit elevate specificity to Level 3, though the remaining language (risk management, business continuity, disaster recovery) is standard ERM vocabulary that does not pass the domain expertise test.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity - BG. Describes board briefings, Audit Committee support, information flow to board.

Specific facts:
- CIO (Chief Information Officer) - named role
- "at least annually" - generic cadence
- Audit Committee - generic (every company has)
- CFO, General Counsel, CIO - generic roles
- Senior Vice President Internal Audit - firm-specific role (SVP level with specific portfolio)
- business continuity and disaster recovery plans - L1 terms
- key security metrics - L1

I need to reconsider whether Senior Vice President Internal Audit actually qualifies as firm-specific—the rules specify VP-level roles whose portfolio includes IT or cybersecurity, but this person's focus is internal audit rather than cybersecurity directly. And CIO isn't explicitly listed as generic like CEO or CFO, though it's a common governance role. Let me check the exact criteria for what counts as cybersecurity leadership versus generic roles.


content_category: Management Role

category_confidence: high

specificity_confidence: medium

reasoning: The paragraph primarily describes who is responsible for cybersecurity (Director of Operations & IT), their qualifications, experience, and consultation with senior management — classic MR content that collapses under the person-removal test. Specificity stays at Level 1: the Director title lacks a security qualifier (per rules, 'Director of IT' is not firm-specific), 'approximately 20 years' is a soft/hedged number (not verifiable), certifications are unnamed (not verifiable like 'CISSP' would be), and the remaining language ('evaluates cybersecurity risk profile,' 'mitigate risks') is generic ERM vocabulary that passes the ERM swap test.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: Describes the Director of Operations & Information Technology's role, experience, and certifications. This is about a management role - responsibilities, qualifications.

Category: Management Role - it's about who is responsible, their qualifications, experience. The person-removal test: remove the Director's title, experience, certifications - very little substantive program description remains beyond generic "evaluates risk profile" and "develops strategies to mitigate risks."

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

The title lacks a security qualifier, so it doesn't meet the firm-specific criteria. The "approximately 20 years" is also soft language rather than a concrete number, which further weakens the specificity here.

Looking at the rest of the paragraph, I'm seeing generic cybersecurity language—"cybersecurity risk profile," "mitigate risks"—without any domain-specific terminology that would pass the ERM test. There are no named certifications like CISSP, just vague references to "accredited information technology certification providers," and "senior management team" is boilerplate. This reads as Level 1 generic boilerplate with no verifiable claims or firm-specific facts.


content_category: None/Other

specificity_confidence: high

reasoning: This paragraph restates the SEC's 8-K Item 1.05 disclosure obligation — it describes what the company will report if a material incident occurs, rather than answering any of the six substantive cybersecurity questions. No actual incident is disclosed, no program activity is described, and no materiality assessment is made. No domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

This is about how the company will report material incidents - it's a forward-looking statement about disclosure obligations, essentially restating SEC requirements. No actual incident is described. No specific program details.

Category: This doesn't describe an actual incident (not ID), doesn't describe what the program does (not RMP), doesn't describe board oversight (not BG). It's essentially restating the SEC's 8-K disclosure requirement. It could be N/O or SI. Let me think... It's about disclosure policy, not an assessment of materiality impact. It's procedural language about reporting obligations. This is N/O.

The language is purely generic boilerplate with no domain-specific terminology, firm-specific facts, or verifiable claims.


content_category: Third-Party Risk

fact: penetration testing (external and internal)

fact: service organization controls (SOC) reports

fact: vulnerability and penetration testing

fact: encryption standards

fact: data protection controls (access reviews, backups, monitoring)

fact: ISO (Information Security Officer) role performs vendor assessments

fact: Information Security Program (named internal program)

reasoning: The central topic is how third-party service providers are assessed — the ISO's vendor security assessment process, SOC report reviews, vendor risk ratings — making this Third-Party Risk. The first sentence about engaging third parties to assess the company (RMP per Rule 3) is subordinate. Specificity reaches Firm-Specific due to the named ISO role performing vendor assessments and the named Information Security Program, with multiple domain terms (SOC reports, penetration testing, encryption standards) establishing L2 as a floor.

thinking:
Let me analyze this paragraph.

Category: This is primarily about third-party risk management. The paragraph describes how third-party assessors are engaged and how the ISO performs security assessments for third-party service providers. The central topic is vendor oversight and third-party security assessments.

Wait - let me re-read. The first sentence is about engaging third parties to assess the company (assessors, consultants, auditors) - that's RMP per Rule 3. But the rest of the paragraph is about assessing third-party vendors - that's TP.

The bulk of the paragraph (sentences 2-4) describes how the ISO assesses third-party service providers, what those assessments include (SOC reports, vendor testing, vulnerability/penetration testing, etc.), and how they produce a risk rating.

So this is clearly third-party risk as the main focus, with a minor RMP element at the end. Looking at the specificity, I see the ISO is a named role which is firm-specific, while most other details like the Audit Committee, third-party assessors, and specific testing methodologies are either generic or standard domain terminology. The paragraph does reference some L2 domain terms like SOC reports, penetration testing, and encryption standards, but the firm-specific identifier is really just the ISO role itself. "Information Security Program" is a named internal program, so that's firm-specific too. The assessment process details they mention are also specific to how this company operates, which reinforces the L3 classification.


reasoning: This is a cross-reference to Item 1A Risk Factors with no substantive cybersecurity disclosure. No specific facts of any kind are present.


content_category: Risk Management Process

fact: vulnerability testing (third-party vulnerability testing)

fact: scanning internal network and infrastructure (vulnerability scanning)

reasoning: The paragraph describes what the cybersecurity program does — risk assessments, vulnerability scanning, third-party testing, and security tools — making it RMP. Vulnerability scanning and vulnerability testing are domain-specific practices that pass the ERM test, elevating to Level 2, but the monthly/annual cadences are generic and no firm-specific or verifiable facts are present.

thinking:
RMP - describes what the program does. Let me check specificity.

Facts: "scanning our internal network and infrastructure at least monthly" - this is a frequency claim, "at least monthly" is a soft cadence. "third-party vulnerability testing at minimum on an annual basis" - again cadence. "vulnerability testing" is a domain term. "scanning our internal network and infrastructure" - vulnerability scanning is a domain term.

Domain terms: vulnerability testing, scanning internal network/infrastructure (vulnerability scanning), security incidents investigation/recovery process.

Firm-specific: "at least monthly" scanning, "at minimum on an annual basis" third-party vulnerability testing - these are cadences but generic ones (quarterly, annual, monthly are not firm-specific per rules).

The domain terminology around vulnerability testing and scanning meets the ERM threshold for specificity, putting this at Level 2.


content_category: Board Governance

fact: Risk and Governance Committee named as delegated oversight body

fact: Head of Information Technology is a Certified Information Systems Security Professional (CISSP)

type: quantified

fact: Head of Information Technology reports directly to Chief Financial Officer

category_confidence: medium

reasoning: The paragraph's framing is board delegation of cybersecurity oversight to the Risk and Governance Committee with quarterly briefings, making the primary question 'how does the board oversee cybersecurity?' (BG), though it also describes management roles. Specificity reaches Level 4 because the CISSP certification claim is independently verifiable via the (ISC)² registry.

thinking:
Let me analyze this paragraph.

Content: Board delegated oversight to Risk and Governance Committee, quarterly updates, Head of IT is CISSP certified, responsible for day-to-day cybersecurity, reports to CFO.

Category: This starts with board delegation (BG) but also has significant management role content (Head of IT, CISSP, reporting to CFO). The first half is about oversight structure (BG), the second half is about management roles (MR). The governance chain description - Board → Risk and Governance Committee → senior management updates - is BG. Then Head of IT's role, qualifications, reporting line is MR.

The paragraph genuinely splits between governance structure and management roles, but the framing around board delegation and the Risk and Governance Committee tips this toward BG. The management details about the Head of IT fit within that governance chain context, so I'm categorizing this as BG with moderate confidence. I'm noting the specific details like the named committee and the CISSP certification as key facts. I'm seeing that "reports directly to our Chief Financial Officer" is just a generic governance reference, not firm-specific. The "quarterly Risk and Governance Committee meeting" is the actual firm-specific detail here, along with the CISSP certification which I can verify through the (ISC)² registry. That puts this at Level 4 for specificity due to the verifiable credential.


fact: Chief Information Security Officer (CISO)

fact: Chief Technology and Digital Officer

reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing the Audit and Finance Committee's oversight role, briefing frequency, and information flow to the board — classic Board Governance. Specificity reaches Firm-Specific due to two named VP+-level roles (CISO and Chief Technology and Digital Officer) that distinguish this company's governance structure, though the 'at least quarterly' cadence and Audit and Finance Committee are too generic to elevate further.

thinking:
Classify this paragraph.

Category: This describes board/committee oversight of cybersecurity. The Audit and Finance Committee's oversight role, briefing frequency, and how information flows to the board. → Board Governance.

