reasoning: The paragraph describes how the Board and Audit Committee oversee cybersecurity risks, including reporting lines and briefing cadence, squarely answering the board oversight question. All elements are generic governance structures (Board, Audit Committee, CFO) and generic cadences ('regular updates', 'at least an annual basis') that exist at virtually every public company, with no domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: Board/Audit Committee oversight of cybersecurity risks, briefing frequency, how information flows to the board. This is Board Governance.

Specific facts:
- Audit Committee (generic, every company has one - NOT firm-specific)
- Chief Financial Officer (generic role - NOT firm-specific)
- "at least an annual basis" - generic cadence

No domain terms that pass the ERM test. No firm-specific facts (CFO is generic, Audit Committee is generic). No verifiable claims.

This is Level 1 - Generic Boilerplate.


content_category: Board Governance

fact: ISO (Information Security Officer) role in incident reporting chain

fact: CISO role

fact: Senior Vice President, General Counsel & Compliance Officer role

category_confidence: high

specificity_confidence: high

reasoning: The paragraph primarily describes how the audit committee and Board oversee cybersecurity and how incident information flows upward, making it Board Governance. Specificity is Firm-Specific due to named roles (ISO, CISO, SVP General Counsel & Compliance Officer) that distinguish this company's governance structure, though no externally verifiable claims are present.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

Category: This describes how the board/audit committee oversees cybersecurity, how information flows to the board, and the reporting chain for incidents. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- Audit committee (generic, every company has one) → not firm-specific
- ISO (Information Security Officer) → named role, firm-specific
- CEO, CFO → generic
- CISO → firm-specific (VP+ security role)
- Senior Vice President, General Counsel & Compliance Officer → firm-specific (specific title)

- Reporting chain flows from ISO through CEO, CFO, and CISO to the audit committee, with the CISO, ISO, and SVP General Counsel & Compliance Officer representing the key named roles in this cybersecurity governance structure.


content_category: Management Role

fact: Chief Information Security Officer (CISO)

fact: Board's Risk Oversight Committee

fact: Information Security Program

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

type: quantified

fact: CISO has over 20 years of work experience in cybersecurity at financial institutions

reasoning: The paragraph primarily describes management roles (CPO, CISO), their responsibilities, reporting lines, and qualifications—person-removal collapses it, confirming MR over BG or RMP. Specificity reaches Level 4 due to two verifiable lower-bound claims: 'over 13 years' as CFO and 'over 20 years' of cybersecurity experience, both checkable against career records.

thinking:
Let me analyze this paragraph.

Content: Describes management roles - CRO/CPO oversight, CISO coordination, reporting to Board's Risk Oversight Committee, responsibilities, and qualifications of both CPO and CISO.

Category: This is primarily about management roles - who is responsible, their qualifications, reporting lines. The mention of reporting to the Board's Risk Oversight Committee is subordinate to the management organization description. Using the person-removal test: remove all person-specific content and very little substantive program description remains. → MR

Specific facts:
- Chief Risk Officer designated as Chief Privacy Officer (named_role, firm-specific)

- Chief Information Security Officer, Board's Risk Oversight Committee, Information Security Program, and Security Incident Response Policy and Plan all identified as firm-specific entities
- CISO brings over 20 years of cybersecurity experience at financial institutions, and previously served as CFO for more than 13 years - both quantified, verifiable claims

Specificity: Level 4 due to verifiable quantified claims about professional background.


fact: ISMS (Information Security Management System)

fact: Chief Information Officer

reasoning: The paragraph primarily answers how the board oversees cybersecurity — describing the audit and risk committee's role, reporting to the full board, and how information flows upward — making it Board Governance. Specificity reaches Firm-Specific due to named leadership roles (CIO, Executive Director of Information Security) that distinguish this company's governance structure, plus the domain term ISMS.

thinking:
Classify this paragraph.

Category: Board governance - describes board/committee oversight of cybersecurity risks, how information flows to the board.

Specific facts:
- "audit and risk committee" - named committee (though "audit committee" is generic, "audit and risk committee" is slightly more specific)
- "Chief Information Officer" - named role (CIO is VP+ level)
- "Executive Director of Information Security" - named role with security qualifier
- "ISMS" (Information Security Management System) - domain term
- "enterprise risk management program" - generic ERM term, not domain-specific

Wait - "audit and risk committee" - this is essentially an audit committee variant.

