reasoning: This is a forward-looking disclaimer about potential cybersecurity incidents using speculative language ('could materially impact,' 'there can be no assurance'). Per Rule 5, 'could have a material adverse effect' is speculation every 10-K says, not a materiality assessment, and no substantive cybersecurity measures are described. No domain terms, firm-specific facts, or verifiable claims are present.

thinking:
This is a forward-looking disclaimer about potential cybersecurity incidents with speculative language ("could", "there can be no assurance"). It doesn't describe actual program activities in detail, no real incident, and the materiality language is speculative ("could materially impact") rather than an assessment.

This is N/O - it's a generic risk disclaimer. "Could materially impact" is speculation, not an assessment per Rule 5.


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: The paragraph states a backward-looking materiality conclusion ('have not materially affected') and a forward-looking SEC 106(b)(2) assessment ('are reasonably likely to materially affect'), making it Strategy Integration under Rule 5. No domain terms, firm-specific facts, or verifiable claims are present—it is standard materiality boilerplate.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking: SI materiality rule applies here.


content_category: Management Role

fact: Chief Technology Officer role

fact: Executive Vice President – Operations role

fact: CTO reports to EVP – Operations

fact: Cybersecurity incidents reported to legal department

reasoning: The paragraph primarily describes management reporting lines (CTO → EVP-Operations), incident escalation to legal, and asserts the team's qualifications — all about how management is organized to handle cybersecurity, making it MR. Specificity is Firm-Specific due to named VP+ roles (CTO, EVP-Operations) and the specific reporting structure, but no externally verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: Describes CTO reporting to EVP-Operations, incident reporting to legal, and qualifications of cybersecurity management team.

Category: This is about management organizational structure - reporting lines, roles, qualifications. MR.

Specific facts:
- CTO (named role, VP+ level) → firm-specific
- EVP – Operations (named role, VP+ level) → firm-specific
- Reporting line: CTO reports to EVP-Operations → firm-specific
- Incidents reported to legal department → firm-specific organizational detail

No verifiable claims (no numbers, certifications, named individuals, etc.)

This falls into Firm-Specific at Level 3 since it details the company's particular organizational structure and internal reporting relationships without any independently verifiable information.


content_category: None/Other

reasoning: This is a cross-reference to Item 1A Risk Factors with no substantive cybersecurity disclosure of its own. The 'could materially and adversely affect' language is generic speculation present in virtually every 10-K, not a materiality assessment. No specific facts elevate specificity.

thinking: Cross-reference to Item 1A Risk Factors. No substantive cybersecurity disclosure.


fact: Executive Vice President of Technology (VP+ level cybersecurity-relevant role)

fact: Reports directly to the Chief Executive Officer

fact: Over 16 years of experience managing information technology and cybersecurity matters

type: quantified

category_confidence: medium

reasoning: The paragraph contains MR content (EVP role, reporting line) and RMP content (ERM integration), but the dominant purpose is the materiality assessment: a backward-looking conclusion ('have not identified risks...that have materially affected us') and a forward-looking SEC 106(b)(2) statement ('reasonably likely to materially affect us'), making SI the primary category per Rule 5. Specificity reaches Level 4 because 'over 16 years of experience' is a verifiable lower bound.

thinking:
Let me analyze this paragraph carefully.

Content: Describes EVP of Technology role, ERM integration, materiality assessment, and cross-reference to Risk Factors.

Category analysis:
- EVP of Technology role, reporting line, experience → MR
- ERM integration → RMP
- Materiality assessment ("have not identified risks...that have materially affected us" and "reasonably likely to materially affect us") → SI
- Cross-reference to Risk Factors → N/O

The materiality assessment is a significant portion. The management role info is also substantial. But the SI materiality rule says stating a conclusion about whether cybersecurity has/will affect business outcomes → SI.

I'm seeing two distinct materiality statements here—one looking back at what hasn't affected the business and another forward-looking about what reasonably could. The paragraph structure has the EVP role description upfront, then ERM integration, followed by these materiality conclusions that take up considerable space, and finally a cross-reference. The backward and forward-looking SEC language around materiality is quite prominent, so I'm leaning toward SI given Rule 5 and how much weight these statements carry in the overall text.

Breaking down the specificity: the EVP title and CEO reporting line are firm-specific details, the 16+ years is quantified and verifiable, the IT and cybersecurity scope provides context, the ERM framework is generic, the materiality language is SI content, and the Item 1A reference is just a pointer. That puts this at Level 4.


fact: Chief Operating Officer and Chief Compliance Officer responsible for assessing and managing cybersecurity risks

fact: Communications with legal, operations, information technology, and/or compliance personnel

specificity_confidence: medium

reasoning: The paragraph primarily answers 'how is management organized to handle cybersecurity?' by identifying responsible officers (COO, CCO), their areas of expertise, and how they stay informed — this is about roles and qualifications, making it MR. Specificity reaches Firm-Specific due to the specific departmental team composition (legal, operations, IT, compliance) and the assignment of cybersecurity responsibility to the COO and CCO, which distinguishes this company's organizational structure, though neither title is a security-specific VP+ role.

thinking:
Classify this paragraph.

Category: Management Role - describes management's responsibilities, expertise, and how they monitor cybersecurity. The primary question answered is "How is management organized to handle cybersecurity?"