Specific facts:
- "Audit and Finance Committee" — this is a named committee but it's essentially a variant of the generic Audit Committee every company has. Hmm, "Audit and Finance Committee" is a specific name but per rules, "Audit Committee" is generic. This is close enough to generic.
- "Chief Information Security Officer" — CISO is a firm-specific named role (VP+ level)

- "Chief Technology and Digital Officer" — another firm-specific named role at VP+ level, a CTO variant
- "at least quarterly" — generic cadence, not firm-specific

So the firm-specific facts here are the CISO and Chief Technology and Digital Officer roles. Level 3.


fact: Chief Information Officer

fact: IT Security Director

fact: VP reports to CIO (reporting line)

fact: threat intelligence

reasoning: The paragraph primarily describes management roles (VP IT Security and Compliance, IT Security Director), their reporting lines (to CIO), responsibilities, and team qualifications — applying the person-removal test, the substantive cybersecurity program content is minimal, making this MR. Specificity reaches Level 3 via firm-specific VP-level and Director-level security roles; 'decades of experience' and 'various certifications' are soft/unnamed so do not reach Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes management roles (VP IT Security and Compliance, IT Security Director), reporting lines (reports to CIO), team composition and qualifications. The person-removal test: remove titles, qualifications, reporting lines → what remains is generic program description ("selecting, deploying and operating cybersecurity technologies" and "relies on threat intelligence"). Some program activity but the primary focus is on WHO is responsible and their qualifications. This is MR.

Specific facts:
- "Vice President, IT Security and Compliance" → named_role (VP-level with security qualifier)

- "Chief Information Officer" → named_role (C-level)
- "IT Security Director" → named_role (Director with security qualifier)
- "threat intelligence" → domain_term
- "cybersecurity technologies" → too generic
- "decades of experience" → soft number, not verifiable
- "various cybersecurity certifications" → not named specifically, not verifiable

The specificity here is Level 3 (Firm-Specific) because of the VP IT Security and Compliance, CIO, and IT Security Director roles that are clearly tied to this organization's structure.


reasoning: This is a summary/closing sentence that provides no substantive cybersecurity disclosure—it merely characterizes the preceding text. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: Meta-commentary about the disclosure, no substantive cybersecurity content.


fact: CTO provides quarterly reports to the Board on cybersecurity

reasoning: The paragraph primarily answers how information flows to the board — CTO reporting quarterly on cybersecurity risks and incidents — making it Board Governance. The CTO is a firm-specific VP-level role elevating specificity to Level 3, but no verifiable claims (specific dates, certifications, named firms) push it to Level 4.

thinking:
Classify this paragraph.

The paragraph describes how the CTO reports to the Board quarterly on cybersecurity risks. This is about how information flows to the board — Board Governance.

Specific facts:
- CTO (named role, firm-specific)
- "quarterly reports" — generic cadence, not firm-specific
- Board of Directors — generic, not firm-specific

CTO is a VP-level-or-above role whose portfolio includes IT/cybersecurity → firm-specific.

Specificity: Firm-Specific (Level 3) due to CTO.


reasoning: The paragraph describes incident response procedures—identification, assessment, escalation, and notification—which are program activities (RMP). Applying the person-removal test, removing CEO/Board references leaves a substantive process description. No domain-specific terminology passes the ERM test ('incident response team,' 'identify, assess, respond,' and escalation procedures are standard ERM language), no firm-specific distinguishing identifiers (the 'Incident Response Team' lacks a unique name per the codebook's CIRP example), and no verifiable claims, so specificity remains Level 1.

thinking:
Classify this paragraph.

Category: This describes what the Incident Response Team does - identifies, assesses, responds to incidents, notification procedures, escalation path. The person-removal test: remove specific roles/titles, and the incident response process description remains. This is about what the program does (incident response procedures), so RMP. The escalation to Board/CEO is part of the incident response process description, not primarily about board oversight structure.

Specific facts:
- "Incident Response Team" - this is a named team (firm-specific)
- CEO notification - generic role
- Board of Directors - generic

"Incident Response Team" as a named team...

I'm debating whether "Incident Response Team" is truly firm-specific or just a standard organizational label. It's a named internal team, but the name itself is fairly generic since most companies use similar terminology. Still, it does refer to a specific team composition at this company, so I'll classify it as firm-specific.

Actually, wait—I need to reconsider this more carefully. The rules specify that named programs need distinguishing identifiers to count as firm-specific, like "Cyber Incident Response Plan (CIRP)" rather than just "incident response plan." Since "Incident Response Team" lacks that kind of identifier and is a common organizational structure, it probably doesn't qualify as firm-specific after all. The domain term "incident response" itself is listed as Level 1, so this should stay at that level.


content_category: Strategy Integration

fact: ransomware incident

fact: Specific date of incident: December 15, 2020

fact: Named incident: 'the Ransomware Incident'

fact: Materiality assessment: 'It is reasonably likely to affect us, including our business strategy, results of operations or financial condition'

reasoning: While the paragraph references a real incident (December 15, 2020 ransomware), the dominant frame is financial/business impact: unexpected costs, future costs, and a clear SEC Item 106(b)(2) materiality assessment ('reasonably likely to affect... business strategy, results of operations or financial condition'), making the financial frame dominant per Rule 4 → SI. The specific date of December 15, 2020 tied to a verifiable real-world event elevates specificity to Level 4.

thinking:
Let me analyze this paragraph carefully.

The paragraph discusses a real cybersecurity incident (ransomware on December 15, 2020) and its business/financial impact, plus a forward-looking materiality statement.

Category: This is mixed. It describes a real incident (ID) but also discusses business/financial impact and includes a materiality assessment (SI). The paragraph starts with incident description but pivots to costs and materiality. Let me assess which frame dominates.

- Incident details: "On December 15, 2020, we detected a ransomware incident... impacting our operational and information technology systems, which caused service delays"

- Financial/business impact: "unexpected costs and impacts", "may in the future incur costs", "It is reasonably likely to affect us, including our business strategy, results of operations or financial condition"

The materiality statement is a clear SI assessment per Rule 5. While the paragraph opens with incident specifics, the dominant focus is on costs and forward-looking business impact—the paragraph's main point centers on financial materiality rather than incident details. The financial frame appears to drive the overall message. The structure confirms this is primarily a strategy/materiality discussion using the incident as supporting evidence. The specific details—the December 15, 2020 date, the ransomware label, the firm-specific naming—establish verifiability and concreteness, but they're framing for the materiality assessment about business strategy and financial condition. This tips it to SI, with the incident details providing necessary context rather than being the main focus. Level 4 classification seems right given the specificity and materiality language.


reasoning: The paragraph describes how the Audit Committee oversees cybersecurity risks, reports to the Board, and reviews the cybersecurity program — classic board governance oversight structure. No domain-specific terminology (everything could apply to any ERM topic), no firm-specific facts (Audit Committee is generic), and no verifiable claims, keeping this at Level 1.

thinking:
Board Governance - Audit Committee oversight of cybersecurity, reporting to Board, review frequency.

Specificity: No domain terms beyond generic. "Audit Committee" is generic. "at least annually" is generic cadence. No firm-specific facts, no verifiable claims.

Level 1.


fact: CFO co-responsible for cybersecurity

fact: last 10 years in leadership positions

fact: Veteran Volunteer Instructor for US Cyber Army Command (ARCYBER)

fact: Information Systems Security Association (ISSA)

fact: Forum of Incident Response and Security Teams (FIRST)

fact: GSTRT certification

fact: CISSP certification

fact: CCSP certification

fact: CISSP-ISSAP for third-party vendors

fact: CGEIT for third-party vendors

fact: CDPSE for third-party vendors

fact: CEH for third-party vendors

reasoning: The paragraph primarily answers who is responsible for cybersecurity and what qualifies them — person-removal collapses it, confirming MR over RMP. Specificity reaches Level 4 via multiple verifiable claims: 'over 20 years' experience (lower bound), named certifications (CISSP, CCSP, GSTRT verifiable via issuing bodies), and named organizational affiliations (ARCYBER, ISSA, FIRST).

thinking:
Let me analyze this paragraph.

Content: Describes CFO and Senior Director of IT roles, qualifications, experience, certifications, and third-party vendor certifications.

Category: This is primarily about management roles - who is responsible, their qualifications, experience, certifications. The person-removal test: remove all person-specific content and almost nothing remains. → MR

Specificity: Let me list facts:
- Senior Director of Information Technology (named role with security portfolio)
- CFO mentioned in cybersecurity context
- "over 20 years of cybersecurity experience" → verifiable lower bound

- "last 10 years in leadership positions" → verifiable lower bound
- US Cyber Army Command (ARCYBER) Veteran Volunteer Instructor → named organization, verifiable
- ISSA membership → verifiable
- FIRST membership → verifiable
- GSTRT certification → verifiable
- CISSP certification → verifiable
- CCSP certification → verifiable
- CISSP-ISSAP, CGEIT, CDPSE, CEH for third-party vendors → verifiable certifications

Multiple verifiable facts → Level 4


fact: advanced persistent threats

reasoning: The paragraph contains a backward-looking materiality assessment ('have not experienced a material cybersecurity incident in the two-year period ended December 31, 2024'), which per Rule 5 is a negative assertion → SI. The remainder is speculative risk language and a cross-reference. For specificity, 'advanced persistent threats' is a domain term passing the ERM test (Level 2). The negative assertion and reporting date are not externally verifiable per the rules, capping at Level 2.

thinking:
Let me analyze this paragraph.

Content: Discusses cybersecurity threats, states no material incident in two-year period, discusses potential consequences, mentions risk evaluation, cross-references Risk Factors.

Category: The paragraph contains a negative assertion about material incidents ("have not experienced a material cybersecurity incident in the two-year period ended December 31, 2024") which is a materiality assessment → SI. But it also has a lot of speculative/risk factor language ("could materially adversely affect"). The materiality assessment (backward-looking negative assertion) points to SI. The rest is speculation and cross-reference.

Per Rule 5: "Have not experienced any material cybersecurity incidents" → SI (negative assertion).