The audit and risk committee is a standard board committee, so it doesn't count as firm-specific. The CIO qualifies as firm-specific since it's a VP+ level role, and the Executive Director of Information Security is firm-specific because it's a director-level title with a security qualifier. ISMS is a domain-specific term. Overall, this falls into Firm-Specific (Level 3) based on the executive roles and security terminology.


fact: forensic analysis

fact: military veterans versed in forensic analysis and regulatory compliance

fact: Master's degree in Cybersecurity

reasoning: The paragraph describes the qualifications, background, and composition of the cybersecurity leadership team; the person-removal test collapses it to nothing, confirming MR. Specificity reaches Level 4 due to 'over 23 years of combined Cybersecurity experience' (verifiable lower bound) and 'Master's degree in Cybersecurity' (verifiable credential).

thinking:
Classify this paragraph.

Category: This is about the cybersecurity leadership team's qualifications and background. Person-removal test: remove all person-specific content (qualifications, experience, team composition) → nothing substantive remains. → MR.

Specific facts:
- "military veterans" — firm-specific team composition detail
- "forensic analysis" — domain term
- "over 23 years of combined Cybersecurity experience" — quantified, verifiable (lower bound)
- "Master's degree in Cybersecurity" — verifiable credential

- "industry certifications" — generic, not named specifically

The quantified experience and named credential push this to Level 4 specificity.


content_category: Risk Management Process

fact: firewalls

fact: anti-malware functionality

fact: access controls

reasoning: The paragraph describes technical safeguards and third-party evaluations as components of the cybersecurity program (RMP). Third parties are hired to serve the company (assessors, auditors), keeping this RMP per Rule 3. Domain terms like firewalls, IDS/IPS, and anti-malware pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Technical safeguards (firewalls, IDS/IPS, anti-malware, access controls) and third-party evaluations/audits.

Category: RMP - describes what the cybersecurity program does (technical safeguards, security controls). Third parties are mentioned but as part of the internal program (Rule 3: third parties hired to serve the company → RMP).

Specificity: Domain terms include firewalls, intrusion prevention and detection systems, anti-malware, access controls. These pass the ERM test. No firm-specific facts or verifiable claims.

This is a Level 2 classification.


fact: Chief Technology Officer role responsible for cybersecurity

fact: over 15 years of experience in software development and security architecture

fact: security architecture

reasoning: The paragraph centers on the CTO's role, qualifications, and reporting relationship with General Counsel — the person-removal test leaves almost no substantive content, confirming MR. 'Over 15 years of experience' sets a verifiable lower bound, driving specificity to Level 4.

thinking:
Classify this paragraph.

Category: This is about the CTO's role, responsibilities, qualifications, and reporting lines. Person-removal test: remove CTO, 15 years experience, General Counsel → almost nothing substantive remains about the program. → MR

Specific facts:
- CTO (named role, firm-specific)
- "over 15 years of experience" — lower bound, verifiable → QV
- "security architecture" — domain term
- General Counsel — generic role, not firm-specific

Specificity: "over 15 years of experience" is a verifiable lower bound → Level 4


fact: privileged access policies

fact: multi-factor authentication

category_confidence: medium

reasoning: The paragraph's primary substantive content describes security measures implemented (privileged access policies, expanded MFA), which are program activities (RMP). The incident is referenced but not described; the forward-looking risk language is generic speculation ('cannot provide assurance...will not be materially affected') which per Rule 5 is not SI, and the cross-reference is N/O filler. Specificity reaches Level 2 via domain terms (privileged access policies, multi-factor authentication) that pass the ERM test, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

It mentions security measures after an incident (privileged access policies, MFA), then a forward-looking risk statement, then a cross-reference.

Category: Mixed content. First sentence is about post-incident remediation measures (RMP or ID). Second sentence is forward-looking risk speculation. Third is cross-reference (N/O).

The first sentence references "the incident" - post-incident remediation. This could be ID (remediation of actual incident) or RMP (security measures implemented). Since it describes what was done after an incident, it's remediation which is part of incident disclosure. But the measures themselves are program activities.

The paragraph opens with remediation steps taken after a real incident, then pivots to speculative forward-looking language about potential future impacts. The substantive content centers on the security measures implemented rather than the incident itself, which points toward RMP classification. The forward-looking assurance disclaimer doesn't qualify as SI since it's speculation rather than a concrete assessment.

