fact: Led by Chief Information Security Officer (CISO)

reasoning: The paragraph primarily describes what the cybersecurity program does — processes to assess, identify, manage, and report risks, system evaluations, security infrastructure enhancements, and business continuity. Person-removal test: removing the CISO and Board references leaves substantial program description, confirming RMP over MR or BG. Specificity is Firm-Specific due to the named CISO role; the remaining language ('processes to assess, identify, manage,' 'business continuity plans,' 'security infrastructure') is generic ERM vocabulary that fails the domain-expertise test.

thinking:
Let me analyze this paragraph.

Category: This describes the cybersecurity program - risk management, processes to assess/identify/manage risks, business continuity, security infrastructure enhancements. The CISO and Board are mentioned but in context of describing the program. Person-removal test: remove CISO and Board mentions, substantial program description remains. → RMP

Specific facts:
- CISO → firm-specific (named role)
- "IT security teams" → generic
- ERM integration mentioned
- Business continuity plans → L1

- The risk assessment and reporting processes are standard ERM language, so they're generic. CISO is the only firm-specific element here, making it Level 3.


content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the board's delegation of cybersecurity oversight to the Audit Committee, squarely answering the board governance question. No domain-specific terms (risk oversight, risk management program are generic ERM language), no firm-specific facts (Audit Committee is universal), and no verifiable claims, leaving this at Level 1.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

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

Specific facts: "Audit Committee" is generic (every company has one) → not firm-specific. No domain terms that pass ERM test. "cybersecurity risk management program" is generic.

Specificity: Level 1 - Generic Boilerplate.


content_category: None/Other

reasoning: This is a cross-reference directing readers to Item 1A Risk Factors with speculative 'may materially affect' and 'could lead to' language — no substantive cybersecurity disclosure is present. No domain terms, firm-specific facts, or verifiable claims elevate specificity above Level 1.

thinking: Cross-reference to Item 1A risk factors with speculative "could/may" language.


reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing the Board's ultimate responsibility and the Audit Committee's oversight of cybersecurity strategies, risks, and data privacy—classic Board Governance. No domain-specific security terms pass the ERM test, no firm-specific facts (Audit Committee and Board are generic governance structures every company has), and no verifiable claims, leaving this at Level 1.

thinking:
Classify this paragraph.

Category: This describes board/committee oversight of cybersecurity. The Audit Committee's role in overseeing cybersecurity. This is Board Governance.

Specificity: Let me scan for facts.
- "ERM" integration - generic
- "Board" - generic
- "Audit Committee" - every company has one, not firm-specific
- "annual ERM assessment" - generic cadence
- "Information Security" as a defined term for "data privacy and data protection" - this is just a label

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

This is Level 1 - Generic Boilerplate.


content_category: Risk Management Process

category_confidence: medium

reasoning: The paragraph opens with Board oversight context but the majority of text describes the company's general cybersecurity program approach—ERM integration, cross-functional risk management, and the goal of preserving confidentiality/security/availability—making RMP the primary category. All language is generic boilerplate that any ERM professional could write; no domain-specific terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Category: This talks about the Board's oversight of risk management and cybersecurity as part of ERM. It's a mix of BG (board oversight) and RMP (ERM integration, general approach). The first sentences describe board oversight, then it shifts to describing the company's general approach. The board mention is brief context-setting; the bulk describes the general program approach. But actually, re-reading: "The Board is actively involved in oversight" is BG. Then "cybersecurity policies...integrated into ERM" and "seeks to address cybersecurity risks through a comprehensive, cross-functional approach" is RMP.

The paragraph leans RMP overall—while the Board's involvement opens it, the bulk of the text focuses on what the program actually does rather than how oversight works. The specifics mentioned are fairly generic: the CIA triad framed as "confidentiality, security and availability," ERM integration, and cross-functional approach, along with the standard threat identification and incident response language.

No domain-specific terminology, firm-specific facts, or verifiable claims here. This reads as Level 1 boilerplate.


content_category: Strategy Integration

reasoning: The paragraph's longest and most substantive statement is the materiality conclusion ('not aware of any risks from cybersecurity threats... which have materially affected or are reasonably likely to materially affect'), which is the SEC Item 106(b)(2) assessment → SI per Rule 5. The preceding sentences describe generic outsourcing of risk management and third-party provider usage but contain no domain terminology passing the ERM test, no firm-specific facts, and no verifiable claims, leaving specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: Management works with third parties for cybersecurity risk management, uses third-party service providers, and states no material cybersecurity risks/incidents.

Category analysis:
- Third-party risk management is mentioned but it's not deeply about vendor oversight requirements
- There's a materiality assessment at the end
- The last sentence is a clear SI materiality statement ("have materially affected or are reasonably likely to materially affect")

The paragraph has three parts: (1) management works with third parties for risk identification, (2) company uses third-party service providers and seeks reliable ones, (3) materiality assessment. The materiality assessment is a clear SI statement per Rule 5.

Now I'm weighing whether the materiality conclusion is the dominant focus or just one component. The text is roughly split into thirds between third-party processes and the materiality statement itself. That final sentence directly mirrors the SEC Item 106(b)(2) language, which makes it significant disclosure, but the bulk of the paragraph discusses third-party management practices. When a paragraph spans multiple categories like this, I need to identify which question it most directly answers.

Looking at the structure: the first two sentences establish how management uses third parties to identify and assess cybersecurity risks—that's clearly risk management processes. The materiality statement is the conclusion, not the primary content. So this lands in RMP territory, though SI is definitely a close call given that explicit materiality language. The process language is too generic to carry much weight, and even by word count the materiality statement is longest. I'm settling on Strategy Integration—the specific conclusion about no material impact is what actually distinguishes this paragraph, despite the RMP elements present.

Now looking at the specificity markers: the risk management language is textbook boilerplate, the third-party reference is equally generic, and the materiality claim itself is just a negative assertion without any verifiable support or domain-specific detail. This is clearly Level 1 generic boilerplate.


reasoning: This is a cross-reference paragraph pointing to Item 1A Risk Factors for additional information about cybersecurity threats. Per Rule 5, cross-references like 'risks that may materially affect us, see Item 1A' are N/O. No substantive cybersecurity disclosure is present.


reasoning: The paragraph contains both a backward-looking materiality assessment ('have not...materially affected us') and a forward-looking SEC 106(b)(2) statement ('reasonably likely to materially affect us'), both of which are SI per Rule 5. The third sentence is a cross-reference (N/O) but SI dominates. No domain terms, firm-specific facts, or verifiable claims are present — the negative materiality assertion is not externally verifiable.

thinking:
Let me analyze this paragraph.

The paragraph has three sentences:
1. "We have not identified known risks...that have materially affected us" → backward-looking materiality assessment → SI
2. "We face certain ongoing risks...reasonably likely to materially affect us" → forward-looking SEC Item 106(b)(2) language → SI
3. Cross-reference to Item 1A → N/O

The first two sentences are materiality assessments (SI per Rule 5). The cross-reference is N/O but the dominant content is SI.

Specificity: No domain terms, no firm-specific facts, no verifiable claims.

The negative assertion about no material incidents lacks any verifiable support—it's just generic boilerplate language.


content_category: Management Role

fact: Chief Technology Officer (CTO) tasked with assessing and managing cybersecurity risks

reasoning: The paragraph describes who is responsible for cybersecurity (CTO, IT Director) and their qualifications, making it squarely Management Role. The CTO is a VP+-level role in a cybersecurity context, qualifying as firm-specific. The IT Director title lacks a security qualifier and doesn't meet the firm-specific threshold per the rules. No verifiable claims (no specific years, certifications, or named entities) prevent elevation to Level 4.

thinking:
Classify this paragraph.

Content: About CTO and IT Director roles, responsibilities, and qualifications.

Category: Management Role - describes who is responsible (CTO, IT Director) and their qualifications.

Specific facts:
- CTO (named_role) - firm-specific VP+ role
- IT Director (named_role) - "Director of IT" without security qualifier... but wait, the text says "IT Director" which is essentially "Director of IT" - per rules, "Director of IT" without security qualifier is NOT firm-specific.

Hmm, but CTO is VP+ level, so that's firm-specific.

The IT Director role mentions IT and Information Security expertise, but the title itself doesn't include a security qualifier, so it doesn't meet the firm-specific criteria. The CTO is clearly VP+ level and firm-specific, making this a Level 3 classification overall.


reasoning: The paragraph describes the information flow from the Global Director of IT to CEO/CFO to Audit Committee to Board, which is an oversight structure description → Board Governance. 'Global Director of IT' is a Director-level title without a security qualifier (NOT firm-specific per rules), CEO/CFO/Audit Committee are generic roles, 'weekly briefings' is a generic cadence, and terms like 'cybersecurity risks,' 'cybersecurity systems testing,' and 'risk management process' are standard ERM language that don't pass the domain expertise test.

thinking:
Let me analyze this paragraph.

Category: This describes how information flows from the Global Director of IT → CEO/CFO → Audit Committee → Board. It's about oversight structure and information flow to the board. This is Board Governance.

Specific facts:
- "Global Director of IT" - this is a Director-level title but without a security qualifier (it's "IT" not "IT Security"), so per rules NOT firm-specific
- "weekly briefings" - generic cadence
- "CEO and CFO" - generic roles
- "audit committee" - generic committee

Wait, let me reconsider.