Now looking at the specificity of the claims here. "Advanced persistent threats" is a domain-specific term that passes the ERM test, while the negative assertion about not experiencing material incidents isn't externally verifiable under the rules. The date reference and timeframe are just context, not cybersecurity facts themselves. So the actual factual content boils down to the domain terminology, which makes this Level 2.


reasoning: The paragraph states a conclusion that cybersecurity risks have not materially affected and are not reasonably likely to materially affect the company's business strategy, results of operations, or financial condition — this is the SEC Item 106(b)(2) materiality assessment, triggering SI under Rule 5. The remainder is a cross-reference to Item 1A risk factors. Despite the materiality assessment being SI, the specificity remains Level 1: the risk factor titles are generic descriptions not firm-specific facts, and the negative materiality assertion is a self-reported claim not externally verifiable.

thinking: Materiality assessment + cross-reference.


fact: Change Healthcare named as third-party vendor involved in incident

fact: UnitedHealth Group named as parent company of Change Healthcare

fact: Exogen device identified as product whose claims were affected

fact: March 7, 2024 — date UnitedHealth Group issued statement

fact: March 18, 2024 — expected date to begin restoring claims network connectivity

reasoning: The paragraph is bookended by materiality assessments ('have not materially affected... business strategy, results of operations, or financial condition') and concludes with a materiality judgment about the Change Healthcare incident's impact on claims and cash flows — the central question answered is how cybersecurity affects the business, making it SI per Rule 5. The Change Healthcare incident details serve to explain the basis for the materiality conclusion. Multiple externally verifiable facts (named firms, specific dates) elevate specificity to Level 4.

thinking:
Let me analyze this paragraph.

Content: Discusses a real cybersecurity incident (Change Healthcare breach), its impact on the company's operations, and materiality assessment.

Category: This is tricky. It discusses a real incident (Change Healthcare) but it's a third-party incident affecting the company. The paragraph starts with a materiality statement, describes the incident, and concludes with another materiality assessment. The dominant frame is about business/financial impact - disrupted billing, delayed cash remittances, materiality conclusions. But there's also significant incident description.

Rule 4: What happened (timeline, scope, response) → ID. Business/financial impact → SI.

The structure is actually a materiality sandwich—opening and closing with statements about whether the incident materially affected the company, with the incident details in the middle serving as evidence for that assessment. Even though the Change Healthcare description is substantial, the paragraph's core purpose is answering whether this cybersecurity event had material business consequences, making the materiality framing dominant. with the incident as supporting evidence.

Hmm, but the incident details are quite extensive - who was affected, what happened, what the company did in response, UnitedHealth's investigation timeline. Rule 4 says "Mixed with incident frame dominant → ID."

I think ID is more appropriate here. The bulk of the text describes a specific incident.

Actually, let me count: ~2 sentences on materiality bookends, ~6 sentences describing the incident. The incident frame dominates.

Wait, but this is a third-party incident. The company is describing impact on itself from Change Healthcare's breach. This is more SI - how cybersecurity affects the business. The incident isn't THEIR incident.

Let me reconsider. ID = "What happened in a cybersecurity incident?" - it references a real event. But the company isn't disclosing their own incident; they're disclosing impact from a third party's incident. The paragraph is primarily answering how cybersecurity affects their business and finances, using the Change Healthcare incident as the mechanism.

I'll go with Strategy Integration - the materiality assessment frames the entire paragraph, and the incident details serve to explain why they're making this assessment. Re-reading Rule 5 confirms it: the paragraph literally uses the language "Have not materially affected our business strategy, results of operations, or financial condition," and the conclusion restates it. The incident is described to support the materiality conclusion.

Now I'm looking at the specificity of the disclosure. They name Change Healthcare and UnitedHealth Group, reference the Exogen device specifically, cite March 7 and March 18 as key dates, and describe how the cybersecurity threat actor gained access to information technology systems.


reasoning: The paragraph states a conclusion about the absence of cybersecurity incidents affecting business operations, which is a backward-looking materiality/impact assessment → SI per Rule 5. No domain terms passing the ERM test, no firm-specific facts, and the negative self-assertion ('has not experienced') is not externally verifiable, keeping specificity at Level 1.

thinking:
Classify this paragraph.

"The Company has not experienced any cybersecurity incidents during the year ended December 31, 2024, or in any prior year that resulted in interruptions to normal business operations or breaches of systems."

This is a negative assertion about incident history — "have not experienced any material cybersecurity incidents" → SI per Rule 5.

Specificity: This is a negative self-assertion. No domain terms, no firm-specific facts, no verifiable claims. Negative assertions are not externally verifiable. No domain terms beyond basic language. → Generic Boilerplate.

The reporting period reference doesn't add substantive cybersecurity content, and without domain-specific terminology or verifiable facts, this falls to Level 1.


reasoning: This is a pure cross-reference paragraph directing readers to Item 1A Risk Factors for cybersecurity risk descriptions, with no substantive cybersecurity disclosure of its own. Despite using materiality language, it points elsewhere rather than making an assessment, so it is N/O per Rule 5. No specific facts elevate specificity above Level 1.

thinking: Cross-reference to Item 1A Risk Factors. This is a pure cross-reference paragraph.


fact: ISO 27001 framework

type: framework

fact: least-privilege access provisioning

fact: phishing awareness exercises

fact: security-by-design principles

fact: privileged access management

reasoning: Paragraph describes cybersecurity program activities — framework adoption, access controls, employee training, and phishing exercises — directly answering what the program does (RMP). Multiple domain terms (ISO 27001, least-privilege, phishing awareness, security-by-design) pass the ERM test, but 'based on ISO 27001' is aspirational alignment rather than certified status, capping at Level 2.

thinking:
RMP - describes what the program does (framework, access control, training)

Facts: ISO 27001 (framework reference - domain term/framework), least-privilege (domain term), phishing awareness exercises (domain term), security-by-design (domain term), privileged access (domain term)

ISO 27001 is "based on" not "certified" → Domain-Adapted level
Least privilege, phishing awareness, security-by-design → domain terms

No firm-specific facts, no verifiable claims.

Level 2.


fact: CTO is primarily responsible for assessing and managing cybersecurity risks

fact: COO is primarily responsible for assessing and managing cybersecurity risks

fact: CTO has over 10 years of experience overseeing cybersecurity functions

fact: COO has over 5 years of experience overseeing cybersecurity and IT functions

reasoning: This is a governance-chain paragraph describing how the Board delegates cybersecurity oversight to the Audit Committee, how CTO/COO report to the board, and information flow — the primary question answered is how the board oversees cybersecurity, making it BG per Rule 1. Specificity reaches Level 4 because 'over 10 years' and 'over 5 years' of experience are lower-bound claims verifiable against the officers' resumes.

thinking:
Let me analyze this paragraph.

Category: This covers board oversight (Board, Audit Committee delegation) AND management roles (CTO, COO responsibilities, qualifications, reporting lines). The paragraph starts with board oversight structure, then shifts to management roles with qualifications. It's a governance-chain paragraph. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. The board oversight and information flow to the board is a significant portion. But there's also substantial MR content (CTO/COO responsibilities, qualifications, experience). The primary question answered seems to be "how does the board oversee cybersecurity" with management details supporting that narrative.

I'll categorize this as BG. Now looking at the specific facts: the CTO and COO are named roles tied to this firm, while the Audit Committee is generic. The experience requirements—over 10 years for the CTO and over 5 years for the COO—are verifiable lower bounds that qualify as QV at Level 4. The quarterly update cadence is too generic to be considered QV.


fact: Change Healthcare named as third-party claims processing intermediary

fact: UnitedHealth Group named as parent of Change Healthcare

fact: EXOGEN device named as product whose claims were affected

fact: Specific real-world incident: cybersecurity threat actor gained access to Change Healthcare IT systems

reasoning: The paragraph opens and closes with materiality assessments ('have not encountered any risks from cybersecurity threats that have materially affected...', 'We do not presently believe that the Change Healthcare incident has materially affected...'), making the dominant frame whether cybersecurity has affected business outcomes → SI. While a real incident is described (Change Healthcare), it serves as supporting context for the materiality conclusion rather than being the primary disclosure purpose (Rule 4: financial frame dominant → SI). Specificity reaches Level 4 because Change Healthcare and UnitedHealth Group are named, externally identifiable firms whose cybersecurity incident is independently verifiable as a public event.

thinking:
Let me analyze this paragraph.

Content: Discusses materiality assessment ("have not encountered any risks from cybersecurity threats that have materially affected..."), then describes a real incident involving Change Healthcare/UnitedHealth Group affecting their operations, and concludes with another materiality assessment.

Category: This is tricky. It contains:
1. A materiality assessment (SI)
2. A real incident description (ID) - the Change Healthcare incident
3. Another materiality conclusion

The paragraph starts with SI language, then describes a real incident (Change Healthcare), then concludes with SI. The incident is described in detail (what happened, impact on operations, remediation steps).

The framing is fundamentally about whether this materially affected the company—that's the SI lens. Even though there's substantial incident detail here with Change Healthcare gaining access, patient billing disrupted, and claims delays, the dominant frame is the materiality assessment. The opening and closing both emphasize the SI conclusion, with the incident serving as supporting evidence rather than the main point. I'll categorize this as Strategy Integration.

Specificity: "Change Healthcare" is named.