Looking at the specifics now: "privileged access policies" and "multi-factor authentication" are domain-specific terms that pass the ERM test, and while the text references "the incident," it provides no actual details about what happened. This lands at Level 2 - Domain-Adapted.


content_category: Incident Disclosure

fact: February 23, 2023 - date of network outage

fact: February 28, 2023 - date of further disclosure about data extraction

fact: incident response and business continuity plans activated

fact: Data extracted from DISH Network IT systems

reasoning: The paragraph describes a real cybersecurity incident—a network outage and data extraction—with specific dates, response actions, and scope, making it clearly Incident Disclosure. Two specific dates (February 23 and February 28, 2023) tied to publicly reported events are externally verifiable, elevating to Level 4.

thinking: Incident disclosure - describes a real cybersecurity incident with specific dates and details.


fact: Chief Business Officer provides updates to the Audit Committee and Board

reasoning: The paragraph describes Audit Committee and Board oversight of cybersecurity risk, including how information flows upward, making it clearly Board Governance. The Chief Business Officer is a C-suite role specific to this company's governance structure (unusual for cybersecurity reporting), elevating specificity to Firm-Specific. The 'outside IT management/cybersecurity consultant' is unnamed and thus not firm-specific.

thinking:
Classify this paragraph.

Category: This is about board/committee oversight of cybersecurity - Audit Committee provides oversight, receives updates. This is Board Governance.

Specific facts:
- "Audit Committee" - generic, every company has one → not firm-specific
- "Chief Business Officer" - this is a named role, VP-level or above? CBO is a C-suite title, firm-specific
- "outside information technology management/cybersecurity consultant" - unnamed third party, not specific
- "periodic updates" - generic cadence

So we have CBO as a firm-specific fact (Level 3).


content_category: Strategy Integration

reasoning: The paragraph's central statement is a backward-looking materiality assessment ('have not materially affected us, including our business strategy, results of operations or financial condition'), which triggers SI per Rule 5. Specificity is Level 1: the negative materiality assertion is not externally verifiable, there are no domain terms passing the ERM test, no firm-specific facts, and the remainder is generic risk acknowledgment plus an Item 1A cross-reference.

thinking:
Let me analyze this paragraph.

Content: States risks haven't materially affected them, mentions they've experienced threats/incidents, cross-references Item 1A.

Category: The key statement is "such risks have not materially affected us, including our business strategy, results of operations or financial condition" — this is a backward-looking materiality assessment → SI per Rule 5.

Specificity: "have not materially affected us, including our business strategy, results of operations or financial condition" — this is a negative materiality assertion, which per the rules is NOT externally verifiable. No domain terms, no firm-specific facts, no verifiable claims.

The cross-reference to Item 1A doesn't add substantive content, and the vague reference to experiencing "threats to, or security incidents" lacks any concrete details. The negative assertion about not experiencing material cybersecurity incidents is similarly unverifiable—there are no domain-specific terms or firm-specific facts to anchor it. This lands at Level 1.


content_category: Third-Party Risk

reasoning: The paragraph centrally addresses how third-party cyber risks are managed—due diligence, contractual notification obligations, and limitations on monitoring—making TP the clear category. Despite mentioning 'Members' data' (a Peloton-specific term), the actual cybersecurity content is entirely generic: due diligence, contractual obligations, and monitoring limitations are standard language any ERM professional could write without domain expertise. No domain terms pass the ERM test, no firm-specific cybersecurity facts, and no verifiable claims.

thinking: Third-party risk management paragraph.


fact: Kroll named as the firm conducting the security maturity assessment

fact: November 2022 - specific date of security maturity assessment

fact: September 2023 - most recent tabletop exercise date

fact: Information Security Incident Response Policy - named internal policy peer reviewed by Kroll

fact: security maturity assessment

fact: penetration tests

fact: network architecture

reasoning: The paragraph describes program activities — external assessment, gap remediation, policy development, tabletop exercises — all things the cybersecurity program does, with Kroll hired to serve the company (→ RMP per Rule 3). Specificity reaches Level 4 via the named firm Kroll and specific dates (November 2022, September 2023), all externally verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes Kroll conducting a security maturity assessment, reviewing documents, working with the Century Communities Information Security Team to close gaps, implementing solutions, developing an Information Security Incident Response Policy, and conducting tabletop exercises.

Category: This is about what the cybersecurity program does - risk assessment, external assessments, incident response planning. Kroll is a third party hired to serve the company (assessor), so per Rule 3, this is RMP not TP.