Person-removal test: Remove COO, CCO titles and expertise descriptions. What remains? "management is informed about and monitors the prevention, detection, mitigation, and remediation of cybersecurity incidents, including through the receipt of notifications from service providers and reliance on communications with legal, operations, information technology, and/or compliance personnel." This describes monitoring activities but is tied to management's role. The paragraph is primarily about who is responsible and what qualifies them. MR.

Now I'm looking at the specific elements to see what's actually firm-specific versus generic governance language. The COO and CCO are standard C-suite titles without security focus, and the incident response terminology is boilerplate. The departments mentioned—legal, operations, IT, compliance—could represent the firm's actual team structure, though they're fairly common organizational divisions. The departmental composition—legal, operations, information technology, and compliance—does distinguish this company's structure, so that qualifies as firm-specific. The COO and CCO being assigned cybersecurity responsibility is also somewhat organizational-specific, though I should be conservative since those aren't security-qualified VP+ roles per the guidelines. I'll classify this as Level 3 (Firm-Specific) based on the departmental team composition.


content_category: Third-Party Risk

fact: penetration testing

fact: managed detection and response services

fact: intrusion prevention and detection applications

reasoning: The paragraph is split between describing third parties hired to serve the company (RMP) and oversight imposed ON third parties (TP); the latter half (vendor risk management program, identifying risks from critical third parties, assessing third-party cyber risk protocols) dominates with 3 of 5 sentences, making TP the central topic. Domain terms like penetration testing, managed detection and response, and intrusion prevention/detection pass the ERM test for Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Category: This discusses third-party engagements for cybersecurity services AND vendor risk management. The first half is about third parties hired to serve the company (assessors, pen testers) → RMP per Rule 3. The second half discusses vendor oversight requirements imposed on third parties. It's mixed, but the majority of text describes the company's own program activities using third parties, plus vendor risk management. The central topic seems split between RMP and TP. Let me re-read...

First 2 sentences: engaging third parties to test/maintain cybersecurity - RMP (third parties serving the company)

The remaining sentences focus on vendor oversight—identifying risks from critical third parties and assessing their cyber risk management capabilities. That's the dominant theme here, so this leans toward TP. The domain-specific terms include penetration testing, managed detection and response, and intrusion prevention and detection systems.


fact: CISO role leading global cybersecurity program

fact: CISO joined Workday in 2010

fact: Served as CISO since April 2018

fact: More than 15 years of experience in cybersecurity and IT risk management

fact: Degree in information systems management

reasoning: The paragraph primarily answers who is responsible for cybersecurity and what qualifies them — the CISO's responsibilities, tenure, experience, and education — making it MR via the person-removal test (removing the person leaves only a generic program sentence). Specificity reaches Level 4 due to multiple verifiable claims: joined in 2010, CISO since April 2018, and more than 15 years of experience (a verifiable lower bound).

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the CISO's responsibilities and qualifications. Using the person-removal test: remove the CISO's title, qualifications, experience, reporting lines → what remains? "leads all aspects of our global cybersecurity program, including the identification, evaluation, and prioritization of security risks, as well as the company's response to material security incidents." This is a generic program description. But the bulk of the paragraph is about the CISO's background. It's close, but the primary question answered is "who is responsible and what qualifies them" → MR.

Specificity:
- CISO → firm-specific (named role)

- The paragraph includes multiple verifiable facts: the specific year they joined the company, when they became CISO, their years of experience, and their educational background. All of these are concrete details that can be confirmed. Level 4.


fact: threat intelligence

reasoning: The paragraph identifies which executive leaders (CFO, SVP/General Counsel) supervise cybersecurity efforts and describes the information channels they use, making management's organizational role the primary focus (MR). The person-removal test is borderline—some program description remains—but the paragraph's purpose is establishing who oversees, not what the program does. 'Threat intelligence' passes the ERM test as a domain-specific term, elevating to Level 2, but CFO and General Counsel are generic roles present at every company, falling short of firm-specific.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes executive leadership team members supervising cybersecurity efforts. The grammatical subjects are leadership team members, but the content describes what activities they supervise (prevent, detect, mitigate, remediate) and through what means (briefings, threat intelligence, security tools). Applying the person-removal test: remove CFO, SVP General Counsel - substantive program description remains about briefings, threat intelligence, alerts from security tools. But actually, the main point is about WHO supervises and HOW they get information. This is about management's organizational role and how they oversee. The "means" listed are how information flows to management, not program activities themselves.

Actually, I'm reconsidering - the means here are the mechanisms through which they supervise, not separate activities. This is clearly about management's oversight role, which makes it MR rather than BG since it's executive leadership, not the board. Now looking at specificity: CFO is a generic role every company has, and while SVP General Counsel indicates seniority, General Counsel itself is a standard position. Terms like "threat intelligence" are domain-specific, but I need to assess whether this crosses into firm-specific territory.

The key issue is "threat intelligence" - that's security jargon that an ERM professional wouldn't naturally use in this context, which pushes this toward Level 2. The other elements like security tools and internal personnel are generic, so the domain terminology is what distinguishes it.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party service providers, including supplier oversight and contractual requirements, making TP the clear category. No domain-specific terminology passes the ERM test — 'selection and oversight of third-party service providers' and 'agree by contract to manage their cybersecurity risks' are generic risk management language any business professional could produce.

thinking:
Let me classify this paragraph.