Looking at the specificity level, I'm seeing named firms like "UnitedHealth Group," named products like "EXOGEN device," materiality assessment language, and specific incident details. Since these are all externally verifiable facts tied to a real, publicly known event, this reaches Level 4.


fact: Externally managed company, operations managed by Manager

fact: Manager is an affiliate of ORIX USA

fact: ORIX USA is a subsidiary of ORIX

fact: Relies on ORIX USA's cybersecurity risk management program

reasoning: The paragraph primarily explains the organizational arrangement for cybersecurity—externally managed, relying on the Manager and ORIX USA's program—answering 'how is management organized to handle cybersecurity?' Person-removal test: removing organizational structure leaves only generic 'identify, assess and manage' language, confirming MR. Named firms (ORIX USA, ORIX) and the specific external-management dependency are firm-specific facts that elevate to Level 3.

thinking:
Let me analyze this paragraph.

Content: This describes an externally managed company (LFT) that relies on its Manager (affiliate of ORIX USA) for operations and cybersecurity. It explains the governance structure and that they depend on ORIX USA's cybersecurity program.

Category: This is primarily about how the company's cybersecurity is organized - it's externally managed, relies on ORIX USA's program. It describes the organizational structure and dependency. The paragraph explains who manages cybersecurity (ORIX USA through the Manager). This feels like a mix of Management Role (organizational structure) and Risk Management Process (relying on ORIX USA's program).

The core issue here is the organizational dependency - the paragraph is fundamentally explaining who handles cybersecurity and how that responsibility is structured. The reliance on ORIX USA's program to identify and assess material risks is really just describing the external management arrangement rather than detailing a separate risk management process. This is about the Management Role - specifically, how cybersecurity governance is delegated to an external party.

Looking at specificity: naming ORIX USA as a diversified financial company and subsidiary of ORIX gives firm-specific organizational details that go beyond generic language. There are no quantified claims here, so this lands at Level 3 - it's identifying a named firm and describing a specific organizational relationship, but without measurable metrics that would push it to Level 4.


content_category: Incident Disclosure

fact: Experienced a cybersecurity incident related to employee interactions with suspicious websites

fact: Forensic investigation conducted confirming no material impact

reasoning: The paragraph discloses an actual cybersecurity incident (employee interactions with suspicious websites), its containment, and the forensic investigation outcome, making it Incident Disclosure. The materiality conclusion is subordinate to the incident narrative (Rule 4). Specificity is Firm-Specific because the incident description (suspicious websites vector, forensic investigation outcome) distinguishes this company's experience, but there are no named firms, specific dates, or quantified details that would reach Level 4.

thinking:
Classify this paragraph.

It describes an actual incident that occurred, its containment, and forensic investigation confirming no material impact.

Category: This is primarily about what happened - an actual cybersecurity incident. That's Incident Disclosure. But it also contains a materiality assessment ("no material impact occurred to operations, financial position, or customer data"). Rule 4 says mixed with incident frame dominant → ID.

Specific facts:
- "forensic investigation" - domain term? An ERM professional might use this. Borderline. Actually forensic investigation in cybersecurity context is fairly standard. I'll skip it.
- The paragraph describes a real incident - but no specific dates, no named firms, no quantified details.

- "suspicious websites" and "promptly contained" are generic language, and the materiality claim is just a negative assertion without verification.

The real distinguishing factor here is that this company experienced a specific cybersecurity incident involving employee interactions with suspicious websites. That's firm-specific - it's what happened to them, not a general statement about cybersecurity practices.

So the incident itself qualifies as a Level 3 firm-specific fact, even though the language around it is vague.


reasoning: The paragraph contains a backward-looking materiality assessment ('prior incidents have not had a material impact on us'), which per Rule 5 triggers SI classification. The remainder is generic speculation ('could have a material impact') and a cross-reference to Item 1A. No domain terms passing the ERM test, no firm-specific facts, and the negative materiality assertion is not externally verifiable, so specificity stays at Level 1.

thinking:
Let me analyze this paragraph.

Content: Acknowledges past incidents without material impact, discusses future risk potential, references Item 1A. The key statement is "While prior incidents have not had a material impact on us" - this is a backward-looking materiality assessment. Per Rule 5, "Have not materially affected" → SI.

But wait, there's also a cross-reference to Item 1A and speculative language ("could have a material impact"). The materiality assessment ("prior incidents have not had a material impact") is SI. The cross-reference and speculation are N/O. The SI assessment is present and substantive.

The language here is pretty generic—just a blanket statement that incidents haven't materially affected the company, with no specific facts or domain-specific details to back it up. It's a self-assertion without external verification, so this lands at Level 1 specificity.


fact: defense in depth

fact: zero trust based controls

fact: phishing email simulations

reasoning: The paragraph describes what the cybersecurity program does—tools, training, controls, risk assessment—squarely answering the RMP question. Domain terms like 'defense in depth,' 'zero trust,' and 'phishing email simulations' pass the ERM test (a non-security risk professional wouldn't naturally use these), but there are no firm-specific roles or verifiable claims, keeping it at Level 2.

thinking:
Let me analyze this paragraph.

Content category: This describes what the cybersecurity program does - risk assessment, tools, training, controls. The primary question answered is "What does the cybersecurity program do?" → RMP.

Specificity: Let me scan for facts.

Domain terms: "defense in depth", "zero trust", "phishing email simulations", "cyber risk management and quantification system" - these pass the ERM test.

Firm-specific: Nothing that distinguishes this company specifically. No named roles, no specific committees, no named tools.

No verifiable facts (no numbers, dates, named products, certifications held).

This lands at Level 2 - Domain-Adapted, since it uses industry terminology and frameworks but lacks company-specific details or concrete metrics.


reasoning: The paragraph contains a backward-looking materiality assessment ('we are not aware of any cybersecurity incidents that have materially affected us to date'), which is a conclusion about whether cybersecurity has affected business outcomes → SI per Rule 5. No domain terms pass the ERM test (generic language like 'prevent, detect and mitigate' and 'information technology'), no firm-specific facts, and the negative materiality assertion is a self-reported claim about absence which is not externally verifiable, leaving specificity at Level 1.

thinking:
Let me analyze this paragraph.

The paragraph states "we are not aware of any cybersecurity incidents that have materially affected us to date" — this is a backward-looking materiality assessment → SI per Rule 5.

It also has "may have a material impact on our business strategy, results of operations or financial condition" — but this is speculative ("could have"), not SI.

The negative assertion about no material incidents is SI (backward-looking assessment).

Specificity: No domain terms that pass ERM test. No firm-specific facts. No verifiable claims. The negative assertion is a self-reported claim about absence — not verifiable per the rules.

The cross-reference to Item 1A pulls in N/O content, but the paragraph itself contains SI. There are no named roles, frameworks, or domain-specific language here — just generic boilerplate language.


fact: Chief Technology Officer (CTO) responsible for information security program and cybersecurity reporting

fact: In 2023, management hosted an expert during the annual board of directors' retreat to discuss cybersecurity threat landscape

reasoning: The paragraph primarily answers how the board oversees cybersecurity — board ultimate oversight, audit committee role, reporting flow, and board education — making it Board Governance despite mentioning the CTO's responsibility. The CTO as the officer responsible for the information security program is a firm-specific fact (VP-level role with cybersecurity portfolio), and the 2023 board retreat with an external expert is a firm-specific event, reaching Level 3. No externally verifiable claims push it to Level 4.

thinking:
Let me analyze this paragraph.

Content category: This paragraph covers board oversight, audit committee role, CTO responsibility, reporting cadences, and board education. The primary question answered is "How does the board oversee cybersecurity?" — Board Governance. There's some MR content (CTO role) but the dominant frame is oversight structure.

Specific facts:
- Audit Committee assisting board (generic, every company has this)
- Chief Technology Officer (CTO) - named role, but CTO is borderline... actually CTO is a VP-level-equivalent role whose portfolio includes IT/cybersecurity → firm-specific
- Quarterly reporting cadence - generic

- In 2023, management brought in an external expert for the annual board retreat focused on cybersecurity and data privacy — this is a specific, verifiable event tied to a particular year and firm activity, so it's firm-specific but self-reported rather than independently verified.
- The CTO role mentioned is a named position within the organization, making it Level 3 firm-specific information.
- Terms like "cybersecurity threat landscape" and "information security program" are fairly generic industry language, not particularly domain-adapted, so there's no strong Level 2 signal here.
- My assessment: Level 3 based on the CTO role being firm-specific.


fact: Risk Management Committee of the Board of Directors has oversight responsibility

fact: EVP ERM and his team provides reporting to the committee

reasoning: The paragraph primarily answers how the board oversees cybersecurity: the Risk Management Committee's oversight role, quarterly reporting from management to the committee, and the committee's reporting to the full board — all describing the governance chain. It also contains a backward-looking materiality assessment (SI) and speculative risk language (N/O), but BG content dominates the first half. Specificity reaches Level 3 via the EVP ERM title (VP+ role) and the named Risk Management Committee, but no externally verifiable claims push it to Level 4 (the negative incident assertion is not independently verifiable).

thinking:
Let me analyze this paragraph carefully.

Category: This paragraph covers multiple topics. Let me break it down:
1. Risk Management Committee of the Board oversees ERM framework - Board Governance
2. Management team including EVP ERM provides quarterly reporting to the committee - Board Governance (information flow to board)
3. "In 2024, no cybersecurity events were identified that materially impacted..." - Strategy Integration (materiality assessment)
4. Cross-reference to Risk Factors section - N/O
5. Speculative breach language ("could pose", "could enable") - N/O (generic risk factor language)

6. The first three sentences focus on board oversight structure and reporting lines, which is clearly Board Governance. Then there's that one sentence about the 2024 materiality assessment, which falls under Strategy Integration per Rule 5. The rest is speculative risk language and cross-references that don't fit either category. Board Governance dominates the first half with the most substantive content about oversight and reporting, while the second half trails off into generic risk factors and references.