The "Global Director of IT" title still lacks a security qualifier, so it doesn't meet the firm-specific threshold. Looking at the domain language—"cybersecurity risks," "cybersecurity incidents," "cybersecurity systems testing," "third-party activities," "risk management process," "cybersecurity policies and processes"—these are all standard ERM terminology without anything distinctive. Even "cybersecurity systems testing" is too generic to differentiate. This is Level 1 - Generic Boilerplate.


content_category: Third-Party Risk

reasoning: The paragraph's central topic is managing cybersecurity risks from third-party vendors—reviewing their internal controls and assessing their procedures—making TP the best fit. The language is entirely generic ('procedures designed to identify and mitigate,' 'reviewing the internal controls,' 'assess their procedures') with no domain terminology, firm-specific facts, or verifiable claims, keeping it at Level 1.

thinking:
Third-party risk management is the central topic here.

Specificity: "reviewing the internal controls of certain third-party service providers" - this is generic process language. No domain terms, no firm-specific facts, no verifiable claims.

Level 1.


fact: Named hotel manager 'Our Town' as a third party they rely on for cybersecurity risk management

reasoning: The paragraph centrally addresses how cybersecurity risks of third parties (hotel manager Our Town and franchisors) are managed, including reliance on them and insurance coverage, making it Third-Party Risk. The named entity 'Our Town' is a firm-specific fact elevating specificity to Level 3.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party cybersecurity risk - hotel manager (Our Town) and franchisors. They don't control those systems, rely on them to manage their own cyber risk, and the hotel manager has cybersecurity insurance.

Category: Third-Party Risk - central topic is managing cyber risks of third parties (hotel manager, franchisors).

Specific facts:
- "Our Town" - named third party (firm-specific)
- "cybersecurity insurance coverage" - could be domain term but insurance is pretty generic
- Named entity "Our Town" as hotel manager - firm-specific

- The reference to "Our Town" as a specific named entity pushes this into firm-specific territory rather than generic discussion.


reasoning: The paragraph states a backward-looking and forward-looking materiality conclusion ('have not materially affected or are reasonably likely to materially affect us'), which is the SEC Item 106(b)(2) assessment → Strategy Integration. No domain terms, firm-specific facts, or verifiable claims are present; the negative self-assertion about no material impact is not externally verifiable, and the cross-reference to Item 1A is boilerplate.

thinking: SI materiality assessment + cross-reference to Item 1A.


fact: cyber insurance coverage secured

specificity_confidence: medium

reasoning: The paragraph opens with a backward-looking materiality assessment ('have not... materially affected') and a forward-looking one ('reasonably likely to materially affect'), both triggering SI under Rule 5. It also mentions securing cyber insurance, a firm-specific fact about this company's posture. The cross-reference to Item 1A is ancillary. Cyber insurance is a firm-specific fact (distinguishes this company's posture) but not externally verifiable as stated, so Level 3.

thinking: Strategy Integration - materiality assessment plus cybersecurity insurance.


content_category: Incident Disclosure

fact: ransomware attack

fact: forensic analysis

fact: persistence mechanisms

fact: compromised exchange on-premises accounts (Microsoft Exchange)

fact: incident occurred early 2019

reasoning: The paragraph describes a real ransomware attack—its discovery, investigation, recovery, and forensic analysis—making it clearly Incident Disclosure. Specificity reaches Level 3 due to the firm-specific reference to 'exchange on-premises accounts' (Microsoft Exchange infrastructure), which reveals this company's specific IT environment; 'early 2019' is a real but soft timeframe insufficient for Level 4, and no named third-party firm or hard verifiable numbers are provided.

thinking:
Incident disclosure about a real ransomware attack in 2019.

Facts: "early 2019" (specific date), "ransomware attack" (domain term), "no evidence of malware, persistence mechanisms" (domain terms), "professional cybersecurity investigation firm" (generic), "forensic analysis" (domain term), "financial impact was not material" (materiality assessment but within incident frame), "within weeks" (soft timeframe).

Category: This describes a real incident - timeline, what happened, response, investigation. ID vs SI: the dominant frame is what happened. The materiality statement is subordinate. → Incident Disclosure.

The specificity here is mixed—"early 2019" gives a real timeframe but it's vague, and while domain terms like "ransomware" and "forensic analysis" are present, there are no named firms or verifiable claims beyond those. But then "compromised exchange on-premises accounts" references Microsoft Exchange specifically, which is a named system and moves this toward firm-specific detail at Level 3. "Early 2019" is too vague to count as a specific date—it's more like a soft timeframe rather than the kind of precise reference the guidelines require. Without hard numbers, named firms, certifications, or concrete dates, this falls to Level 3 based on "Exchange on-premises" being a named Microsoft system tied to firm-specific infrastructure.


fact: Fidelity oversees vendor cybersecurity on behalf of the Trust

reasoning: The paragraph's central topic is how third-party/vendor cybersecurity risks are managed through a vendor oversight program, making it Third-Party Risk. Naming Fidelity as the specific entity managing vendor oversight on behalf of the Trust is a firm-specific fact, but the rest of the paragraph (periodic reviews, risk-based frequency) is generic process description.

thinking:
Classify this paragraph.

This is about third-party/vendor cybersecurity oversight. The central topic is how third-party cyber risks are managed through Fidelity's vendor management program.

Category: Third-Party Risk - vendor oversight is the central topic.

Specific facts:
- "vendor management program" - generic
- "periodic reviews of the cybersecurity controls" - generic process
- "Fidelity" oversees on behalf of the Trust - named firm? Fidelity is the parent/manager, this is firm-specific
- Risk-based review frequency based on vendor criticality - generic process description

- The key distinguishing element is that Fidelity is explicitly named as the entity performing vendor oversight for the Trust, which makes this firm-specific rather than just a generic description of vendor management practices.

Specificity: Firm-Specific (Level 3)


reasoning: The paragraph states a materiality conclusion ('not aware of risks...that have materially affected or are reasonably likely to materially affect the Company, including its business strategy, results of operations or financial condition'), which is the SEC Item 106(b)(2) assessment → SI. No domain terms, firm-specific facts, or verifiable claims are present; the negative assertion about no material incidents is not externally verifiable.

thinking: SI materiality assessment paragraph.


fact: Lead IT Systems Specialist role on incident team

fact: Specific cross-functional team composition: CFO, CEO, Legal/Compliance, Corporate Security, Internal Audit, Human Resources, Directors of Banking and Mortgage, Corporate Communications

reasoning: The paragraph describes which roles and departments may join incident response teams, making it about team composition and organizational structure (MR). The person-removal test leaves very little substance. The specific departmental composition ('Directors of Banking and Mortgage,' 'Corporate Security') distinguishes this company's organizational structure, reaching Firm-Specific.

thinking:
Classifying this paragraph about team composition for incident response.

This describes who may be involved in incident response teams - it's about organizational structure and team composition for cybersecurity management. The paragraph lists various roles that could be pulled into investigations.

Category: This is about team composition for incident response. It mentions a "Lead IT Systems Specialist" and cross-functional team members. The person-removal test: remove the roles and titles, what remains? "Depending upon the type of incident or event, representatives from other areas of the Company may be included on any of these teams from time to time for a particular investigation/response." That's very thin. But the content is about WHO participates, not WHAT the program does.

The roles mentioned are mostly generic titles like CFO and CEO, with "Lead IT Systems Specialist" being a non-security-specific position below VP level. The departments referenced - Legal/Compliance, Corporate Security, Internal Audit, Human Resources, and Directors of Banking and Mortgage - reveal some organizational structure, though most are standard corporate functions rather than firm-specific details.

Wait, actually the specific list of departments itself is firm-specific, and "Directors of Banking and Mortgage" does indicate the company's business lines. So this qualifies as both MR and firm-specific based on the specific team composition breakdown.


fact: network security

fact: data privacy

fact: Named internal program: Cybersecurity Program

fact: VP of IT reports directly to the CEO

reasoning: The paragraph centers on who manages cybersecurity (VP of IT), their responsibilities, qualifications, and reporting lines; the person-removal test collapses the paragraph, confirming MR. The VP-level title 'Vice President of Information Systems and Architecture' is firm-specific, elevating to Level 3, but no named certifications or verifiable quantities keep it below Level 4.

thinking:
Let me analyze this paragraph.

Category: This is about the VP of IT's role, responsibilities, team, qualifications, and reporting lines. Person-removal test: remove the VP of IT, their qualifications, reporting lines → little remains. This is MR.

Specific facts:
- "Vice President of Information Systems and Architecture (VP of IT)" — named role at VP level → firm-specific
- "reports directly to the Company's Chief Executive Officer" — reporting line, but CEO is generic
- "Cybersecurity Program" — named internal program

- "data privacy and network security" — network security is a domain term
- "holds relevant and applicable certifications" — vague, not verifiable (no specific certs named)

The VP of IT role itself is firm-specific, while network security is a standard domain term. The certification requirement lacks specificity since no particular credentials are mentioned. Overall, this lands at Level 3.


fact: penetration testing

reasoning: The paragraph primarily answers what the cybersecurity program does: risk assessment, policy development, third-party evaluations, and framework adoption — all program activities (RMP). Third parties are mentioned as serving the company (assessors, pen testers), not as vendors being overseen. Penetration testing is the only term that passes the ERM test; the rest (risk assessment, policies, independent audits, consulting) is generic language any ERM professional would use.

thinking:
Let me analyze this paragraph.

Content: Discusses regulatory compliance, working with cybersecurity consultant, risk assessment, policies, frameworks, third-party evaluations including penetration testing, independent audits, consulting. This is primarily about what the cybersecurity program does - risk management processes.