Content: About third-party cybersecurity risk management - vendor oversight, contractual requirements.

Category: This is centrally about third-party risk management. Rule 3 says vendor oversight as central topic → TP.

Specificity: Let me scan for facts.
- "suppliers and manufacturers" - generic
- "patient and employee data" - somewhat specific to their business but not really a domain term
- "agree by contract to manage their cybersecurity risks" - generic contractual requirement

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

There are no verifiable claims here—it's just generic boilerplate that any ERM professional could produce. This rates as Level 1.


content_category: Board Governance

fact: vulnerability assessments

fact: Chief Technology Officer (CTO)

fact: Chief Information Security Officer (CISO)

reasoning: The paragraph describes how the Board and Audit Committee oversee cybersecurity, including briefing frequency and information flow from management, making it Board Governance. The named VP+-level roles (CTO, CISO) are firm-specific facts elevating to Level 3, while 'vulnerability assessments' is a domain term but the firm-specific roles set the floor.

thinking:
Classify this paragraph.

Category: Board oversight via Audit Committee, receiving reports from CTO/CISO. This is about how the board oversees cybersecurity → Board Governance.

Specific facts:
- CTO (named role, but generic? No - CTO is VP+ level → firm-specific)
- CISO (named role → firm-specific)
- "quarterly presentations" - generic cadence
- "vulnerability assessments" - domain term (ERM test: would a non-security ERM professional use this? It's borderline but I think vulnerability assessments is cybersecurity-specific enough)

- "third-party and independent reviews" - generic
- "threat environment" - domain term? Borderline. ERM professionals might say this.

The presence of CTO and CISO roles at the VP+ level makes this firm-specific, pushing the specificity to Level 3, even though some language like "threat environment" and "third-party reviews" could appear in broader ERM contexts.


fact: 25 years of experience in strategic IT leadership and global project management

reasoning: The paragraph describes a management role's title and qualifications, making it Management Role. '25 years of experience' is a specific numeric claim verifiable against the individual's resume, elevating to Level 4.

thinking:
Classify this paragraph.

Content: About a specific person's role and experience - "Head of Information Technology for Latin America, who oversees Cybersecurity" with "25 years of experience."

Category: Management Role - describes a leadership role, qualifications, experience.

Specific facts:
- "Head of Information Technology for Latin America" - this is a named role but need to check if it qualifies as firm-specific. It's not VP-level or above, and "Head of IT" is listed as NOT firm-specific. But "Head of Information Technology for Latin America, who oversees Cybersecurity" - the title itself is "Head of Information Technology for Latin America" which is below VP level without a security qualifier in the title.

The geographic qualifier for Latin America makes this more specific than a standard "Head of IT" role, but the rules are clear that "Head of" titles below VP level aren't firm-specific, and the cybersecurity oversight is a separate description rather than part of the formal title itself.

For the experience claim, "25 years" is a concrete, verifiable metric that can be checked against a resume, so that's Level 4 specificity.


reasoning: The paragraph states a backward-looking materiality conclusion ('none of these incidents...had a material adverse effect on our business strategy, operations, or financial conditions'), which is an SI assessment per Rule 5. The second sentence is a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims are present — the acknowledgment of past incidents is vague and the negative materiality assertion is a self-reported claim not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: States past cyber incidents weren't material, then cross-references Item 1A.

Category: The first sentence is a materiality assessment - "none of these incidents...had a material adverse effect on our business strategy, operations, or financial conditions" → SI per Rule 5 (backward-looking materiality conclusion). The second sentence is a cross-reference → N/O, but the first sentence dominates.

Specificity: "Have not had a material adverse effect" is a negative self-assertion about absence of material impact - not externally verifiable. "There have been cyber incidents in the past" acknowledges incidents but no specifics.

This lands at Level 1 - there's no domain expertise, no company-specific facts, and nothing that can be independently verified.


content_category: Risk Management Process

fact: References NIST CSF five functions framework: 'identifying, protecting from, detecting, responding to, and recovering from'

type: framework

reasoning: The paragraph describes incident management team activities, escalation procedures, and incident response testing — all program activities, making it RMP. The explicit use of the five NIST CSF functions (identify, protect, detect, respond, recover) demonstrates domain knowledge beyond generic ERM language, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Category: This describes what the cybersecurity program does - incident management team activities, incident response processes, escalation procedures, testing exercises. Applying the person-removal test: remove person-specific content and the program description remains intact. This is RMP.

Specificity: Let me scan for facts:
- "dedicated incident management team" - generic
- "executive incident team" - could be firm-specific as a named team? It's somewhat generic though
- "cross-functional teams" - generic
- "incident response test exercise" - generic (tabletop exercises without cyber qualifier = L1)

- "at least one incident response test exercise on an annual basis" - the frequency is generic, though "at least one" sets a lower bound

The language around identifying, protecting, detecting, responding to, and recovering from threats maps directly to the NIST CSF framework - that's domain-specific terminology that an ERM professional wouldn't naturally gravitate toward without specialized knowledge.

"Executive incident team" functions as a named internal team, though it's fairly common across organizations. "Incident management team" and "incident response team" are more generic terms.

The NIST CSF five-function reference qualifies as Level 2 domain terminology. While "incident response" itself is listed as commonly confused at Level 1, the specific invocation of all five NIST pillars together demonstrates domain knowledge and shows this isn't just generic incident response language.