Looking at specificity now: the EVP ERM is a firm-specific role at the executive vice president level, which is more concrete than the generic Risk Management Committee that many companies have. The quarterly reporting cadence is standard, and the "In 2024, no cybersecurity events were identified that materially impacted" statement is a negative self-assertion that isn't independently verifiable. The Risk Management Committee itself is a named board-level committee, though calling it specifically a "Risk Management Committee" rather than just an "Audit Committee" does add some specificity about governance structure.

The EVP ERM role is the clearest firm-specific indicator here, which puts this at Level 3 - Firm-Specific.


fact: threat intelligence sharing

fact: Arizona Cyber Threat Response Alliance (ACTRA)

fact: The Internet and Television Association (NCTA)

reasoning: The paragraph describes a cybersecurity program activity — intelligence sharing about emerging threats through collaboration and partnerships — making it RMP. Named external organizations ACTRA and NCTA are independently verifiable entities whose partnership with the company could be confirmed, elevating specificity to Level 4.

thinking:
Classify this paragraph.

Content: Intelligence sharing about emerging threats through industry collaboration, consultants, and public-private partnerships with named organizations (ACTRA, NCTA).

Category: This describes what the cybersecurity program does - threat intelligence sharing activities. RMP.

Specificity: Named organizations ACTRA and NCTA are specific, named entities that are verifiable. These are firm-specific facts (named partnerships). Actually, ACTRA and NCTA are named external organizations - these are verifiable (you can confirm membership/partnership).

Named firms: ACTRA, NCTA - these are externally verifiable organizations. But does membership constitute a verifiable claim? Yes, you could verify if Cable One participates in ACTRA.

"Threat intelligence" is a domain-specific term, and the named partnerships with ACTRA and NCTA are externally verifiable, making this a Level 4 claim.


fact: Director of IT Security and Compliance (Director-level title with security qualifier)

fact: IT Steering Committee

fact: vulnerability assessments

fact: third-party control tests

fact: continuous monitoring techniques

reasoning: The paragraph primarily answers what the cybersecurity program does — assessments, monitoring, threat elevation — and the person-removal test leaves substantial program description intact, so RMP. Specificity reaches Level 3 via the firm-specific 'Director of IT Security and Compliance' (Director with security qualifier) and 'IT Steering Committee' (named non-generic committee).

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity assessment activities (internal tools, third-party tests, vulnerability assessments, audits), governance structures for elevating threats, and monitoring techniques using frameworks.

Category: The paragraph describes what the cybersecurity program does - assessments, monitoring, governance structures for threat elevation. There are named roles (Director of IT, Director of IT Security and Compliance) but the primary content is about program activities. Person-removal test: remove the titles and you still have substantial program description (assessment tools, third-party control tests, vulnerability assessments, audits, monitoring techniques, industry frameworks). → RMP

Now I'm checking the specificity of the roles and committees mentioned. The Director of IT is generic, but the Director of IT Security and Compliance is a firm-specific title with a security qualifier, and the IT Steering Committee is a named governance structure, which pushes this to Level 3.


fact: SOC2 report evaluations

fact: SOC 2 Trust Services Criteria enumerated: security, availability of data, processing integrity, confidentiality and privacy controls

reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party vendors/service providers — due diligence surveys, centralized registry, vendor reviews — making TP the primary category. The mention of SOC 2 reports and the enumeration of Trust Services Criteria (security, availability, processing integrity, confidentiality, privacy) demonstrates domain knowledge beyond generic ERM language, reaching Level 2. No firm-specific or verifiable facts elevate it further.

thinking:
Classifying this paragraph about AHR's third-party risk management and related practices.

Category: The central topic is managing cybersecurity risks from third-party service providers/vendors. This is Third-Party Risk (TP). The last sentence about cybersecurity insurance is Strategy Integration, but the dominant content is TP.

Specificity: Let me scan for facts.
- "SOC2 report evaluations" - this is a domain term (SOC 2) that passes the ERM test
- "centralized registry" for third-party vendors - this is somewhat firm-specific but generic enough

- The mention of SOC 2 Trust Services Criteria—security, availability, processing integrity, confidentiality, and privacy—demonstrates domain knowledge, but these are standard criteria rather than company-specific details. No verifiable claims or distinguishing facts here.

Level 2.


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing ERM integration and listing approaches (third-party assessments, internal audit, IT security, GRC reviews), making it RMP. The vocabulary is entirely within what a non-security ERM professional would use — 'multi-faceted approach,' 'governance, risk and compliance,' 'internal audit' — none of these pass the ERM test for domain-adapted terminology.

thinking:
Classify this paragraph.

Content: Describes how cybersecurity risk is integrated into overall risk management, and lists approaches (third-party assessments, internal audit, IT security, GRC reviews). This is about what the program does → RMP.

Specific facts:
- "governance, risk and compliance reviews" - GRC is a domain term that passes the ERM test? Hmm, GRC is used broadly but in this context it's a security domain concept. Actually, GRC is used in general enterprise risk management too. Let me reconsider.

- The language here is pretty generic—"multi-faceted approach," "identified and addressed"—and the methods listed (third-party assessments, internal audit, IT security, GRC) are standard approaches any ERM professional would recognize. This points to Level 1.


fact: October 2023 cybersecurity incident

fact: 23andMe.com accounts were accessed and downloaded without authorization

fact: Security Operations enhancements

fact: Two-step verification required for new and existing customers

fact: Enhanced detection tools and capabilities

fact: Reset customer passwords as remediation

reasoning: The paragraph describes a real cybersecurity incident—unauthorized access to 23andMe.com user accounts—including timeline, nature, and remediation steps, making Incident Disclosure the clear category. Specificity reaches Level 4 due to the specific date (October 2023) and named platform (23andMe.com), both tied to a publicly known, externally verifiable security breach.

thinking:
Classify this paragraph.

Content: Describes a real cybersecurity incident (October 2023, user data accessed/downloaded from 23andMe.com accounts), then describes remediation steps, then mentions ongoing risk and cross-references Risk Factors.

Category: This describes a real incident (what happened, when, remediation). The dominant frame is the incident and response. → Incident Disclosure.

Specific facts:
- "October 2023" - specific date of incident → verifiable
- "23andMe.com" - named platform → verifiable
- "Security Operations" - domain term

- "two-step verification" (MFA) - domain term
- "certain information of our users was accessed and downloaded" - incident detail
- "reset customer passwords" - remediation action

The incident is a real, publicly known event with concrete details like the specific date and named entity, placing this at Level 4 specificity for verifiable information.


reasoning: The paragraph describes program activities — continuous monitoring, security tools detecting suspicious behaviors, and incident response — making it RMP. The language is entirely generic; 'security tools,' 'monitor our environment,' and 'respond to possible security incidents' would be natural in any ERM context, with no domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Describes security monitoring, tools, incident response activities performed by cyber security consultants and IT support team.

Category: This is about what the cybersecurity program does - monitoring, tools, incident response. The "cyber security consultants" are doing program activities. RMP.

Specificity: Let me scan for facts.
- "continuously monitor" - generic
- "security tools" - generic
- "suspicious behaviors" - generic
- "cyber security consultants" - not a named role at VP+ level
- "IT support team" - generic

No domain terms that pass the ERM test. "Security tools," "suspicious behaviors," "monitor our environment" - an ERM professional could say all of this.

There's nothing firm-specific here and no verifiable claims to anchor on, so this lands at Level 1.


fact: penetration testing

fact: threat monitoring

reasoning: The paragraph is framed entirely around third-party services: hiring cybersecurity firms for specialized tasks and imposing security controls on vendors, making TP the central topic per Rule 3. Domain terms like 'penetration testing' and 'threat monitoring' pass the ERM test for Level 2, but no named firms, roles, or verifiable claims elevate it further.

thinking:
Classify this paragraph.

Content: About third-party cybersecurity firms for pen testing, threat monitoring, risk assessments. Also mentions vendor security requirements. The central topic is third-party services and how they manage third-party risk.

Wait - there are two parts: (1) third parties hired to serve the company (assessors, pen testers) → RMP per Rule 3, and (2) requirements imposed on vendors → TP. Let me assess which is central.

First sentence: partners with third-party firms for pen testing, threat monitoring, risk assessments → these are third parties hired to serve the company → RMP.

Second sentence describes vendor security requirements, which falls under TP. The paragraph splits between describing the company's use of external security services and the controls it imposes on its vendors. The title frames this around third-party services broadly, and since the second sentence focuses on requirements imposed on vendors, I'm leaning toward Third-Party Risk Management as the classification.

Looking at Rule 3 more carefully—when vendor oversight is the central topic, it maps to TP. That's the case here. The language uses domain-specific terms like "penetration testing" and "threat monitoring" without naming particular firms or roles, so this qualifies as Level 2 - Domain-Adapted.


reasoning: The paragraph states a backward-looking conclusion that cybersecurity risks have not materially affected business strategy, results of operations, or financial condition, and a forward-looking assessment that they are not reasonably likely to do so — both are materiality assessments triggering SI under Rule 5. 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 reporting period date is contextual, not a cybersecurity fact.

thinking: SI materiality rule applies here.


reasoning: The paragraph's central substantive claim is the backward-looking materiality assessment ('have not experienced a cybersecurity incident that resulted in a material adverse impact to our business or operations'), which is SI per Rule 5. The remainder is a cross-reference to Item 1A and speculative risk language. 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.

thinking:
Let me analyze this paragraph.