Category: RMP - describes program activities (risk assessment, policies, penetration testing, audits, frameworks). Third parties are mentioned but as part of the internal program (Rule 3 - third parties hired to serve the company → RMP).

Specificity: Let me scan for facts:
- "penetration testing" - domain term (passes ERM test)

- "independent audits" - generic
- "cybersecurity consultant" - unnamed, not firm-specific
- "Federal Drug Administration" - not cybersecurity specific
- "third party frameworks" - unnamed, generic

Domain terms: penetration testing passes ERM test. The rest is fairly generic. Level 2 - Domain-Adapted due to penetration testing.


fact: ransomware attacks

fact: phishing attacks

fact: insider threats

reasoning: The paragraph contains a backward-looking materiality assessment ('none of which...have had a material impact on its business information systems or operations'), which is SI per Rule 5, alongside RMP-like content about monitoring and disaster recovery. The materiality conclusion is the paragraph's key disclosure point. Specificity reaches Level 2 via specific cyber threat types (ransomware, phishing, insider threats) that pass the ERM test, but no firm-specific or verifiable facts elevate it further—the negative materiality assertion is not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: Discusses material cybersecurity risks (ransomware, phishing, insider threats, third-party attacks), mentions monitoring and adjusting strategy, states no material impact from incidents, mentions disaster recovery process, and cross-references Item 1A.

Category: The paragraph contains a materiality assessment ("none of which...have had a material impact on its business information systems or operations") → SI per Rule 5. But let me check - the paragraph also discusses risk types and monitoring (RMP-like) and cross-references (N/O-like). The materiality conclusion is a key element.

The materiality statement is the core of this paragraph—it's a backward-looking SI assessment per Rule 5, even though the paragraph weaves in risk types, monitoring practices, and disaster recovery details. The SI classification hinges on that materiality conclusion about past incidents having no material impact. about acknowledging risks and stating they haven't been material - this feels like SI.

But there's also substantial RMP content (monitoring systems, disaster recovery process exercised annually). Hmm, the "most text" test - I think it's fairly split. The materiality conclusion is a clear SI marker per Rule 5. I'll go with SI.

Wait, let me reconsider. The paragraph is really a hodgepodge. Let me count sentences:
1. Risk acknowledgment (ransomware, phishing, insider threats, third-party attacks)
2. Monitor systems and adjust strategy
3. Systems have been subject to incidents, none material impact
4. Can't guarantee, but robust disaster recovery exercised annually
5. Cross-reference to Item 1A

The materiality assessment in sentence 3 is a clear SI marker. Sentences 1-2 are RMP-ish. Sentence 4 is RMP, and sentence 5 is N/O. It's close between RMP and SI, but the materiality statement is the key disclosure point here, so I'll go SI with moderate confidence.

Looking at specificity: ransomware, phishing, insider threats, and third-party attacks are domain terms that a non-security professional wouldn't naturally enumerate together. The disaster recovery process exercised annually is generic cadence language. The negative self-assertion about material impact isn't verifiable per the rules, which reinforces the SI classification.


fact: Breach Response Team (named internal team)

reasoning: The paragraph describes program activities (tabletop exercises, incident simulation, risk analysis) rather than roles or qualifications, making it RMP. The named 'Breach Response Team' is a firm-specific identifier that elevates specificity to Level 3, while the remaining language (tabletop exercises, detection/mitigation/remediation) is generic process description.

thinking:
Classify this paragraph.

Content: Describes tabletop exercises conducted by the "Breach Response Team" - simulating incident responses, analyzing risks, developing strategies, discussing cybersecurity topics.

Category: This is about what the cybersecurity program does (activities) - RMP. The Breach Response Team is the subject but the content is about activities (tabletop exercises, simulations).

Specific facts:
- "Breach Response Team" - named team, firm-specific
- "tabletop exercises" - commonly confused list says "tabletop exercises (without cybersecurity qualifier)" stays L1, but here they explicitly say "tabletop exercises to simulate responses to cybersecurity incidents" - that's with a cybersecurity qualifier...

Even though "tabletop exercises" is standard ERM terminology, the cybersecurity context here is just the filing context, so I'm keeping it L1. Same with "detection, mitigation and remediation strategies" - that's generic process language. The "Breach Response Team" itself is the firm-specific element with a distinguishing identifier, making that L3.


fact: Chief Technology and Digital Officer leads cybersecurity efforts

fact: Senior Vice President, Technology leads cybersecurity efforts

fact: over 10 years of networking and IT management/executive experience (CTDO)

type: quantified

fact: over 25 years of networking and IT management/executive experience (SVP Technology)

fact: Cybersecurity Committee

fact: Committee comprised of accounting, finance, legal, internal audit, and information technology representatives

reasoning: The paragraph's primary question is 'How is management organized to handle cybersecurity?' — it introduces leadership roles, their qualifications, the Cybersecurity Committee's composition, and then its charter. While committee activities are listed, they define the committee's organizational scope rather than describing program operations in detail, favoring MR. Specificity reaches Level 4 due to the verifiable lower-bound experience claims ('over 10' and 'over 25 years') tied to specific officer roles.

thinking:
Let me analyze this paragraph.

Category: This describes management roles (Chief Technology and Digital Officer, SVP Technology, Cybersecurity Committee) with their qualifications, team composition, and what the committee does. The paragraph covers both MR and RMP elements. Let me apply the person-removal test.

Remove person-specific content (names, titles, qualifications, experience, reporting lines, team composition, committee membership): What remains? "cyber risk assessments, monitor applicable key risk indicators, review cybersecurity training procedures, establish cybersecurity policies and procedures, and implement enhancements to our cybersecurity infrastructure...

The committee meets regularly and ensures senior management and the Board receive the information they need to oversee cybersecurity risks and handle incident escalation. So this is a mixed paragraph—the opening focuses on organizational structure and roles, while the committee section blends its composition with its charter and operational activities.

Let me think through the categorization more carefully. The paragraph's core question is really about how management is organized to handle cybersecurity—it introduces the leadership, their qualifications, the committee structure, and then lays out what that committee does. Even though there's substantial program content about risk assessments and monitoring, the framing is fundamentally about the organizational setup. The person-removal test is tricky here because removing titles and qualifications still leaves program description, but that program description is really the committee's charter—it's defining the committee's role, not describing a standalone program. I'm leaning toward MR because the paragraph's primary purpose is answering "how is management structured," with the activities serving as the committee's defined responsibilities rather than a separate program.

For specificity, I'm seeing named roles at the VP+ and SVP level, which are L3, a named committee that's L3, and specific team composition details that are L3. The years of experience are quantified and verifiable, so that's L4. Monthly cadence is mentioned but isn't firm enough to be a strong specificity marker.

Looking at the remaining items, most of them are generic terms—cyber risk assessments, cybersecurity training procedures, policies and procedures, and infrastructure all lack the concrete detail needed for higher specificity levels. Key risk indicators is a domain term that ERM professionals use, so it doesn't stand out as particularly specific either.


reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing the Audit Committee's review scope and briefing cadence — classic Board Governance. Two VP-level roles with security-relevant portfolios (VP Information Security and Privacy; SVP Chief Strategy and Digital Officer) elevate specificity to Firm-Specific.

thinking:
Classify this paragraph.

Category: This describes board-level oversight (Audit Committee) of cybersecurity. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance. Even though VP and SVP roles are mentioned, they're described in context of briefing the board committee.

Specific facts:
- "Audit Committee" — generic, every company has one → not firm-specific
- "Vice President, Information Security and Privacy" — VP-level with security qualifier → firm-specific
- "Senior Vice President, Chief Strategy and Digital Officer" — SVP level → firm-specific

- "quarterly" briefings — generic cadence → not firm-specific
- Reviews cover "cybersecurity risks, incidents, audits, assessments, crisis readiness, awareness activities and compliance" — standard oversight topics, not firm-specific

Specificity: Level 3 (firm-specific due to the named roles at VP+ level)


reasoning: The paragraph describes how the Audit Committee (a board-level committee) oversees cybersecurity through reviewing internal controls, data security policies, and receiving management reports — squarely answering 'how does the board oversee cybersecurity?' All terminology ('internal controls,' 'risk management,' 'data security and privacy policies,' 'internal audit department') is standard ERM language with no cybersecurity domain expertise, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Category: Board Governance - describes how the Audit Committee (board-level) oversees cybersecurity, reviews policies, and receives reports from management. This is about oversight structure.

Specificity: Let me scan for facts.
- "Audit Committee" - generic, every company has one → not firm-specific
- "internal audit department" - generic
- "cybersecurity/data privacy risks" - generic topic reference
- No domain terms that pass the ERM test - "internal controls," "data security and privacy policies," "risk management" are all generic ERM language
- No named roles at VP+ level, no specific frameworks, no verifiable claims

- This lands at Level 1 - Generic Boilerplate.


reasoning: The paragraph's primary statement is a materiality assessment ('have not identified any cybersecurity incidents or threats that have materially affected us or are reasonably likely to materially affect us'), which is the SEC Item 106(b)(2) backward/forward-looking conclusion → SI per Rule 5. No domain terms passing the ERM test, no firm-specific facts, and the negative assertion about no material incidents is not externally verifiable, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: States no material incidents, mentions time-to-time threats, cross-references Risk Factors.

Category: The first sentence is a materiality assessment - "have not identified any cybersecurity incidents or threats that have materially affected us or are reasonably likely to materially affect us." This is the SEC Item 106(b)(2) language → SI per Rule 5.