Specificity assessment: Domain-Adapted (Level 2).


reasoning: The paragraph states a backward-looking negative materiality assertion ('not aware of any cybersecurity incidents that have materially impaired our operations or financial reporting'), which is an assessment of whether cybersecurity has affected business outcomes → SI per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present; the negative self-assertion about absence of incidents is not externally verifiable → Level 1.

thinking:
Classify this paragraph.

"We are not aware of any cybersecurity incidents that have materially impaired our operations or financial reporting responsibilities or performance historically."

This is a negative materiality assertion - stating that no material incidents have occurred. Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI.

Specificity: This is a negative self-assertion about absence of material incidents. No domain terms, no firm-specific facts, no verifiable claims. Level 1.


reasoning: The paragraph centrally addresses how the company manages third-party/vendor cybersecurity risks, making Third-Party Risk the clear category. The language is entirely generic — 'vendor risk management program,' 'third-party risks,' 'cybersecurity defense programs' — all terms any ERM professional would use, with no domain-specific terminology, firm-specific facts, or verifiable claims.

thinking:
Classifying this paragraph about third-party risk management.

Category: This is centrally about third-party cyber risks - managing vendor risks, assessing exposure to external cybersecurity risks. → Third-Party Risk

Specificity: Let me scan for facts.
- "vendor risk management program" - generic term
- "developing a vendor risk management program" - this is somewhat firm-specific (they're still developing it, not yet implemented), but "vendor risk management program" is generic
- No domain terms that pass ERM test
- No named roles, committees, frameworks
- No verifiable facts

This is pretty generic.

The language here—third-party risks, cybersecurity incidents, vendor risk management programs—reads like something any ERM professional could produce without insider knowledge. That puts it at Level 1.


reasoning: The first sentence is a materiality assessment concluding that no cybersecurity risks have materially affected or are reasonably likely to materially affect the company — a textbook SI conclusion per Rule 5. The brief third-party sentence is subordinate. No domain terms passing the ERM test, no firm-specific facts, and '2024' is merely a reporting period reference, so specificity stays Level 1.

thinking:
Let me analyze this paragraph.

Two sentences:
1. "We are not aware of any cybersecurity risks...that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition." - This is a materiality assessment (both backward and forward-looking). → SI per Rule 5.
2. "Third parties with access to sensitive data or systems are subject to due diligence and ongoing monitoring." → TP content, but brief.

The first sentence is clearly a materiality conclusion → SI. The second sentence is about third-party risk but is subordinate. The primary question answered is "How does cybersecurity affect the business?" → SI.

The language here relies heavily on SEC materiality standards—"materially affected" and the specific enumeration of business strategy, results of operations, and financial condition are textbook disclosure language. The third-party monitoring statement is vague boilerplate without specifics, and there are no domain-specific terms, firm-particular facts, or verifiable claims that would elevate this beyond generic language. This is Level 1 boilerplate.


reasoning: The paragraph's central assertion is a negative materiality statement ('have not had any known instances of material cybersecurity incidents') which is a backward-looking assessment per Rule 5, making it Strategy Integration. The remainder is generic disclaimer and a cross-reference to Item 1A. No domain terms pass the ERM test, no firm-specific facts, and the negative assertion about no incidents is not externally verifiable, so specificity stays at Level 1.

thinking:
Let me analyze this paragraph.

Content: States no material incidents as of Dec 31 2024, disclaims future assurance, cross-references Item 1A risk factors.

Category: The key statement is "we have not had any known instances of material cybersecurity incidents" - this is a negative assertion about materiality → SI per Rule 5. The rest is disclaimer and cross-reference.

Specificity: "As of December 31, 2024, we have not had any known instances of material cybersecurity incidents" - this is a negative self-assertion, NOT externally verifiable per the rules.

The cross-reference to Item 1A doesn't add substantive content, and the mention of third-party provider incidents is too generic without firm-specific details. This looks like Level 1 disclosure.


reasoning: The paragraph states a backward-looking materiality conclusion ('has not encountered any risks from cybersecurity threats...that materially affected or are reasonably likely to materially affect the Company') plus forward-looking SEC Item 106(b)(2) language, making it Strategy Integration per the SI materiality rule. No domain terms, firm-specific facts, or verifiable claims are present—just generic boilerplate materiality language and a vague mitigation statement.

thinking: Strategy Integration - materiality assessment statement.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not had a material impact') and a forward-looking assessment ('not anticipated to significantly affect... business strategy, results of operations or financial condition'), triggering the SI materiality rule. No domain terms, firm-specific facts, or verifiable claims are present, so specificity remains Level 1.

thinking: Materiality assessment paragraph.


fact: NIST CSF used as guide for program design and assessment

reasoning: The paragraph describes the company's framework adoption (NIST CSF) for identifying, assessing, and managing cybersecurity risks, which is a program activity → RMP. NIST CSF is a named cybersecurity framework (Domain-Adapted), but the language is 'use as a guide' rather than claiming certification, so it stays at Level 2.

thinking:
Classify this paragraph.

Content: Describes using NIST CSF as a guide for their program design and assessment, with a disclaimer that it doesn't mean they meet all standards.

Category: This is about what the cybersecurity program does (framework adoption) → RMP.

Specific facts:
- NIST CSF → framework reference, domain term (Level 2). It's "based on" / "use as a guide" — not claiming certification, so Domain-Adapted not QV.