Content: States they haven't experienced a material incident, cross-references Item 1A risk factors, and mentions policies are reviewed regularly.

Category: The key statement is "have not experienced a cybersecurity incident that resulted in a material adverse impact" — this is a negative assertion about materiality → SI per Rule 5. There's also a cross-reference to Item 1A. The materiality assessment is the substantive content here.

Specificity: "Have not experienced a cybersecurity incident that resulted in a material adverse impact" — negative self-assertion, NOT externally verifiable.

The cross-reference to Item 1A is just boilerplate navigation with no domain-specific details or verifiable facts — that's Level 1 content.


reasoning: The paragraph's central topic is reviewing third-party IT service providers' cybersecurity measures during engagement, making it Third-Party Risk. The description is entirely generic — 'a review of such providers' cybersecurity measures' contains no domain terminology, no firm-specific details, and no verifiable claims, keeping it at Level 1.

thinking:
Classify this paragraph.

Content: Reviews third-party IT service providers' cybersecurity measures during engagement process.

Category: This is about how they manage third-party cyber risks - reviewing vendors' cybersecurity measures. Third-party risk is the central topic.

Specificity: "third-party information technology service providers" - generic. "review of such providers' cybersecurity measures" - generic process description. No domain terms, no firm-specific facts, no verifiable claims. This is Level 1.


fact: Incident involved unauthorized access of an employee's email account

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

fact: Incident occurred in 2024

reasoning: The paragraph describes a real cybersecurity incident — unauthorized email access leading to fraudulent fund diversion — with timeline, nature, scope, and impact assessment, making it Incident Disclosure. The reference to '2024' as the year of occurrence is a specific, verifiable temporal anchor for the incident. Note the materiality conclusion ('immaterial impact to our financial results') could suggest SI, but the incident narrative is clearly dominant. The impact assessment here is subordinate to the incident frame per Rule 4.

thinking: Incident disclosure with specifics about what happened.


fact: CISO role referenced as providing briefings to Audit Committee and Board

fact: Briefings include assessments of the threat landscape, updates on incidents, results of client security audits, and reports on investments in cybersecurity risk mitigation

reasoning: The paragraph answers how the board oversees cybersecurity: delegation to Audit Committee, briefing structure, and information flow from CISO to committee and board — classic Board Governance. The CISO is a firm-specific named role (VP+ security title), elevating specificity to Level 3; the briefing content details (threat landscape, client security audits) add texture but the Audit Committee is generic and cadences ('at least annually') are not verifiable.

thinking:
Board oversight structure with delegation to Audit Committee, briefing details.

Category: Board Governance - describes how the board oversees cybersecurity through committee delegation and briefing structure.

Specific facts:
- CISO (named role, firm-specific)
- "information security team" - generic
- "at least annually" - generic cadence
- "threat landscape" - domain term? Borderline. ERM professional might use this.
- "client security audits" - domain-ish
- Audit Committee - generic, every company has one

- Briefing content (threat landscape assessments, incident updates, client security audit results, cybersecurity risk mitigation investments) shows some domain specificity but reads as fairly standard governance language

The CISO role is clearly firm-specific and represents Level 3 specificity, while the briefing topics themselves are borderline domain-specific without being particularly distinctive to this organization.


reasoning: The majority of the paragraph addresses how the company oversees third-party service providers (security assessments, ongoing review, compliance with standards), making TP the central topic; the trailing materiality sentence is a secondary SI element. No domain-specific terminology passes the ERM test—'security assessments' and 'ongoing review' are generic process descriptions any risk professional would use—and no firm-specific or verifiable facts are present, leaving this at Level 1.

thinking:
Let me analyze this paragraph.

Content: Two sections merged. First about third-party risk oversight, second a materiality statement.

Category: The first part is about third-party risk management. The second part is a materiality assessment ("have not encountered cybersecurity challenges that have materially impaired our operations or financial standing" → SI per Rule 5).

The majority of text is about third-party risk. But the materiality statement is also present. The third-party content is the central topic for most of the paragraph. I'll go with Third-Party Risk as the primary category since it has more text.

Looking more closely, the third-party section definitely dominates the word count. The materiality claim is brief and unverifiable. For specificity, I'm seeing mostly generic process language—"security assessments of all third-party providers" is standard practice without concrete details. The negative assertion about not encountering material cybersecurity challenges is self-reported with no supporting evidence. Nothing here rises above L1 generality.


reasoning: The paragraph describes the company's commitment to safeguarding systems and implementing policies/procedures to mitigate cyber risks, which answers 'what does the program do?' albeit at the most generic level. Every phrase ('robust policies, procedures, and security measures,' 'mitigate risks,' 'ensure compliance') is standard ERM language with no domain-specific terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Generic intro about cybersecurity commitment. No specific processes, no board, no management, no incidents. It's describing their general approach to cybersecurity risk management but in very generic terms.

Category: RMP - it's about what the cybersecurity program does, but very generically.

Specificity: "policies, procedures, and security measures", "mitigate risks", "ensure compliance" - all generic ERM language. No domain terms that pass the ERM test. Level 1.


fact: Senior Vice President and General Counsel reports to audit committee on cybersecurity

fact: Vice President, Finance and Controller reports to audit committee on cybersecurity

reasoning: The paragraph describes how the Audit Committee receives cybersecurity briefings — classic board oversight / information-flow-to-the-board content → Board Governance. The specific reporting structure naming SVP/General Counsel and VP Finance/Controller as the roles briefing the audit committee on cybersecurity is a firm-specific organizational detail (analogous to naming specific departments in a cross-functional team), elevating to Level 3. The remaining language ('periodic reports,' 'significant cybersecurity threats and risk,' 'processes to address them') is generic oversight boilerplate.

thinking:
Classify this paragraph.

Content: Audit Committee receives reports from SVP/GC, CFO, VP Finance/Controller about cybersecurity threats/risk. Also receives reports/summaries about cybersecurity.

Category: This is about how the board (via Audit Committee) oversees cybersecurity - information flow to the board. → Board Governance.

Specific facts:
- "Senior Vice President and General Counsel" - named role at VP+ level
- "Chief Financial Officer" - generic role every company has
- "Vice President, Finance and Controller" - VP-level role

Wait - CFO is generic.

Now I'm thinking through whether these roles are actually cybersecurity-specific. The instructions focus on cybersecurity leadership like CISO, CTO, CIO, or IT-level executives, but here we have finance and legal roles reporting on cyber to the audit committee. The SVP/GC and VP Finance/Controller are firm-specific positions with defined titles, which suggests this describes the company's particular reporting structure rather than generic governance. The Audit Committee itself and the CFO are standard across companies, but the specific combination of who reports on cybersecurity matters does distinguish this organization's approach. Finance and Controller roles have finance portfolios, not IT or cybersecurity ones, so they don't meet the firm-specific criteria on that basis. But wait—the paragraph actually names specific organizational positions reporting to the audit committee on cyber matters, which matches the rule about "specific team compositions by department." That specific reporting structure does seem to qualify as a firm-specific organizational claim.


reasoning: The paragraph's central statement is a backward-looking materiality assessment ('has not experienced a cybersecurity incident that has materially affected our operations, reputation, or financial performance'), which maps to Strategy Integration under Rule 5. No domain terms, firm-specific facts, or verifiable claims are present — the negative materiality assertion is a self-reported claim about absence and the remaining language is generic boilerplate.

thinking:
Classify this paragraph.

The paragraph states "has not experienced a cybersecurity incident that has materially affected our operations, reputation, or financial performance" — this is a backward-looking materiality assessment → SI.

It also has generic forward-looking language about cyber threats and investing in technologies.

The materiality assessment is the core content → Strategy Integration.

Specificity: The negative materiality assertion is not externally verifiable. "invest in technologies and partnerships" is generic. No domain terms, no firm-specific facts, no verifiable claims.

Level 1.


reasoning: The paragraph primarily answers what the cybersecurity program does: regular evaluation by internal/external experts and engagement with vendors, industry participants, and law enforcement. Reporting to senior management/Audit Committee/Board is subordinate context. No domain terms pass the ERM test (evaluation, engagement, policies and procedures are generic), Audit Committee is not firm-specific per rules, and 'ELT' is a generic executive leadership team reference, leaving no facts above Level 1.

thinking:
Classify this paragraph.

The paragraph describes evaluation of the information security program by internal/external experts, reporting results to senior management/ELT/Audit Committee/Board, and engagement with vendors, industry participants, and law enforcement.

Category: This is about what the program does (evaluation, engagement) and how results flow up. The governance chain aspect (reporting to ELT, Audit Committee, Board) is present but the primary content is about program evaluation and external engagement activities. The person-removal test: remove reporting lines, the program evaluation and external engagement remain. This leans RMP.

Actually, let me reconsider. The first sentence is about program evaluation (RMP activity) with results reported upward (governance chain).

The second sentence focuses on external engagement to strengthen the program—vendors, industry peers, and law enforcement—which is fundamentally answering what the cybersecurity program does, pointing toward RMP. The language around law enforcement engagement has some ERM flavor, but the overall vocabulary and framing stay generic to information security rather than risk management.

Looking at the specific entities mentioned: "ELT" is just the executive leadership team, "FactSet Audit Committee" is the company's audit committee (generic governance), and "information security program" is standard terminology. There's nothing here that signals firm-specific facts or domain-specific risk management language—this reads as Level 1 generic boilerplate.


reasoning: The paragraph describes the company's framework for threat detection, incident response, and risk mitigation, answering 'what does the cybersecurity program do?' → RMP. The language is entirely generic — 'threat detection,' 'incident response,' and 'risk mitigation' are standard ERM terms that fail the domain expertise test, and no named framework, domain-specific tools, firm-specific details, or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Describes a framework for identifying and mitigating cybersecurity threats, with procedures for threat detection, incident response, and risk mitigation.