Specificity: "Have not identified any cybersecurity incidents or threats that have materially affected us or are reasonably likely to materially affect us" → This is a negative self-assertion, NOT externally verifiable. No domain terms, no firm-specific facts, no verifiable claims.

The cross-reference to Risk Factors doesn't add substantive content, and there's no domain terminology that would satisfy the ERM test. This lands at Level 1.


reasoning: This paragraph is a purely definitional/legal cross-reference establishing that SEC regulatory definitions apply, with no substantive cybersecurity disclosure. No specific facts of any kind are present.

thinking: Definitional/legal cross-reference paragraph with no substantive cybersecurity disclosure.


reasoning: The paragraph describes the governance oversight chain (Board → Audit Committee → General Counsel) for cybersecurity, which is primarily about how the board oversees cybersecurity risk, making it Board Governance per Rule 1. All entities mentioned (Board, Audit Committee, General Counsel) are generic governance roles present at every public company, and no domain-specific terms, firm-specific facts, or verifiable claims are present, keeping specificity at Level 1.

thinking:
Classify this paragraph.

Content: Board assigned oversight to Audit Committee. Audit Committee reviews with management. General Counsel has primary responsibility.

Category: This describes the governance chain - Board → Audit Committee → General Counsel. The primary question answered is "How does the board oversee cybersecurity?" with some management role content. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. The General Counsel mention is part of the oversight chain description. BG.

Specific facts:
- "Audit Committee" — every company has one, NOT firm-specific

- "General Counsel" — generic governance role, NOT firm-specific
- No domain terms that pass ERM test
- No verifiable claims

This is generic oversight language with no firm-specific details or substantive claims. Level 1.


reasoning: The paragraph traces the governance chain from CFO → Audit Committee → Board Chairman, with the primary purpose being to describe the oversight structure for cybersecurity risk; per Rule 1, this defaults to BG. All roles mentioned (CFO, Audit Committee, independent directors, Chairman of the Board) are generic governance roles present at every public company, no domain-specific terminology passes the ERM test, and no firm-specific or verifiable facts are present, leaving this at Level 1.

thinking:
Let me analyze this paragraph.

Category: This describes both management role (CFO responsible for cybersecurity) and board governance (Audit Committee oversight). The paragraph covers: CFO's responsibility, what he does (develops strategies, implements controls), reporting to Audit Committee, Audit Committee's role, and reporting chain to Board. The governance chain from CFO → Audit Committee → Board is the primary structure. The purpose is describing the oversight structure. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure.

Now I'm checking the specificity of the language used. The CFO title, Audit Committee structure, annual review cadence, and independent director composition are all standard governance practices that don't distinguish this company from others. The references to outside consultants and internal audit functions are similarly generic without firm-specific details.


reasoning: The paragraph primarily answers how the board oversees cybersecurity — describing the Audit Committee's role, reporting flows from management to the committee and full Board, and the independent cybersecurity advisor's annual report, all placing it squarely in Board Governance. Specificity reaches Level 2 via domain terms like 'information security audits' and 'information security training and awareness program,' which pass the ERM test, but the Director of Global Information Systems title lacks a security qualifier for Level 3, and unnamed entities (independent cybersecurity advisor) are not firm-specific per rules.

thinking:
Let me analyze this paragraph.

Category: This describes board/committee oversight of cybersecurity. The Audit Committee oversees information security programs, receives reports, the full Board gets updates. This is Board Governance.

Specific facts:
- "Director of Global Information Systems" - named role, but is this VP-level or above? No, it's a Director-level title without a security qualifier (it's "Information Systems" not "Information Security"). Per rules, Director-level needs a security qualifier. Hmm, but the person "manages information security training and awareness program" - the title itself is "Director of Global Information Systems" which doesn't have an explicit security qualifier. Not firm-specific.

- The title "Director of Global Information Systems" lacks the security qualifier the rules require—it's more like "Director of IT" than "Director of Information Security," so it doesn't count as firm-specific.
- "independent cybersecurity advisor" is unnamed and not firm-specific
- "annual third-party and internal information security audits" and "information security training and awareness program" are domain concepts, though I'm wondering if these are specialized enough to qualify as firm-specific terminology. the rules more carefully. "Director of Global Information Systems" lacks the security qualifier, so it doesn't cross into firm-specific territory. The domain-adapted language around security audits and training programs is the main signal here, so I'm settling on Level 2.


reasoning: The paragraph focuses on management's responsibility, qualifications (education, work experience), and how they are informed by their teams — all about WHO is responsible and what qualifies them, making it MR. No named roles, no domain-specific terms passing the ERM test, no firm-specific or verifiable facts — everything is generic ("relevant degrees," "prior work experience," "prevention, detection, mitigation and remediation").

thinking:
Classify this paragraph.

Category: This describes management's responsibility for cybersecurity programs, their expertise, and how they're informed. Person-removal test: remove expertise/qualifications → "cybersecurity programs... prevention, detection, mitigation and remediation of cybersecurity incidents" — some program description remains but it's thin. The primary focus is on management's role, qualifications, and how they're informed. → Management Role.

Specificity: No named roles (just "management"), no specific titles, no named individuals. "relevant degrees" and "prior work experience" are generic. "prevention, detection, mitigation and remediation" — this is standard language.

There's nothing here that would trigger the ERM test, no domain-specific terminology, and no facts unique to the firm itself. This is generic boilerplate.


reasoning: The first sentence is a backward-looking materiality assessment ('have not identified any cybersecurity threats that are reasonably anticipated to have a material effect on our business strategy, results of operations or financial condition'), which maps directly to Strategy Integration per Rule 5. The remainder is generic forward-looking language. 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:
Materiality assessment + forward-looking commitment.

The first sentence is a backward-looking materiality conclusion → SI per Rule 5.

Specific facts: "have not identified any cybersecurity threats that are reasonably anticipated to have a material effect on our business strategy, results of operations or financial condition" — this is a materiality assessment → SI. But is it a verifiable fact? No — negative self-assertion per the rules.

No domain terms, no firm-specific facts, no verifiable claims.

This lands at Level 1 — the lowest disclosure quality tier.


fact: In February 2024, the Board delegated cybersecurity oversight to its Audit Committee

fact: Interim Chief Financial Officer

fact: Chief Legal Officer

reasoning: The paragraph describes how the Board and Audit Committee oversee cybersecurity risk, including delegation, reporting lines, and briefing cadence — squarely Board Governance. The specific date 'February 2024' for the delegation action is a verifiable fact, elevating to Level 4; the Interim CFO and Chief Legal Officer roles are firm-specific but not security-qualified VP+ titles (borderline), though the date alone suffices for QV.

thinking:
Classify this paragraph.

Category: Board Governance - describes board/committee oversight structure, delegation, briefing flow.

Specific facts:
- "February 2024" - specific date → verifiable
- "Audit Committee" - generic, every company has one → not firm-specific
- "Interim Chief Financial Officer" - named role but CFO is generic... however "Interim CFO" is a bit specific
- "Chief Legal Officer" - generic executive role

Wait, "Interim Chief Financial Officer" - this is a generic role. "Chief Legal Officer" is also generic. These are not VP-level security roles.

The specific date "February 2024" tied to this governance action makes it verifiable, so this lands at Level 4.


reasoning: The paragraph's central purpose is assessing whether cybersecurity has materially affected the company's business, financial condition, or operations, with multiple backward-looking and forward-looking materiality conclusions ('none...have resulted in a material impact,' 'do not believe cybersecurity threats are reasonably likely to affect us'). Despite the length, it contains no domain terminology beyond generic language, no firm-specific facts (no named roles, committees, or programs), and no verifiable claims — the negative materiality assertions are self-reported and not externally verifiable, and the cross-reference to Item 1A is boilerplate.

thinking: Strategy Integration - materiality assessment is the central theme.


reasoning: The paragraph states a backward-looking materiality conclusion ('not reasonably likely to materially affect... business strategy, results of operations or financial condition'), which is the SEC Item 106(b)(2) assessment → SI per Rule 5. The remainder is a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims are present — the materiality language is a standard negative assertion, not externally verifiable.

thinking: Materiality assessment + cross-reference.


fact: Security Governance Council (SGC) – named management-level committee

fact: SGC is chaired by the CISO

fact: SGC reports to CEO and Audit Committee

fact: Members from Operations, Information Technology, Finance, Internal Audit, Legal, Human Resources and Organizational Development, and Risk Management

fact: SGC meets on a quarterly basis

reasoning: The paragraph primarily describes the structure, membership, and reporting lines of the Security Governance Council—a management-level committee—making it MR per Rule 1. Specificity is Level 3 due to the named non-generic committee (SGC), the CISO chairing it, and the specific departmental composition, but no externally verifiable quantified claims push it to Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes the Security Governance Council (SGC) - a management-level committee. It covers its composition, membership, chair, meeting frequency, and mission. By Rule 1, management-level committees → MR if about structure/membership. The primary content is about who sits on this committee and how it's organized. MR.

Specific facts:
- Security Governance Council (SGC) - named committee → firm-specific
- CISO chairs the SGC → named role
- Reports to CEO and Audit Committee - CEO/Audit Committee are generic but the reporting structure is organizational
- Specific departments listed: Operations, IT, Finance, Internal Audit, Legal, HR and Organizational Development, Risk Management → specific team composition

- Quarterly meeting cadence and Paychex reference confirm this is firm-specific governance structure with no quantifiable claims. Level 3.


reasoning: The paragraph's central purpose is a materiality assessment: no breaches occurred and no cybersecurity risks are 'reasonably likely to have a material effect on our results of operations or financial condition,' which is the SEC Item 106(b)(2) forward-looking materiality language → SI. No domain terms pass the ERM test, the negative breach assertion is not externally verifiable, and 'year ended September 30, 2024' is a reporting period rather than a cybersecurity fact, leaving specificity at Level 1.

thinking:
Let me analyze this paragraph.