Specificity: Level 2 (Domain-Adapted) due to NIST CSF reference.


fact: Risk Committee of the Board of Directors ('Risk Committee') provides cybersecurity oversight

reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing the governance chain from management to the Board and delegating cybersecurity oversight to the Risk Committee — classic Board Governance. The named 'Risk Committee of the Board of Directors' is a non-generic board-level committee that elevates specificity to Firm-Specific; otherwise the language is standard governance boilerplate with no domain terms or verifiable claims.

thinking:
Classify this paragraph.

Category: This describes the board's oversight structure for cybersecurity. The Risk Committee of the Board provides oversight. Even though management is mentioned first, the primary content is about how the Board and its Risk Committee oversee cybersecurity risks. → Board Governance.

Specific facts:
- "Risk Committee of the Board of Directors" — this is a named committee but it's a board-level committee. Is it firm-specific? The instructions say "named non-generic committees (Cybersecurity Committee, Technology Risk Committee)" are firm-specific, while "Audit Committee" is not because every company has one. A "Risk Committee" is somewhat common but not universal like Audit Committee.

The Risk Committee counts as firm-specific since it's a named committee that isn't universally standard. There are no domain terms meeting the ERM threshold—"data security and privacy" are too generic—and no verifiable facts to extract. This lands at Firm-Specific (Level 3) based on the named Risk Committee.


reasoning: This paragraph is a cross-reference pointing readers to Item 1A for materiality discussion, not itself making a materiality assessment or disclosing substantive cybersecurity content. Per Rule 5, cross-references like 'risks that may materially affect us, see Item 1A' are N/O. No specific facts elevate specificity above Level 1.

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


fact: Named internal program: 'Third Party Program'

reasoning: The paragraph is centrally about how the company manages third-party risk, making Third-Party Risk the clear category. The capitalized 'Third Party Program' is a named internal program, pushing specificity to Firm-Specific, though the remaining language ('identification, measurement, management, monitoring and reporting') is standard ERM boilerplate.

thinking:
Classify this paragraph.

Content: About third-party risk management program - guidance, identification, measurement, management, monitoring, reporting of third party risk.

Category: This is centrally about third-party risk management → Third-Party Risk.

Specificity: "Third Party Program" - is this a named internal program? It's capitalized, suggesting a specific named program. That would be firm-specific. But it's fairly generic naming. Let me think... "Our Third Party Program" - capitalized, suggesting it's a named program. This could be firm-specific.

Actually, the rest is very generic - "identification, measurement, management, monitoring and reporting" - standard ERM language.

The capitalization of "Third Party Program" as a proper noun does suggest it's a specific named program within the firm, even though the terminology itself is fairly standard.


reasoning: The paragraph describes program activities — employee security awareness training and ERM integration — answering 'what does the cybersecurity program do?' → RMP. All language (security awareness training, enterprise risk management framework, key risk indicators, emerging risks) is standard ERM vocabulary that any risk professional would use; nothing passes the ERM test for domain specificity, and there are no firm-specific or verifiable facts.

thinking:
Classify this paragraph.

Content: Security awareness training + ERM integration of cybersecurity.

Category: This describes what the cybersecurity program does - training and ERM integration. RMP.

Specificity: "Security awareness training" - generic, any ERM professional could say this. "key risk indicators" - ERM language. "enterprise risk management framework" - generic ERM. "emerging risks" - generic. No domain terms that pass ERM test, no firm-specific facts, no verifiable claims.

Level 1.


reasoning: The paragraph describes how the Audit Committee and Board oversee cybersecurity risks, including briefing frequency and scope, making it Board Governance. 'Vulnerability assessments' passes the ERM test as a domain-specific security practice, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

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

Specific facts:
- "Audit Committee" - generic, every company has one, NOT firm-specific
- "COO" - not a VP+ security role, generic
- "vulnerability assessments" - domain term (passes ERM test)
- "at least once a year" - generic cadence

Level 2 due to "vulnerability assessments" as a domain term.


reasoning: The paragraph contains both a backward-looking materiality conclusion ('have not...materially affected us') and a forward-looking SEC 106(b)(2) assessment ('reasonably likely to materially affect'), making it squarely Strategy Integration. No domain terms, firm-specific facts, or verifiable claims are present—the negative assertion and forward-looking statement are standard materiality language, and the cross-reference to Item 1A adds no specificity.

thinking:
This paragraph contains two materiality assessments and a cross-reference.

First sentence: backward-looking materiality conclusion → SI
Second sentence: forward-looking "reasonably likely to materially affect" → SI (SEC Item 106(b)(2))
Third sentence: cross-reference to Risk Factors → N/O

The dominant content is SI materiality assessments.

Specificity: The negative assertion "have not identified risks...that have materially affected us" is a self-reported negative → not verifiable. The forward-looking statement is also not verifiable. No domain terms, no firm-specific facts. This is generic boilerplate materiality language.

These are materiality assessments with no domain-specific language, named roles, or verifiable facts—just generic boilerplate at Level 1.


fact: service organization controls reports

fact: Risk Management, Legal and/or Information Security Departments review higher risk and material contracts

reasoning: The paragraph's central topic is how third-party service providers are assessed and overseen for cybersecurity risk, making it Third-Party Risk. Specificity reaches Firm-Specific due to the named departments (Risk Management, Legal, Information Security) involved in contract review, and 'service organization controls reports' is a domain term (SOC reports).