Category: RMP - describes what the cybersecurity program does.

Specificity: Let me check for specific facts. "threat detection, incident response, and risk mitigation" - these are generic process descriptions. No named framework, no domain-specific terms that pass the ERM test. "Incident response" is listed as commonly confused L1. "Threat detection" - would an ERM professional use this? It's borderline but fairly generic. "Risk mitigation" is definitely generic.

The language here is pure boilerplate with no specificity—just standard terminology that any cybersecurity program would use. This is clearly Level 1.


reasoning: The paragraph describes executive management's responsibility for overseeing cybersecurity strategy, making it about management's organizational role rather than board governance or program activities. The text is truncated and contains only generic language ('cybersecurity risk,' 'risk oversight,' 'cybersecurity strategy') with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims, keeping it at Level 1.

thinking:
Classify this paragraph.

The paragraph talks about executive management's oversight of cybersecurity risk and strategy. It's cut off ("during the year ended"). Let me classify what's there.

Category: This describes management's role in overseeing cybersecurity strategy - but it's about oversight structure. "Executive management considers cybersecurity risk... has ultimate responsibility for overseeing our cybersecurity strategy." This is about management's organizational role and responsibility. Per Rule 1, this is MR since it's about management's responsibilities.

Wait - "executive management" is generic. No specific roles named. The paragraph is about management oversight responsibility.

So this is MR - it's describing the company's management responsibility for cybersecurity oversight. The language is generic without domain-specific details or firm-specific facts, making this Level 1 specificity.


reasoning: The paragraph primarily answers how the board oversees cybersecurity — management reports to the Audit Committee, which evaluates overall cybersecurity strategy, making this Board Governance. The 'Senior Director, Global Information Security' is a Director-level title with a security qualifier, elevating specificity to Firm-Specific.

thinking:
Classify this paragraph.

The paragraph describes how information flows from management to the Audit Committee (board-level), covering reporting cadence, format, and the committee's role in evaluating cybersecurity strategy. This is about board oversight structure → Board Governance.

Specific facts:
- "Senior Director, Global Information Security" — This is a Director-level title WITH a security qualifier → Firm-Specific (Level 3)
- "Audit Committee" — generic, every company has one → NOT firm-specific

Specificity: Level 3 (Firm-Specific) due to the named role.


reasoning: The paragraph states a backward-looking materiality conclusion ('have to date not materially affected us, our business strategy, results of operations or financial condition'), which is a textbook SI assessment per Rule 5. Specificity remains Level 1: the negative materiality assertion is not externally verifiable, 'from time to time' is vague, and no domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

"Although risks from cybersecurity threats have to date not materially affected us, our business strategy, results of operations or financial condition, we have, from time to time, experienced threats to and breaches of our and our third-party vendors' data and systems."

Category: This is a materiality assessment - "have to date not materially affected us, our business strategy, results of operations or financial condition" → SI per Rule 5.

Specificity: The materiality statement is a negative self-assertion, not externally verifiable. No domain terms, no firm-specific facts, no verifiable claims.

This lands at Level 1 disclosure.


fact: cyber response protocol

fact: November 2023 cybersecurity incident

fact: investigation with assistance from external cybersecurity experts

fact: coordinated with law enforcement

fact: notified affected individuals and regulators as required by applicable law

reasoning: The paragraph opens with a materiality assessment (SI) and ends with cross-references (N/O), but the dominant frame is a description of the actual November 2023 cybersecurity incident—detection, investigation, remediation, and notification—making Incident Disclosure the primary category per Rule 4. The specific date 'November 2023' tied to a publicly disclosed real cybersecurity event is externally verifiable, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

It covers multiple topics: a materiality assessment, an actual incident description, and cross-references. Let me determine the primary category.

The paragraph starts with a materiality statement (SI), then describes an actual November 2023 incident in detail (ID), then has forward-looking language and cross-references (N/O).

The bulk of the text describes what happened in the incident - detection, investigation, remediation, notification. The incident description dominates. But it also opens with a clear SI materiality assessment and closes with cross-references.

Given the mix, the incident frame is dominant - most of the text describes the actual event.

The opening line is a clear SI materiality conclusion, but looking at the structure: one sentence on materiality, about five sentences on the actual incident, one forward-looking statement, and two cross-reference sentences. The incident frame clearly dominates, so this falls under ID. On specificity, I have "November 2023" as a verifiable date tied to a real event, though "external cybersecurity experts" lacks naming and "cyber response protocol" is just domain terminology.

Now I'm seeing that LivaNova is the named company here, and the paragraph includes specific actions like notifying affected individuals and regulators as required by law. The November 2023 date is externally verifiable since this was publicly disclosed, which points to Level 4.


reasoning: This is a cross-reference fragment pointing to Item 1A Risk Factors with no substantive cybersecurity disclosure of its own. No specific facts elevate specificity above Level 1.

thinking: This is a fragment - a cross-reference to Item 1A Risk Factors. No substantive cybersecurity disclosure.


reasoning: The paragraph is centrally about how the company oversees third-party providers' cybersecurity compliance, making TP the clear category. The language ('due diligence', 'periodically reviewing', 'comply with necessary cybersecurity standards') is entirely generic — no domain terms, firm-specific facts, or verifiable claims, so Level 1.

thinking:
Classify this paragraph.

Content: About managing third-party provider cybersecurity risk through due diligence and periodic review.

Category: Third-Party Risk — this is centrally about how third-party cyber risks are managed (vendor oversight).

Specificity: "due diligence", "periodically reviewing", "comply with necessary cybersecurity standards" — all generic. No domain terms that pass the ERM test. No firm-specific facts. Level 1.


reasoning: This is a cross-reference directing readers to Item 1A Risk Factors, with no substantive cybersecurity disclosure — just a pointer elsewhere. No domain terms, firm-specific facts, or verifiable claims.


fact: Forensic investigation of the 2025 Cybersecurity Incident is complete

fact: Between approximately August 5-8, 2025, a threat actor gained unauthorized access

fact: Threat actor may have acquired certain data

reasoning: The paragraph primarily describes what happened in a real cybersecurity incident — timeline, threat actor access, forensic investigation completion — making it Incident Disclosure. The later materiality language is speculative ('not yet determined,' 'could materially affect') and a cross-reference, not a materiality assessment. The specific dates 'August 5-8, 2025' are externally verifiable facts tied to a real event, driving specificity to Level 4.

thinking: Incident disclosure with specific dates and details about a real event.


reasoning: The paragraph states a conclusion about whether cybersecurity has materially affected business strategy, results of operations, or financial condition — a backward-looking materiality assessment triggering SI under Rule 5. No specific facts elevate specificity: the negative assertion about incidents is not externally verifiable, and 'December 31, 2023' is merely a reporting period anchor.

thinking:
Materiality assessment - backward-looking negative assertion about incidents + forward-looking "reasonably likely to materially affect" language. This is SI per Rule 5.

Specificity: "no material incidents" is a negative self-assertion, not externally verifiable. The date "December 31, 2023" is a reporting period, not a cybersecurity fact. This is Level 1.


fact: CISO role reporting directly to CIO

fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)

fact: Legal team included in cybersecurity oversight

reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing the governance chain from Board/Audit Committee down through management with reporting cadences, making it Board Governance. The CISO and CIO are firm-specific named roles, and the CISO-to-CIO reporting line is a firm-specific organizational detail, elevating to Level 3. Quarterly cadence is generic and does not reach Level 4.

thinking:
Classify this paragraph.

Category: This describes the oversight structure - Board, Audit Committee, Legal team overseeing cybersecurity, with CISO reporting to CIO, and quarterly updates to Audit Committee/Board. The primary question answered is "How does the board oversee cybersecurity?" - it's a governance-chain paragraph describing oversight structure → Board Governance.

Specific facts:
- CISO (named role, firm-specific)
- CIO (named role, firm-specific)
- CISO reports to CIO (firm-specific reporting line)
- "quarterly updates to the Audit Committee" - generic cadence

- Legal team involvement in oversight appears to be firm-specific team composition

The CISO and CIO are VP-level+ roles, which pushes this into firm-specific territory at Level 3.


fact: President and CEO has more than 20 years of experience in Business Finance and Audit management

fact: January 2020 start date for leading information security team

reasoning: The paragraph describes the CEO's role leading the information security team, his qualifications, and his reporting line to the Board—person-removal leaves almost nothing, confirming MR over BG. 'More than 20 years of experience' is a verifiable lower bound and 'January 2020' is a specific date, elevating to Level 4.

thinking:
Classify this paragraph.

Content: CEO with 20+ years experience leads info security team, reports to Board on cybersecurity programs.

Category: This is about the CEO's role in managing cybersecurity - his responsibilities, experience, reporting lines. Person-removal test: remove CEO, 20 years experience, reporting to Board → almost nothing remains. → MR.

But wait - "reports directly to our Board of Directors" describes information flow to the board. BG vs MR: The primary content is about the CEO's role, qualifications, and responsibilities. The board reporting is subordinate. → MR.