The paragraph states no breaches occurred, then hedges with generic risk language, and concludes with a materiality assessment.

Category: The key sentence is "we believe there are currently no risks from any potential cybersecurity threat or cybersecurity incident that are reasonably likely to have a material effect on our results of operations or financial condition" — this is a materiality assessment (SI per Rule 5).

"There have not been any breaches" — negative assertion about incidents, but per Rule 5 this is SI (backward-looking materiality-adjacent).

Actually, the paragraph has two parts: (1) no breaches statement, (2) materiality assessment.

The materiality assessment invokes SEC 106(b)(2) language, which triggers SI classification. The "no breaches" claim is just a negative self-assertion without verification, and the reporting period reference doesn't add cybersecurity substance. Since there are no domain-specific terms that would satisfy the ERM test, this lands at Level 1 specificity.


fact: Chief Information Officer (CIO) who also serves as Chief Information Technology Architect & Chief Information Security Officer (CISO)

fact: Written escalation protocols for cybersecurity incidents

reasoning: The paragraph describes how a board-level Committee receives cybersecurity reports, briefings, and incident escalations from management, and reports to the full Board — classic board oversight structure → Board Governance. The combined CIO/CISO/Chief Information Technology Architect role is a firm-specific fact that elevates specificity to Level 3.

thinking:
Classify this paragraph.

This describes how the Committee (board-level) receives reports, briefings, and updates about cybersecurity from management. It's about board oversight structure and information flow to the board → Board Governance.

Specific facts:
- "quarterly reports" - generic cadence
- "at least annually, a detailed briefing" - generic cadence
- CIO who also serves as CISO - named roles, firm-specific
- "Chief Information Technology Architect" - unique combined title, firm-specific
- "written escalation protocols" - domain term? Not really, ERM professionals use this too
- The combined role CIO/CISO is firm-specific (Level 3)

- No verifiable facts like specific numbers, dates, certifications, or named firms
- Firm-Specific (Level 3) classification due to the named CISO/CIO role


reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing Board and Audit Committee roles in cyber risk oversight. All language is generic ERM terminology (risk identification, mitigation strategy, industry standards) with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Category: Primarily about board/committee oversight of cybersecurity. The Board oversees cyber risk management, Audit Committee reviews financial reporting of cyber risks. Last sentence about investing in security infrastructure is SI-adjacent but minor. → Board Governance.

Specific facts:
- "Audit Committee" — generic, every company has one → not firm-specific
- "cyber risk management program" — generic
- "risk identification, mitigation strategy" — generic ERM language
- "security infrastructure" — borderline, but generic
- "industry standards for cybersecurity" — no specific standard named

- This reads like standard boilerplate with no domain-specific terminology, firm-specific details, or verifiable claims that would elevate it beyond Level 1.


fact: penetration tests

reasoning: Applying the person-removal test, removing 'Management' leaves substantive program activities (preparing policies, testing response plans, engaging vendors for pen tests), so this is RMP rather than MR. 'Penetration tests' is a domain-specific security term passing the ERM test, elevating to Level 2; no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes management's involvement in cybersecurity. It talks about what management does - overseeing policies, testing incident response plans, engaging vendors for pen tests, participating in incident response. Using the person-removal test: remove "Management" references, and we still have "preparation of cybersecurity policies and procedures, testing of incident response plans, engagement of vendors to conduct penetration tests, incident response efforts." That's a substantive program description. But the paragraph's primary framing is about management's role/involvement. Actually, the grammatical subject is "Management" throughout, but the content describes program activities. Per Rule 2, "A paragraph where a named officer is the grammatical subject but content describes what the PROGRAM does → RMP." But wait - this is about management's role in overseeing and participating.

When I strip away the role language and focus on what actually remains, there's clearly substantive program content here - the policies, testing procedures, vendor engagement, and incident response activities all stand on their own. That pushes this toward RMP rather than MR. Looking at the specificity, "penetration tests" is a clear domain term that passes the test, though "incident response plans" and "incident response team" are closer to the line.


reasoning: The paragraph answers 'how does the board oversee cybersecurity?' — describing the Board's responsibility, expertise areas, strategic review, and resource allocation, all squarely Board Governance. No domain-specific cybersecurity terms pass the ERM test ("cybersecurity program," "cybersecurity threats" are generic), no firm-specific facts ("the Board" is universal), and no verifiable claims, leaving this at Level 1.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity - Board responsibility, expertise, review of strategic direction, resource allocation. This is Board Governance.

Specific facts:
- Lists board expertise areas but these are generic (every board claims diverse expertise)
- "budget are allocated" - mentions budget but no specifics
- No named roles above generic "Board"
- No domain terms that pass ERM test - "cybersecurity program", "cybersecurity threats" are generic

This is generic board oversight language. Level 1.


fact: Senior Vice President and Chief Information Officer (CIO)

fact: CIO has over 25 years of IT Risk Management experience

fact: CIO's cybersecurity team has more than 30 years of collective information and product security experience

fact: Team includes professionals with cybersecurity degrees and multiple cybersecurity-related certifications

reasoning: The paragraph primarily answers how management is organized for cybersecurity — the CIO's role, qualifications, team composition, and reporting lines — making it MR. Two lower-bound quantified claims ('over 25 years' and 'more than 30 years') are verifiable thresholds, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes management's organizational role - the CIO, their qualifications, team composition, and reporting lines. The person-removal test: remove SVP/CIO, 25 years experience, team composition details - what remains? "manage cybersecurity risks", "enterprise-wide cybersecurity strategy, policy, standards, architecture, and processes", "periodic reports", "updates on cyber risks and threats, status of projects, assessments, emerging threats", "regularly evaluated and reported on." There's some program description but the primary focus is on WHO manages cybersecurity (CIO, their team) and their qualifications.

The core question this answers is how management is organized to handle cybersecurity - that's the management role category. Looking at the specifics, I see named positions like Senior Vice President and Chief Information Officer, quantified experience metrics like 25 years in IT Risk Management and 30 years of collective security experience, plus domain-specific credentials in cybersecurity degrees. These details are firm-specific and verifiable.

I notice the certifications are mentioned but not named explicitly, which is less specific than the other claims. The experience figures are lower bounds, making them Level 4 claims in terms of specificity.


reasoning: This is a cross-reference directing readers to Item 1A Risk Factors, with no substantive cybersecurity disclosure. Per Rule 5, 'risks that may materially affect us, see Item 1A' is a cross-reference → N/O. No specific facts elevate specificity.

thinking: Cross-reference to risk factors section.


reasoning: This is a closing aspirational statement about minimizing breach likelihood and maintaining stakeholder trust, with no substantive cybersecurity disclosure. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: Closing statement, no substantive content.


reasoning: This paragraph describes hypothetical risks of IT system damage and cyber-attacks, uses speculative 'could' language rather than materiality assessments, and cross-references Item 1A Risk Factors — no substantive cybersecurity measures or program details are disclosed. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: This paragraph discusses hypothetical risks and consequences of cybersecurity incidents, with a cross-reference to Item 1A Risk Factors. It doesn't describe any actual program, process, governance, or incident. The materiality language is speculative ("could materially harm") not an assessment.


reasoning: This paragraph 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. This is a pure cross-reference paragraph.


fact: NIST CSF

type: framework

fact: HIPAA

fact: SOC 2 Type II

fact: SOX ITGC (Sarbanes-Oxley IT General Controls)

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

reasoning: The paragraph describes the company's cybersecurity risk management program and the frameworks it references, directly answering 'what does the program do?' → RMP. Multiple named frameworks (NIST CSF, HIPAA, SOC 2 Type II, SOX ITGC) are domain terms passing the ERM test, but the explicit disclaimer that referencing does not imply certification prevents Level 4 verification.

thinking: RMP - describes what the program does, frameworks referenced. Multiple named frameworks = domain terms. "reference" not "certified" so Level 2 not 4.


reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing the Audit Committee's role in overseeing ERM and cybersecurity programs with quarterly updates from management — classic BG. No domain-specific cybersecurity terms (ERM, risk assessment, Audit Committee, quarterly/annual cadences all fail the ERM test), no firm-specific facts, and no verifiable claims, so it remains Level 1.

thinking:
Let me analyze this paragraph.

Category: The paragraph discusses the Audit Committee's oversight of cybersecurity and ERM, plus how management reports to the committee. The primary question answered is "How does the board oversee cybersecurity?" — this is about the oversight structure (Audit Committee reviewing risks, getting updates). BG.

Specificity: Let me scan for facts.
- "Audit Committee" — generic, every company has one → not firm-specific
- "enterprise risk management program" — generic ERM language
- "annually" and "quarterly" — generic cadences

- "likelihood of occurrence and potential monetary impact" — basic risk assessment language, not domain-specific to cybersecurity

No domain terms that pass the ERM test. No firm-specific facts. No verifiable claims. This is Level 1.


category_confidence: low

reasoning: The paragraph is an introductory overview primarily framing the company's cybersecurity program goals (safeguarding systems, industry best practices), with a brief mention of governance support; the program description takes slightly more text than the governance mention, edging it toward RMP. No domain-specific terminology passes the ERM test—'industry best practices,' 'Audit Committee,' and generic safeguarding language are standard non-domain vocabulary—leaving specificity at Level 1.

thinking:
Classify this paragraph.