Specificity: Let me list facts:
- "Kroll" - named third-party firm (verifiable)

- "November 2022" and "September 2023" - specific dates (verifiable)
- "Century Communities Information Security Team" - named team (firm-specific)
- "Information Security Incident Response Policy" - named internal program (firm-specific)
- "penetration tests" and "network architecture" - domain terms
- "tabletop exercises" - in the context of incident response planning, which gives it cybersecurity specificity, so this qualifies as ERM-relevant
- "security maturity assessment" - domain term

The presence of the named firm Kroll combined with these specific dates pushes this to Level 4.


fact: Management-level cybersecurity risk committees at Morgan Stanley

fact: Morgan Stanley named as parent firm managing cybersecurity

fact: Non-Financial Risk Committee receives escalated cybersecurity risks

fact: CIO reports on Cybersecurity Program status

fact: Head of Operational Risk reports on Cybersecurity Program status

fact: Firm Risk Committee receives cybersecurity reporting

fact: BOTC receives cybersecurity reporting

reasoning: The paragraph describes a governance chain from management-level committees up through Non-Financial Risk Committee, Firm Risk Committee, BOTC, and ultimately the Board, making it primarily about oversight structure → Board Governance. Multiple named committees (Non-Financial Risk Committee, Firm Risk Committee, BOTC) and named roles (CIO, Head of Operational Risk) provide firm-specific detail, but no externally verifiable claims push it to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes management-level cybersecurity risk committees at Morgan Stanley, escalation to Non-Financial Risk Committee, CIO and Head of Operational Risk reporting to various committees and boards. This is about governance structure - how oversight flows from committees to board.

Category: This describes a governance chain from management committees up to the board. The purpose is describing oversight structure. It mentions board-level reporting (BOTC, MS Board, Company Board) and committee escalation paths. This is primarily about how information flows to the board and oversight structure → Board Governance.

Actually, I'm confirming this is Board Governance. The paragraph traces the oversight chain from management-level cybersecurity committees through the Non-Financial Risk Committee and Firm Risk Committee up to the board, with specific roles like the CIO and Head of Operational Risk reporting through this escalation path. The named committees and firm-specific structure reinforce that this is about governance oversight.


fact: Information Security Program ("ISP") — named internal program

fact: Information Technology Board Committee ("ITBC") — named non-generic board-level committee

fact: IT Steering Committee ("ITSC") — named non-generic committee

reasoning: The paragraph describes the oversight structure for cybersecurity through two named committees (ITBC and ITSC), making it primarily about governance oversight → Board Governance. Three named, non-generic entities (ISP, ITBC, ITSC) distinguish this company's structure, elevating specificity to Firm-Specific, but no externally verifiable claims are present.

thinking:
Let me analyze this paragraph.

Category: This describes oversight structure - committees overseeing the ISP. The ITBC sounds like a board-level committee, and ITSC sounds like a management-level committee. The paragraph describes their role in managing cyber risks. This is about oversight structure → Board Governance. But wait - it mentions both a board committee and a steering committee. The primary content is about oversight structure of the program through these committees.

Per Rule 1: Board-level committees → BG. This paragraph describes the governance/oversight structure with both committees playing oversight roles. BG.

The references here are all firm-specific - the ISP is their named internal program, and both the ITBC and ITSC are non-generic committees unique to this organization. That puts this at Level 3 specificity.


fact: CIO oversees CISO (reporting line)

fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)

fact: Cyber Incident Response Teams under the CISO

fact: Information Security team under CISO

fact: Partnership with Risk and Legal departments

reasoning: The paragraph's primary content is the organizational structure of cybersecurity management—CIO-to-CISO reporting line, team responsibilities, and cross-functional partnerships—making it MR via the person-removal test (removing roles/titles leaves little substantive content). Specificity is Firm-Specific due to named roles (CIO, CISO), named teams (Cyber Incident Response Teams, Information Security team), and specific departmental partnerships (Risk and Legal), but no externally verifiable claims.

thinking:
Classify this paragraph.

The paragraph describes CIO overseeing CISO, CISO's team responsibilities, and Cyber Incident Response Teams. This is about management organization - roles, responsibilities, reporting lines.

Person-removal test: Remove CIO, CISO, team references. What remains? "Information Security is built into the Company's larger technology strategy" and "enterprise-wide information security strategy, policy, standards, architecture, and processes" and "monitoring and analyzing the Company's cybersecurity posture in partnership with Risk and Legal." Some program description remains but the paragraph is primarily about WHO does WHAT - organizational structure. The roles and reporting lines are the primary content.

Looking at the specific facts here: the CIO and CISO are named roles with a defined reporting relationship, the Cyber Incident Response Teams are a specific team structure, and there's a partnership arrangement with Risk and Legal. The domain language around cybersecurity posture and information security strategy passes the ERM test. Since there are no verifiable claims like numbers, certifications, or named individuals, this falls into Level 3 - Firm-Specific classification.