Now I'm checking the specificity markers. The title "President and CEO" is a generic governance role, not firm-specific. The 20+ years in Business Finance and Audit management is verifiable against a resume, and the January 2020 start date for leading the security team gives me a concrete reference point. That puts this at Level 4.


reasoning: This is a fragment containing a backward-looking materiality assertion ('not encountered cybersecurity challenges that have materially impaired our operations or financial standing'), which is an assessment of business impact → SI per Rule 5. The cross-reference to Item 1A is secondary. No domain terms, firm-specific facts, or verifiable claims are present, keeping specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: "encountered cybersecurity challenges that have materially impaired our operations or financial standing. For additional information regarding risks from cybersecurity threats, please refer to Item 1A, "Risk Factors," in this Annual Governance"

This appears to be a fragment. It seems to be the tail end of a sentence like "We have not encountered cybersecurity challenges that have materially impaired our operations or financial standing." followed by a cross-reference.

The key statement is a negative materiality assertion + cross-reference.

Category: The materiality assertion "have [not] materially impaired our operations or financial standing" is a backward-looking assessment → SI per Rule 5.

The cross-reference is just a pointer, so the real substance here is the materiality assessment itself. This is a negative self-assertion about the absence of material cybersecurity incidents, which isn't externally verifiable and lacks any specific facts or firm-specific details. That makes it generic boilerplate at Level 1.


reasoning: This is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk descriptions, with no substantive cybersecurity disclosure of its own. No specific facts elevate specificity above Level 1.

thinking: Cross-reference to Item 1A risk factors.


fact: COO leads cybersecurity strategy

fact: COO reports to CEO

fact: Over 15 years of experience in cybersecurity

reasoning: The paragraph describes the COO's role, reporting line, qualifications, and cybersecurity responsibilities — squarely Management Role. 'Over 15 years of experience' is a lower-bound quantified claim verifiable against a resume, elevating specificity to Level 4.

thinking:
Classify this paragraph.

Content: About the COO's role, reporting line, qualifications, and responsibilities in cybersecurity.

Category: Management Role - describes a leadership role (COO), reporting line (to CEO), qualifications (15 years experience), and responsibilities (cybersecurity strategy, risk assessments, incident response, compliance).

Person-removal test: Remove COO, reporting to CEO, 15 years experience → "leads the development and implementation of our cybersecurity strategy... oversees risk assessments, incident response, and compliance with industry standards." Some program description remains, but the paragraph is primarily about the role and qualifications. The frame is about WHO does this and their qualifications. → MR.

The COO role is firm-specific with cybersecurity responsibility, reports to the CEO, and requires over 15 years of experience—a quantified, verifiable lower bound. The responsibilities listed (risk assessments, incident response, compliance) are generic ERM terms, so the specificity level is determined by the experience requirement, making this Level 4 (Quantified-Verifiable).


fact: phishing attempts

fact: scanning (network/port scanning as threat activity)

reasoning: The paragraph's primary purpose is a backward-looking materiality assessment ('did not identify any cybersecurity incidents that had a material impact on our operations, liquidity, or financial condition'), which maps to Strategy Integration under Rule 5. The negative assertion is not externally verifiable, and the fiscal year dates are reporting-period context rather than cybersecurity facts. References to 'phishing attempts' and 'scanning' are domain-specific threat types that pass the ERM test, elevating specificity to Level 2.

thinking:
Let me analyze this paragraph.

Content: States no material incidents in fiscal years ended April 30, 2025 and 2024, mentions routine scanning/phishing/vulnerabilities were mitigated.

Category: This is a materiality assessment - "did not identify any cybersecurity incidents that had a material impact" → SI per Rule 5 (negative assertion about material impact).

Specificity:
- "fiscal years ended April 30, 2025 and 2024" - reporting period context, not cybersecurity facts
- "routine scanning, phishing attempts, and minor technical vulnerabilities" - these are threat types but fairly generic

- The negative materiality assertion itself isn't externally verifiable, though the threat types mentioned—phishing attempts, network scanning, and vulnerabilities—are domain-specific terms that demonstrate cybersecurity knowledge. This pushes the disclosure toward Domain-Adapted (Level 2) specificity despite the unverifiable materiality claim.


reasoning: This is a backward-looking materiality assessment stating no cybersecurity incidents have materially affected business strategy, results, or financial condition — directly triggering the SI materiality rule. The negative self-assertion about absence of material incidents is not externally verifiable, and there are no domain terms, firm-specific facts, or quantified claims, so specificity remains Level 1.

thinking: SI materiality rule applies here.


reasoning: The paragraph makes both a backward-looking materiality conclusion ('have not...materially affected us') and a forward-looking SEC Item 106(b)(2) assessment ('are reasonably likely to materially affect'), squarely fitting Strategy Integration under Rule 5. No domain terms, firm-specific facts, or verifiable claims are present—the negative incident assertion is not externally verifiable, and the cross-reference to Risk Factors is generic boilerplate.

thinking: SI - materiality assessment both backward and forward-looking, plus cross-reference.


reasoning: The paragraph centrally addresses how third-party vendors and contractors are assessed for cybersecurity risks and expected to meet security requirements — squarely Third-Party Risk. The language is entirely generic ('assessed for risks,' 'information security requirements,' 'annual basis') with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Central topic: third-party vendor cybersecurity oversight. Annual assessment of vendors, security requirements for vendors with data access.

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

Specific facts:
- "annual basis" - generic cadence
- "assessed for any applicable cybersecurity or service availability risks" - generic process description
- No domain terms that pass ERM test - "cybersecurity or service availability risks" is generic, "information security requirements" is generic

This is pretty generic. No domain terms, no firm-specific facts, no verifiable claims.

This lands at Generic Boilerplate level - it's standard vendor risk management language without any specific details or measurable commitments.


reasoning: This paragraph is a generic risk factor discussion with speculative language ('may be perceived', 'may lose', 'could affect') and a cross-reference to Item 1A Risk Factors, containing no substantive cybersecurity program disclosure. N/O paragraphs receive Generic Boilerplate.

thinking:
This is a risk factor discussion with speculative language ("could have", "may be perceived", "may lose") and a cross-reference to Item 1A Risk Factors. No actual cybersecurity measures or programs described. The materiality-adjacent language "could affect BlackLine, including our business strategy, results of operations, or financial condition" is speculative ("could"), not an assessment.

This is None/Other - it's a forward-looking disclaimer/risk factor cross-reference with no substantive cybersecurity disclosure.

Specificity: N/O always gets Generic Boilerplate.


reasoning: The paragraph concludes with a backward-looking negative assertion ('we are not aware of any cybersecurity threats, nor have we had any cybersecurity incidents'), which is a company-level assessment of cybersecurity impact on the business, fitting SI under Rule 5. The bulk of the text is speculative risk language ('could have a material adverse impact') which alone would be N/O, but the concluding assertion tips it to SI. No domain terms passing the ERM test, no firm-specific facts, and the negative assertion is not externally verifiable, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: This is speculative risk language ("may be unable to", "could have a material adverse impact") combined with a negative assertion about incidents ("we are not aware of any cybersecurity threats, nor have we had any cybersecurity incidents").

Category: The speculative "could have a material adverse effect" language is NOT SI per Rule 5. The negative assertion "we are not aware of any cybersecurity threats, nor have we had any cybersecurity incidents" - is this an SI materiality assessment? It's a negative assertion but without the word "material" - it's saying no incidents at all. This is similar to "Have not experienced any material cybersecurity incidents" → SI.

The negative assertion about having no incidents at all is actually a backward-looking assessment of their cybersecurity posture, which makes it SI. The bulk of the paragraph is speculative risk language that's not SI, but that final sentence—claiming no awareness of threats and no incidents—functions as a materiality assessment, so I'd classify the overall paragraph as mixed, with the speculative portions being N/O and the assertion being SI.

Actually, the assessment is what matters here. I'll mark it SI. Now looking at specificity: the statement "to date we are not aware of any cybersecurity threats, nor have we had any cybersecurity incidents" is a negative self-assertion that isn't externally verifiable. There are no domain-specific terms that would pass the ERM test, no firm-specific facts, nothing verifiable. This is generic boilerplate. Even though it's SI rather than N/O, I still need to evaluate specificity independently, and there's nothing here—no domain terminology, no concrete facts, no verifiable claims. This lands at Level 1.


fact: Cybersecurity overseen by independent board members (not full board or standard committee)

fact: Quarterly review of cybersecurity program including key program metrics, initiatives, and developments

reasoning: The paragraph describes board-level oversight of cybersecurity — who oversees it (independent board members), review cadence, and incident escalation — squarely answering the BG question. The oversight structure by 'independent board members' rather than a named committee is a somewhat unusual firm-specific arrangement, though the quarterly cadence alone is generic. The designation of a specific subset (independent board members) as the oversight body is a firm-specific organizational fact that distinguishes this company's governance structure.

thinking: Board oversight, quarterly review, incident escalation to board.


reasoning: The paragraph describes ERM integration of the cybersecurity program, answering 'what does the program do?' — placing it in RMP. The language is entirely generic ('common methodologies, reporting channels and governance processes') with no domain-specific terms, firm-specific facts, or verifiable claims; the trailing company name is a page footer, not a distinguishing fact.

thinking:
Classify this paragraph.

Content: ERM integration statement, very generic. The company name at the end is just a footer.

Category: Risk Management Process (ERM integration)

Specificity: "enterprise risk management program" - this is generic ERM language. No domain terms, no firm-specific facts, no verifiable claims. Level 1.


reasoning: This is a definitional fragment defining 'systems' as electronic information resources — it answers none of the six substantive cybersecurity questions and appears to be a truncated legal definition. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: This appears to be a definition of "systems" - likely a continuation of a larger paragraph defining terms. It's purely definitional, not describing any cybersecurity program, governance, or incident.