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

Specific facts: "Risk Management, Legal and/or Information Security Departments" - named team composition (firm-specific). "service organization controls reports" - domain term (SOC reports).

No verifiable claims. Firm-specific: the named departments involved.


reasoning: This paragraph is a cross-reference directing the reader to an Item 1A risk factor for materiality discussion — it makes no substantive cybersecurity disclosure itself. Per Rule 5, cross-references like 'risks that may materially affect us, see [elsewhere]' are N/O. No specific facts elevate specificity above Level 1.

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


fact: CISO role

fact: President of Technology role

fact: CISO has over 30 years of industry experience

fact: CISO joined Visa in November 2015

fact: President of Technology joined Visa in November 2013

fact: President of Technology has over 30 years of experience

fact: Zero Trust Architecture

fact: VisaNet

reasoning: The paragraph is entirely about two management figures — their qualifications, experience, tenure, and responsibilities — collapsing to near-nothing under the person-removal test, making it MR. Specificity reaches Level 4 via multiple verifiable claims: specific join dates (November 2015, November 2013) and lower-bound experience figures (over 30 years each).

thinking:
Let me analyze this paragraph.

Content: Describes CISO and President of Technology - their experience, qualifications, when they joined Visa, and responsibilities.

Category: This is about management roles - qualifications, experience, responsibilities. Person-removal test: remove names, titles, qualifications, experience → very little remains. → MR

Specific facts:
- CISO (named role, firm-specific)
- "over 30 years of industry experience" (quantified, verifiable lower bound)
- President of Technology (named role, firm-specific)
- "joined Visa in November 2015" (specific date, verifiable)

- Zero Trust Architecture expertise (domain-specific knowledge)
- Fortune 500 background (other)

This lands at Level 4 given the specific verifiable dates and quantified experience metrics.


fact: layered security model

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

reasoning: The paragraph describes the company's information security program and its approach (layered security model, ERM integration), answering 'what does the cybersecurity program do?' → RMP. References to the CIA triad and a layered security model demonstrate cybersecurity domain knowledge beyond what a generic ERM professional would use, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Category: This describes what the cybersecurity program does at a high level - "deploys a comprehensive and resilient information security program that consists of a layered security model." It's about the program's approach. This is RMP.

Specificity: Let me check for specific facts.
- "layered security model" - this is a concept (defense in depth), but "layered security model" is somewhat generic. Actually, it does suggest domain knowledge about defense-in-depth architecture.
- "confidentiality, integrity, and availability" - the CIA triad, a foundational cybersecurity concept. Does this pass the ERM test? An ERM professional might use these terms too... actually the CIA triad is pretty domain-specific to information security.

- "industry leading hardware, software, and services" - generic
- "enterprise risk management program" - generic ERM term

The CIA triad and layered security model are domain-specific enough that a general ERM professional wouldn't naturally frame things this way. That pushes this to Level 2.


content_category: Incident Disclosure

fact: Cybersecurity incident announced on October 28, 2023

fact: All facilities operational by mid-December 2023

fact: $1.5 million of expenses related to the cybersecurity incident in Q1 fiscal 2024

fact: Incident adversely affected ability to ship orders in first quarter of fiscal 2024

reasoning: The paragraph is anchored by a real cybersecurity incident—announcement date, operational timeline, remediation—making the incident frame dominant per Rule 4, even though it also contains a materiality assessment (SI) and cross-references (N/O). Specificity is Level 4 due to the specific announcement date (October 28, 2023), the quantified $1.5M expense figure, and the mid-December 2023 recovery timeline, all of which are externally verifiable.

thinking:
This paragraph discusses actual incident details and financial impact, plus a materiality assessment.

Let me break it down:
- Cybersecurity incident announced October 28, 2023
- Affected shipping in Q1 fiscal 2024
- Facilities operational by mid-December 2023
- $1.5 million expenses
- Materiality assessment statement
- Cross-references to risk factors

This is mixed ID and SI. The incident details (what happened, timeline, remediation) and the financial impact ($1.5M) are both present. The financial frame is significant but the incident frame is dominant - the paragraph leads with and centers on the incident.

But I'm seeing the materiality statement creates a tension here. The $1.5M cost is clearly SI material, yet the paragraph's structure and emphasis keep the incident itself front and center. The materiality language about not being aware of material risks from cybersecurity threats is pulling toward SI classification, but the dominant framing throughout is still the incident narrative itself. The incident frame is clearly dominant here—the specific dates, dollar amount, and materiality assessment all support the central narrative about what happened and its financial consequences. This hits level 4 specificity with verifiable details like "October 28, 2023," "$1.5 million," and the cross-references to risk factors, so I'm confident this is ID.


reasoning: The paragraph describes developing cybersecurity processes and response plans using outside counsel and third-party providers who serve the company (Rule 3 → RMP, not TP). No domain-specific terminology, firm-specific facts, or verifiable claims are present — 'cybersecurity protection,' 'response plan,' and 'third-party service providers' are all generic ERM-level language.

thinking:
Classify this paragraph.

Content: Working with outside counsel and third-party service providers to develop expertise, processes, procedures for cybersecurity protection and response plan.

Category: This is about what the program does (developing processes/procedures) using third parties as helpers. Third parties are hired to serve the company → RMP per Rule 3.