Content: Generic commitment to safeguarding info systems, mentions industry best practices, supported by management and Board/Audit Committee.

Category: This is a general overview touching on commitment and mentioning Board/Audit Committee support. The primary question it answers is vague - it's a general intro. It mentions board oversight briefly but doesn't describe HOW. It mentions the program but doesn't describe WHAT it does. This is mostly introductory boilerplate. The mention of Audit Committee is generic. I'd lean RMP as it's describing the program's existence and goals, but it's really just an intro.

The paragraph actually straddles two categories - it discusses the program's goals around industry best practices, which points toward RMP, but also emphasizes governance support from management and the Board, which leans toward BG. Looking at the primary framing though, the focus is on the program itself and its commitment to best practices rather than the governance structure, so RMP seems like the better fit despite the generic nature of the content.

As for specificity, this is clearly Level 1 boilerplate - mentions like "Audit Committee" and "industry best practices" are standard corporate language with no firm-specific details or domain terminology that would indicate deeper engagement with cybersecurity frameworks.


fact: December 2021 targeted cyber-attack causing global shutdown

fact: March 2024 cybersecurity breach at Canadian subsidiary

fact: Operations disrupted for approximately two weeks (2021 incident)

fact: Systems restored within one week (2024 incident)

fact: Endpoint protection software detected the 2024 attack

fact: Canadian subsidiary specifically affected

reasoning: The paragraph describes two actual cybersecurity incidents with timelines, scope, and response details, making Incident Disclosure the clear category despite brief materiality and remediation mentions. Specificity reaches Level 4 due to specific dates (December 2021, March 2024) tied to real events and quantified durations (approximately two weeks, within one week) that are externally verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: This describes two actual cybersecurity incidents - December 2021 and March 2024. The primary question answered is "What happened?" → Incident Disclosure. There's a brief SI-like sentence ("we do not anticipate further material adverse impacts") and some RMP content about enhancements, but the incident narrative dominates.

Specificity: Let me scan for facts:
- "December 2021" - specific date
- "March 2024" - specific date
- "approximately two weeks" - duration (soft-ish but has a specific number)

- "Canadian subsidiary" - firm-specific
- "one week" restoration time
- "endpoint protection software" - domain term
- "third-party monitoring partner" - generic
- "global shutdown" - firm-specific detail
- "freight shipments, customs brokerage functions, and distribution activities" - firm-specific operations

Verifiable facts: "December 2021" specific date tied to real event, "March 2024" specific date tied to real event, "approximately two weeks" disruption, "within one week" restoration. These are specific dates and durations tied to real events that could be verified.

Level 4 - Quantified-Verifiable due to specific dates and durations tied to real incidents, plus firm-specific operational details and restoration timelines.


fact: Senior Director of Information Technology role managing cybersecurity

fact: over 25 years of work experience in information technology and cybersecurity

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' by describing the Senior Director of IT and CFO's responsibilities and qualifications — the person-removal test leaves only a thin shell ('processes are implemented and maintained'). Specificity reaches Level 4 because 'over 25 years of work experience' is a quantified lower bound (≥25) that is in principle checkable against the individual's resume, though the Senior Director of IT title itself lacks a security qualifier and doesn't meet the firm-specific threshold per the rules.

thinking:
Let me analyze this paragraph.

Category: This describes management roles (Senior Director of IT, CFO) with their qualifications and responsibilities. The person-removal test: remove names, titles, qualifications → "Our cybersecurity risk assessment and management processes are implemented and maintained" — some process description remains but it's thin. The primary content is about WHO manages the program and their qualifications. → MR

Specificity:
- "Senior Director of Information Technology" — Director-level title without security qualifier → NOT firm-specific per rules. Wait, "Director of Information Technology" without security qualifier is explicitly listed as NOT firm-specific.

- "Chief Financial Officer" — generic role, not firm-specific
- "over 25 years of work experience" — this is a lower bound, verifiable (≥25 years). This counts as QV.
- "in public companies in our industry" — not specific enough
- "cybersecurity risk assessment" — fails ERM test
- "internal controls frameworks" — fails ERM test

Now I'm checking whether "over 25 years" is actually verifiable without a named person. The rules treat quantified experience thresholds like "more than 20 years" or "over 15 years" as verifiable claims, but here there's no specific individual identified, which makes it harder to verify against actual credentials. This seems like it might not meet the verification standard after all. I'm realizing the "over 25 years" is a quantified claim that should count as verifiable, so I'll mark it as Level 4. But "Senior Director of Information Technology" isn't firm-specific since it lacks a security qualifier like the rules require for director-level titles—it's just a generic IT role, not IT Security or Cybersecurity. I'm settling on the "over 25 years" experience claim as a quantifiable fact—the rules are explicit that lower bounds count as verifiable even without a named individual. The company is making a specific assertion about someone's tenure that can be checked.


fact: security questionnaires

reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party vendors, including different levels of assessment and contractual obligations, making TP the best fit. 'Security questionnaires' is a domain-specific vendor risk practice that passes the ERM test, elevating to Level 2.

thinking: Third-party risk management is the central topic here.


fact: threat intelligence

fact: Head of Information Technology role responsible for strategic leadership of IT organization

fact: Over thirty years of experience leading information technology teams in the life sciences industry

reasoning: The paragraph primarily answers who is responsible for cybersecurity at the management level — the Head of IT role, their responsibilities, and qualifications — making it MR. While some RMP activity (reviewing threat intelligence) is mentioned, the person-removal test leaves very little substance. 'Over thirty years of experience' is a verifiable lower bound (≥30 years), elevating to Level 4. Note: 'Head of IT' is below VP level without a security qualifier, so it does not qualify as firm-specific per the rules, but the quantified experience claim independently drives Level 4.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the Head of IT role, responsibilities, qualifications (30+ years experience), and some activities. Using the person-removal test: remove "Head of IT", "over thirty years of experience leading information technology teams in the life sciences industry" — what remains? "reviews threat intelligence, and receives updates from the Company's third-party providers, to help identify risks from cybersecurity threats." Some RMP content remains but it's thin. The primary focus is on who is responsible, their qualifications, and their role. This is MR.

Wait - "Head of IT" - is this firm-specific? The rules say "IT titles below VP level without a security qualifier" are NOT firm-specific.

"Head of Information Technology" isn't VP level and lacks a security qualifier, so it doesn't qualify as firm-specific. That puts it at Level 2 at best. Now looking at domain terms: "threat intelligence" clearly passes the ERM test as a cybersecurity-specific concept. The "over thirty years of experience" is a lower bound that's verifiable, which counts per the rules. So the overall specificity lands at Level 4 due to that quantified, verifiable experience metric.


reasoning: The paragraph describes who is responsible for cybersecurity (the information systems organization and its management team), their qualifications (formal education or relevant experience), and their training — all about how management is organized rather than what the program does. No specific roles at VP+ level are named, no specific certifications are identified, and no domain terms pass the ERM test, leaving this at Level 1.

thinking:
Classify this paragraph.

Category: This is about management's organization and qualifications - the information systems organization and management team, their responsibilities, their qualifications (formal education, experience), and training. Person-removal test: remove people/roles/qualifications → "developing and implementing cybersecurity policies" remains, but that's thin. The primary focus is on who is responsible and what qualifies them. → MR

Specificity: Let me scan for facts.
- "information systems organization" - generic
- "formal education in information technology or cybersecurity or relevant experience" - generic qualifications

- "periodic training and education on cybersecurity related topics including certifications" - mentions certifications but no specific ones named

No domain terms that pass ERM test. No firm-specific facts (no named roles at VP+ level, no specific committees). No verifiable claims. This is Level 1 - Generic Boilerplate.


reasoning: The paragraph primarily answers how the board oversees cybersecurity: full board oversight, quarterly reports, escalation process, and board education — all classic Board Governance content. Specificity stays Level 1 because the language is generic ERM ('oversight function,' 'quarterly reports,' 'escalation process,' 'third-party technology experts'); 'Director of IT' is a director-level title without a security qualifier, which per rules is not firm-specific, and no domain-specific cybersecurity terminology passes the ERM test.

thinking:
Let me analyze this paragraph.

Category: This is about board oversight of cybersecurity - how the board oversees cybersecurity risks, briefing frequency, escalation processes. Primary question: "How does the board oversee cybersecurity?" → Board Governance.

The "Director of IT" is mentioned but in context of presenting to the board - this is about the oversight structure flowing to the board.

Specific facts:
- "Director of IT" - this is a Director-level title WITHOUT a security qualifier, so per rules it's NOT firm-specific

- Quarterly board meeting reports and escalation processes for high-severity incidents are standard governance practices, not firm-specific
- The mention of independent third-party technology experts and penetration testing are generic industry practices, not unique terminology or domain-specific language
- "Director of IT" without a security qualifier doesn't meet the firm-specific threshold per the rules
- The cybersecurity risk and compliance language here is boilerplate ERM terminology

This reads as generic boilerplate with no domain-specific terminology or firm-specific facts that would elevate it beyond Level 1.


fact: CTO role named: Vaidyanathan Raghavan

fact: Vice President of Information Technology and Security: Brendan Hamilton

fact: CTO previously served as General Manager of Technology at Wayfair

fact: Holds a Master of Science in Electrical Engineering from University of Minnesota

fact: VP previously worked as a Vice President at an international bank with cybersecurity supervisory responsibility

fact: Certified Information Systems Security Professional (CISSP)

reasoning: The paragraph's primary content is the qualifications, career history, and credentials of two named management figures — applying the person-removal test leaves only a generic stub, confirming MR. CISSP certification is independently verifiable via (ISC)², the Wayfair role and University of Minnesota degree are also externally checkable, driving Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes management roles (CTO and VP of IT Security) with their qualifications, credentials, and career history. The opening clause mentions "cybersecurity risk assessment and management processes" but the bulk is about WHO these people are.

Person-removal test: Remove names, titles, qualifications → "Our cybersecurity risk assessment and management processes are implemented and maintained by certain members of management." Nearly nothing substantive remains → MR.

Specificity: Let me list facts:
- CTO title (named_role, firm-specific)
- Vaidyanathan Raghavan (named individual)

- Previously General Manager of Technology at Wayfair (named_firm, verifiable)
- Master of Science in Electrical Engineering from University of Minnesota (verifiable)
- Vice President of Information Technology and Security (named_role, firm-specific)
- Brendan Hamilton (named individual)
- Previously VP at an international bank with cybersecurity supervisory responsibility (firm-specific but bank unnamed)
- CISSP certification (verifiable via (ISC)² registry)

Multiple verifiable facts → Level 4.


fact: Uses the Ontrack software solution to monitor and track risk assessment and cybersecurity incidents

reasoning: The paragraph describes continuous risk monitoring activities and a specific software tool used for tracking risk assessments and incidents — clearly RMP. The named software 'Ontrack' is a firm-specific detail distinguishing this company's tooling, elevating specificity to Level 3.

thinking:
Classify this paragraph.

Content: Describes risk monitoring and review activities - continuous evaluation, use of Ontrack software for risk assessment monitoring and incident tracking.

Category: This is about what the cybersecurity program does - monitoring, tracking, software tools. RMP.

Specific facts:
- "Ontrack" - named software system (firm-specific, and potentially verifiable)
- Risk monitoring and review activities

Ontrack is a named system - firm-specific. Is it verifiable? It's a named software product, so potentially verifiable externally. Let me think... "Ontrack software solution" - this is a named product/tool.

Since Ontrack is a named software system, that makes this firm-specific at Level 3, even though it could theoretically be verified as a commercial product. The paragraph doesn't make any certification claims, so I'm classifying it as firm-specific based on the named system alone.


reasoning: The paragraph's primary purpose is materiality assessment: a backward-looking negative assertion ('have not identified any cybersecurity threat or incident that has materially affected') and a forward-looking SEC 106(b)(2) statement ('reasonably likely to materially affect us'), both triggering SI under Rule 5. The remaining content is generic investment language and a cross-reference to Risk Factors. No domain terms pass the ERM test, no firm-specific facts, and the negative self-assertion is not externally verifiable, leaving this at Level 1.

thinking:
Let me analyze this paragraph.

The paragraph states: no material incidents identified, but ongoing risks are reasonably likely to materially affect them, they invest in cybersecurity, and cross-references Risk Factors.

Category: The first sentence makes a materiality assessment (backward-looking: "have not identified any cybersecurity threat or incident that has materially affected") AND a forward-looking assessment ("reasonably likely to materially affect us"). Per Rule 5, both of these are SI assessments. The second sentence is generic RMP. The third sentence is a cross-reference (N/O). The dominant content is the materiality assessments → Strategy Integration.

The language here is entirely boilerplate—unverifiable assertions about past incidents, SEC-mandated forward-looking statements, and vague commitments to cybersecurity without any specifics about what the company actually does or how it differs from competitors. There are no domain-specific details, no firm-specific facts, and nothing that could be independently verified, which puts this squarely at Level 1 Generic Boilerplate.


fact: SVP of IT Security reports to Audit Committee

reasoning: The paragraph describes how the Audit Committee receives cybersecurity briefings and how information flows from management to the board, making it primarily about board oversight (BG). The SVP of IT Security is a VP-level role with a security qualifier, elevating specificity to Firm-Specific; the remaining content (quarterly cadence, report topics) is generic governance language.

thinking:
Let me analyze this paragraph.

Category: This describes how the Board's Audit Committee receives cybersecurity briefings and how information flows up to it. The SVP of IT Security reports to the Audit Committee. This is about board oversight structure and information flow → Board Governance.

Specific facts:
- "SVP of IT Security" — VP-level+ role with security qualifier → firm-specific (named_role)
- "at least once each calendar year" — generic cadence
- "quarterly" — generic cadence

- The briefings cover standard ERM topics like risk assessment, risk management, control decisions, service provider arrangements, test results, and incident responses — all generic language without specific quantified claims.

The SVP of IT Security is a firm-specific role (VP+ with security qualifier), so that's Level 3. No verifiable quantified claims present.


fact: Vice President and Chief Information Officer oversees cybersecurity programs

fact: Director of Information Security leads day-to-day administration

fact: VP/CIO has 27 years of technology leadership experience

fact: VP/CIO holds a Doctor of Business Administration

fact: Director of Information Security has 27 years of experience in infrastructure and security operations

fact: Director of Information Security holds a degree in Information Technology Management

fact: Information Security Committee

fact: Executive committee includes SVP/CFO, SVP/CLO and Secretary, SVP/CHRO

fact: security operations

reasoning: The paragraph primarily describes management organization: roles (VP/CIO, Director of Information Security), their qualifications, reporting lines, and committee membership/structure — all answering 'how is management organized to handle cybersecurity?' → MR. Specificity reaches Level 4 via multiple verifiable claims: specific years of experience (27 years each) and named credentials (Doctor of Business Administration, degree in IT Management).

thinking:
Let me analyze this paragraph.

Category: This describes management roles, qualifications, reporting lines, committee structure and membership. The primary question answered is "How is management organized to handle cybersecurity?" → Management Role.

The governance chain goes from management committees up to Audit Committee, but the bulk is about management organization, qualifications, and committee membership.

Specific facts:
- VP and CIO (named role, firm-specific)
- Director of Information Security (named role with security qualifier, firm-specific)
- 27 years of technology leadership experience (quantified, verifiable)

- Doctor of Business Administration and degree in Information Technology Management (verifiable credentials)
- Information Security Committee and Executive Information Security Oversight Committee (named committees, firm-specific)
- SVP, CFO; SVP, CLO and Secretary; SVP, CHRO serving as committee members (firm-specific roles)
- Audit Committee providing oversight

Specificity: Level 4 due to quantified experience metrics and specific degree credentials.


reasoning: The paragraph answers how the board oversees cybersecurity, describing the Audit Committee's role in reviewing risk assessment and risk management policies including cybersecurity — classic Board Governance. No domain-specific cybersecurity terms (risk assessment/risk management are generic ERM language), no firm-specific facts (Audit Committee is generic), and no verifiable claims, leaving this at Level 1.

thinking:
Classify this paragraph.

Content: Board-level oversight via Audit Committee, risk management review responsibilities including cybersecurity.

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

Specificity: "Audit Committee" is generic (every company has one). "risk assessment", "risk management" are generic ERM terms. No domain-specific cybersecurity terms, no firm-specific facts, no verifiable claims.

Level 1.


fact: Chief Technology Officer (CTO) presents cybersecurity topics to the Board and Audit Committee

reasoning: The paragraph describes how the Audit Committee reports to the full Board on cybersecurity, how the Board receives briefings, and the flow of information from management to the Board — all classic board oversight structure, making this Board Governance. The CTO is a firm-specific named role (VP-level or above) that elevates specificity to Level 3, while the remaining content (Audit Committee, briefings from management, external experts) is generic governance language.

thinking:
Board governance paragraph about oversight structure.

Facts: CTO mentioned (named_role), Audit Committee (generic, every company has one).

CTO is a VP-level-or-above role → firm-specific. "Audit Committee" is generic per rules.

"cyber risk management program" - generic. "internal security staff or external experts" - generic.

Specificity: Level 3 due to CTO.


fact: HITRUST framework

fact: SOC2 framework

fact: NIST framework

fact: penetration testing

fact: threat modeling

fact: network firewalls

fact: vulnerability scanners

fact: identity and access management systems

fact: access controls

fact: phishing email simulations

fact: vulnerability assessments

fact: cybersecurity threat intelligence

reasoning: The paragraph is a comprehensive description of the company's cybersecurity program activities—frameworks, tools, training, incident response—squarely answering 'what does the program do?' → RMP. It is rich in domain terminology (HITRUST, SOC2, NIST, IDS/IPS, endpoint protection, vulnerability scanners, threat modeling, phishing simulations) passing the ERM test, but cadences like 'quarterly' and 'annual' are generic per the rules, the Incident Response Plan lacks a distinguishing identifier, and no named roles, verifiable claims, or firm-unique facts elevate it beyond Level 2.

thinking:
This is a detailed paragraph about cybersecurity risk management processes.

Category: RMP - describes what the cybersecurity program does, including frameworks, tools, training, incident response, etc.

Specific facts:
- HITRUST framework
- SOC2 framework
- penetration testing
- threat modeling
- network firewalls, access controls, vulnerability scanners, intrusion prevention and detection systems, anti-malware/endpoint protection systems, identity and access management systems
- NIST framework
- quarterly mandatory training
- quarterly phishing email simulations

- annual tabletop exercises
- formal Incident Response Plan
- cybersecurity insurance

The program also runs annual tabletop exercises to test incident response procedures and maintains a formal Incident Response Plan aligned with NIST, HITRUST, and SOC2 standards, plus carries cybersecurity insurance as an additional risk mitigation layer.