Specificity: No domain terms beyond generic "cybersecurity protection" and "response plan." No firm-specific facts. No verifiable claims. This is generic boilerplate.


reasoning: The paragraph contains a backward-looking materiality assessment ('prior cybersecurity incidents have not had a material adverse effect on the Partnership's business, financial condition, results of operations, or cash flows'), which is SI per Rule 5. The rest is generic risk speculation and a cross-reference to Item 1A. No domain terms passing the ERM test, no firm-specific facts, and the negative materiality assertion is not externally verifiable, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: States cybersecurity threats could have material adverse effect (generic speculation), then says prior incidents have not had material adverse effect (backward-looking materiality assessment → SI per Rule 5), then cross-references Item 1A.

Category: The key sentence is "prior cybersecurity incidents have not had a material adverse effect" — this is a backward-looking materiality assessment → Strategy Integration per Rule 5.

Specificity: "Have not had a material adverse effect" is a negative self-assertion — not externally verifiable. No domain terms, no firm-specific facts beyond generic language. The cross-reference to Item 1A is just a pointer.

The statement about experiencing and continuing to experience cyber incidents is equally generic, and the cross-reference adds no substantive content. There's no domain-specific terminology or verifiable facts here—just boilerplate language. This is Level 1 materiality.


reasoning: This paragraph is pure speculative risk language ('if any of these security breaches were to occur,' 'could have a material adverse effect') without describing any substantive cybersecurity measures, processes, or assessments. The 'material adverse effect' phrasing is standard 10-K boilerplate speculation (Rule 5: 'could have' ≠ SI). No domain terms, firm-specific facts, or verifiable claims are present.

thinking: This is speculative risk language about potential security breaches and their hypothetical effects. No actual cybersecurity measures are described in detail - just generic "procedures and controls." The "material adverse effect" language is the standard 10-K boilerplate speculation, not an actual materiality assessment.


fact: Chief Information Security Officer (CISO)

fact: Chief Information Officer (CIO)

fact: CISO reports to CIO with open line to Bank President

fact: Internal Technology and Operations Committee

fact: Information Security Department

fact: Management Committee

reasoning: The paragraph describes management organizational structure: CISO reporting to CIO, reporting line to Bank President, and a named internal committee with its own reporting chain to Management Committee. Person-removal test leaves little substantive program content, confirming MR over RMP. Firm-specific due to named roles (CISO, CIO), a named internal committee (Technology and Operations Committee), and specific reporting lines.

thinking:
Classify this paragraph.

Category: This describes management organizational structure - CISO reporting to CIO, cross-functional committee, reporting lines. The person-removal test: remove CISO, CIO, Bank President, committee names - not much substantive program description remains. This is MR.

Specific facts:
- CISO (named_role) - firm-specific
- CIO (named_role) - firm-specific
- Bank President (named_role) - firm-specific level? Bank President is somewhat generic but in context it's a reporting line

- "internal Technology and Operations Committee" (named_committee) - firm-specific
- Management Committee (named_committee) - somewhat generic
- "Information Security Department" (named_team) - firm-specific

The specificity level is 3 (Firm-Specific) because of the named roles and committees that are unique to this organization.


reasoning: The paragraph describes employee training and awareness activities, which are cybersecurity program activities → RMP. Despite the 'Employee Training and Awareness' header, the content is entirely generic — 'mandatory ongoing cybersecurity training' and 'culture of cybersecurity awareness' could describe any company's program with no domain-specific terminology or firm-specific details.


reasoning: The paragraph's central topic is managing cybersecurity risks from third-party service providers, making TP the best fit. The language is entirely generic—'third party risk management program,' 'information technology systems and networks'—all standard ERM vocabulary with no domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

The paragraph talks about relying on IT systems, some managed by third parties, and having a third-party risk management program. The central topic is third-party risk management.

Content category: Third-Party Risk - the paragraph is centrally about managing third-party cyber risks.

Specificity: No domain terms that pass the ERM test. "third party risk management program" is generic ERM language. No firm-specific facts, no verifiable claims. This is Level 1.


reasoning: This paragraph states a backward-looking conclusion that cybersecurity has not materially affected business strategy, results of operations, or financial condition, which is a materiality assessment → SI per Rule 5. The years mentioned (2024, 2023, 2022) are reporting periods anchoring a negative self-assertion, which is not externally verifiable, and no domain terms or firm-specific facts are present, so specificity remains Level 1.

thinking: Materiality assessment paragraph.


reasoning: This is a cross-reference directing readers to Item 1A for materiality discussion, with no substantive cybersecurity content itself. Per Rule 5, cross-references like 'risks that may materially affect us, see Item 1A' are N/O. No specific facts elevate specificity.

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


fact: Facilities operational by mid-December 2023

fact: Adversely affected ability to ship orders in Q1 fiscal 2024

fact: Materiality assessment: not aware of risks that have materially affected business strategy, results of operations, or financial condition

reasoning: While the paragraph references a real incident, its primary purpose is answering how cybersecurity affected the business — shipping disruptions, $1.5M in costs, and a backward-looking materiality assessment — making SI the dominant frame per Rule 4 (financial frame dominant). Specificity is Level 4 due to the specific announcement date (October 28, 2023), verifiable dollar amount ($1.5M), and recovery timeline.

thinking:
Let me analyze this paragraph.