Now I'm reconsidering what actually qualifies as firm-specific here. The frameworks themselves are domain knowledge, and cadences like "quarterly" are too generic to be distinguishing. What might push this toward L3 is the formal Incident Response Plan as a named internal program, though without specific identifiers or details about how it differs from standard practice, it's borderline. The combination of which frameworks they reference together could suggest firm-specific choices, but frameworks themselves are L2 domain terms. The insurance claim is something many companies mention, so it's not really firm-specific either. I'm settling on Domain-Adapted (L2) for this overall assessment.


reasoning: The paragraph's primary purpose is a backward-looking materiality assessment ('have not identified any cybersecurity threats that have materially affected...our business strategy, results of operations, or financial condition'), which is the SEC Item 106(b)(2) conclusion → SI. No domain terms, firm-specific facts, or verifiable claims are present; the negative self-assertion about no material incidents is not externally verifiable, and the remaining content is generic hedging and a cross-reference to Item 1A.

thinking: SI materiality assessment + cross-reference to 1A.


fact: Topper Group (named entity specific to CAPL's organizational structure)

reasoning: The paragraph's central purpose is stating materiality conclusions: incidents 'have not had a material impact' (backward-looking) and are not 'reasonably likely to materially affect' operations (forward-looking SEC 106(b)(2) language), making it SI per Rule 5. The reference to 'Topper Group' is a firm-specific entity name that distinguishes this company, elevating specificity to Level 3.

thinking:
Let me analyze this paragraph.

It discusses actual incidents (directed attacks) but then states conclusions about materiality impact. Let me check the rules.

The paragraph has three parts:
1. Description of attacks they experience (general, not a specific incident)
2. Materiality assessment: "these incidents have not had a material impact" and "we do not believe cybersecurity risks from these prior incidents are reasonably likely to materially affect"
3. Cross-reference to Risk Factors

By Rule 5, the materiality statements are SI. The first sentence describes general attack patterns, not a specific incident. The cross-reference is N/O. The dominant frame is the materiality assessment.

The materiality statement is a negative self-assertion that can't be independently verified, and while the text references Topper Group by name, the cross-reference to Risk Factors and the unverifiable nature of the claim push this toward Firm-Specific categorization.


reasoning: This is an introductory framing paragraph about the importance of cybersecurity. It lists threat types (ransomware, denial-of-service, nation-state actors) as context but does not describe any actual cybersecurity measures, governance structures, management roles, or program activities — it answers none of the six substantive questions. The 'could materially adversely affect' language is speculation per Rule 5, not an SI assessment. As N/O, specificity defaults to Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Category: This is an introductory paragraph about cybersecurity importance. It mentions threat types but doesn't describe what the program does, how the board oversees it, or management roles. It has a materiality statement but it's speculative ("could materially adversely affect") rather than an assessment. Per Rule 5, "could have a material adverse effect" is speculation, not SI. This is mostly introductory framing without substantive disclosure of any specific category. → None/Other.

Wait, let me reconsider. It mentions specific threat types (ransomware, denial-of-service, nation-state actors, APTs).

But the paragraph doesn't describe any actual cybersecurity measures or processes. It's about recognizing importance and listing threats. No substantive program description. Per Rule 6, "Pure speculation without measures → N/O." This paragraph doesn't describe any actual measures, just why cybersecurity matters and what threats exist. It's borderline for RMP, but there's no description of what they actually do to manage these risks.

The "could materially adversely affect" language is speculation per Rule 5, not Strategy Integration. This reads as an introductory framing paragraph that doesn't substantively answer any of the six questions. Even though it contains domain-specific terms like ransomware, denial-of-service, and CIA triad, N/O paragraphs always get Generic Boilerplate. The paragraph recognizes importance, lists threat types, mentions third-party risks, and speculates about potential adverse effects—but it doesn't explain what the program actually does.


reasoning: This is a cross-reference paragraph 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: CTO identified as responsible for cybersecurity risk management

fact: IT Manager identified as responsible for cybersecurity risk management

reasoning: The paragraph describes who is responsible for cybersecurity (CTO, IT Manager) and their supervisory scope — this is about organizational roles, not program activities, making it MR. CTO is a C-suite title in cybersecurity context (firm-specific); IT Manager is below VP without a security qualifier and wouldn't normally qualify, but the CTO alone elevates to Level 3.

thinking:
Classify this paragraph.

Category: This describes management's organizational role - who is responsible, reporting structure. The person-removal test: remove CTO, IT Manager titles → "Our team is responsible for assessing and managing risks. The team has primary responsibility for our program and supervises both internal personnel and external consultants." Some substance remains but it's about the role/responsibility, not program activities. This is MR.

Specific facts:
- CTO → named_role (VP-level or above? CTO is typically C-suite, yes → firm-specific)
- IT Manager → NOT firm-specific (below VP level, no security qualifier)

- "cybersecurity risk management program" → generic
- External cybersecurity consultants → generic

Specificity: Level 3 (CTO is firm-specific as a named role in cybersecurity context)


reasoning: The paragraph's central topic is how third-party service providers are selected, overseen, and monitored for cybersecurity risks, making TP the clear category. The language is entirely generic — 'due diligence,' 'adequate cybersecurity safeguards,' 'continually monitor' — all terms any ERM professional would use, with no domain-specific terminology, firm-specific facts, or verifiable claims.

thinking:
Third-party risk management is the central topic here.

Specificity: No domain terms that pass ERM test, no firm-specific facts, no verifiable claims. "Due diligence," "cybersecurity safeguards," "monitor cybersecurity threat risks" — all generic language any ERM professional could write.


reasoning: The paragraph is centrally about oversight requirements imposed on IT suppliers/vendors regarding data handling and periodic assessments, making Third-Party Risk the clear category. The language is entirely generic — 'risk assessments,' 'periodic basis,' 'due diligence procedures' — with no domain-specific terminology, firm-unique details, or verifiable claims.

thinking:
Classify this paragraph about SS&C's IT supplier risk assessments.

Category: This is centrally about how third-party/vendor cyber risks are managed - requirements imposed on vendors. → Third-Party Risk

Specificity: Let me scan for facts.
- "information technology supplier risk assessments" - generic process description
- "periodic basis" - generic cadence
- "access, handle, transmit, process or store personal information or other customer data" - fairly standard language
- "due diligence procedures" - generic

No domain terms that pass the ERM test. No firm-specific facts. No verifiable claims. This is generic boilerplate about vendor oversight.

This lands at Level 1 - it's just standard vendor management language without any concrete details or company-specific practices.


fact: NIST Framework

reasoning: The paragraph describes what the cybersecurity program does: framework adoption, security tools, monitoring and detection — all program activities, making it RMP. NIST Framework is a named standard passing the ERM test, but the remaining language ('security tools,' 'monitoring and detection tools,' 'internal reporting') is generic and no firm-specific or verifiable facts are present, so specificity stays at Level 2.

thinking:
Classify this paragraph.

Category: Describes what the cybersecurity program does - risk assessment, framework adoption, security tools, monitoring. This is RMP.

Specificity: "NIST Framework" is a domain term (named standard). The rest is fairly generic. No firm-specific facts, no verifiable claims.

Level 2 - Domain-Adapted due to NIST Framework reference.


fact: ISO 27001 certification (obtained second certification)

fact: Second ISO 27001 certification — specific count, externally verifiable via certification body

reasoning: The paragraph describes program activities: controls review, external testing, employee training, and third-party assessments — all squarely RMP. Specificity reaches Level 4 because 'obtained our second ISO 27001 certification' is a verifiable claim (certification status is confirmable via accredited certification bodies), and the count 'second' is a hard number.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity controls review, external testing, employee training, third-party assessments, and ISO 27001 certification.

Category: This is about what the cybersecurity program does - testing, training, third-party assessments. RMP.

Specific facts:
- "external parties on an annual basis" - testing by external parties, annual cadence - generic
- "online training modules" - generic
- "periodic testing" - generic
- "ISO 27001 certification" - domain term (framework reference), but "obtained our second ISO 27001 certification" - this is a verifiable claim (they hold the certification, verifiable via certification body)

- The "second ISO 27001 certification" is quantified and verifiable - you can confirm they actually hold this certification. Level 4.


reasoning: The paragraph describes the responsibilities of the Senior Director of IT and General Counsel regarding cybersecurity—hiring, budgets, incident preparation, reviewing assessments—making it primarily about management roles and responsibilities. No domain-specific terms pass the ERM test (all activities described are generic management functions), and neither 'Senior Director of IT' (no security qualifier) nor 'General Counsel' (generic governance role) qualify as firm-specific, leaving this at Level 1.

thinking:
Let me analyze this paragraph.

Content: Describes responsibilities of Senior Director of IT and General Counsel regarding cybersecurity. This is about management roles and responsibilities.

Category: Management Role - describes who is responsible for what in cybersecurity management.

Specific facts:
- "Senior Director of IT" - this is a director-level title without a security qualifier, so per rules it's NOT firm-specific
- "General Counsel" - generic governance role, NOT firm-specific

Wait, let me re-check. "Senior Director of IT" - the rules say "Director-level titles WITH a security qualifier (Director of IT Security, Director of Cybersecurity, Director of Information Security)" are firm-specific, but "NOT plain 'Director of IT' or 'Director of Information Technology' without a security qualifier." So Senior Director of IT is NOT firm-specific.

The activities listed—hiring, integrating cybersecurity into risk management, communicating priorities, approving budgets, incident preparation, approving processes, reviewing assessments—are all standard management functions without specialized domain language. Terms like "security assessments" and "risk management strategy" are too generic to distinguish this from general enterprise risk management. This falls into Level 1 - Generic Boilerplate.