It describes a real cybersecurity incident (October 28, 2023), its impacts ($1.5M expenses, operational disruption), recovery timeline (mid-December 2023), and a materiality assessment. It also has cross-references to risk factors.

Category: This is mixed. It has incident disclosure (what happened), strategy integration (financial impact, materiality assessment), and cross-references (N/O). The dominant frame is about effects and impacts - financial consequences and materiality. But there's significant incident detail too.

Per Rule 4: Mixed with financial frame dominant → SI. The paragraph is titled "Effects and Impacts" and focuses on business/financial impact ($1.5M, affected shipping, materiality statement).

The incident details are really just context for explaining the financial consequences. The core of what they're communicating is the materiality assessment and the $1.5M cost, so this lands in SI territory. The heading and overall structure reinforce that the financial and business effects are what matter here, even though the incident specifics are included to support that framing. me re-read Rule 4: "What happened (timeline, scope, response) → ID. Business/financial impact → SI. Mixed with incident frame dominant → ID. Mixed with financial frame dominant → SI."

The paragraph leads with incident details but quickly pivots to financial impacts and materiality. The title itself says "Effects and Impacts." I think SI is appropriate since the financial frame dominates.

Actually, I think this is more ID. The paragraph tells us what happened, when, recovery timeline, and costs. The costs are part of the incident narrative. The materiality statement is secondary. Let me look again...

The paragraph structure shows incident context followed by business consequences—the cybersecurity event is the setup, but the real focus is on how it affected operations and finances. The materiality assessment clinches it as SI. I'm seeing lots of concrete details too: the October 28 announcement, mid-December recovery window, $1.5 million in Q1 expenses, and the explicit materiality statement. That specificity and quantification puts this at Level 4.


reasoning: The paragraph's central topic is managing cybersecurity risks from third-party service providers, including a dedicated third-party risk management program, making TP the best fit. No domain-specific terminology, firm-specific facts, or verifiable claims are present—'third-party risk management program' is standard ERM language.

thinking:
Classify this paragraph.

The paragraph talks about relying on IT systems, some managed by third parties, and having a third-party risk management program. The central topic is third-party risk management.

Content: mentions third-party service providers and a third-party risk management program. Per Rule 3, vendor oversight as central topic → TP. But let me re-read... it's quite generic. The last sentence makes third-party risk the central focus.

Specificity: No domain terms beyond generic ERM language. "third-party risk management program" - would an ERM professional use this? Yes. No named roles, no specific facts. Level 1.


fact: Prudential's CISO

fact: Prudential's CIO

fact: Operational Risk Management (named organizational unit providing updates)

fact: Prudential (named parent firm in cybersecurity context)

reasoning: The paragraph describes the Board's oversight responsibilities, briefing cadence, and how cybersecurity information flows to the Board from management—squarely answering the Board Governance question. Specificity reaches Firm-Specific due to named roles (Prudential's CISO, CIO), a named organizational unit (Operational Risk Management), and the named parent firm (Prudential), but no externally verifiable claims push it to Level 4.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity - board responsibilities, briefing frequency, how information flows to the board. This is Board Governance.

Specific facts:
- CISO (named role, firm-specific)
- CIO (named role, firm-specific)
- Operational Risk Management (named team/function)
- "at least annually" - generic cadence
- Prudential's CISO/CIO - references parent company Prudential
- Manager and Subadviser - investment fund structure terms

CISO and CIO are firm-specific roles. "Prudential's CISO" references a named firm (Prudential) in cybersecurity context.

The presence of named roles like CISO and CIO combined with the reference to Prudential as the parent company pushes this to Level 3 specificity—firm-specific rather than verifiable at the parent company level.


fact: CISO reports to the full Board

reasoning: The paragraph describes the Board's direct and committee-based oversight of cybersecurity risk, including how information flows from the CISO to the Board, making it Board Governance. The mention of the CISO as a specific leadership role reporting to the Board is firm-specific (Level 3), but no externally verifiable claims are present.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity risks, committee structure, how information flows to the board (CISO reports to Board). This is Board Governance.

Specific facts:
- CISO (named role, firm-specific)
- "At least annually" reporting cadence (generic)
- "prevent, detect, and respond" - generic
- "incident response" concepts mentioned but generic

The CISO is a firm-specific role (VP-level equivalent). That's Level 3.

No verifiable claims (no specific names, certifications, dates of incidents, etc.).


reasoning: The paragraph answers how the board oversees cybersecurity: Board has ultimate oversight, assisted by the Audit Committee, which reports back. All language is generic governance boilerplate — 'enterprise risk management program,' 'resource allocations,' 'oversight structures,' and 'Audit Committee' are standard terms any public company would use, with no domain-specific, firm-specific, or verifiable facts.

thinking:
Classify this paragraph.

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

Specific facts:
- "Audit Committee" - generic, every company has one → NOT firm-specific
- "enterprise risk management program" - generic ERM language → Level 1
- No domain terms that pass ERM test
- No firm-specific facts
- No verifiable facts

Specificity: Generic Boilerplate (Level 1)


fact: CISO updates the Audit Committee quarterly

reasoning: The paragraph primarily answers how the board oversees cybersecurity—describing Audit Committee responsibility, quarterly briefing cadence, information flow to the full Board, and ad hoc engagement—making it Board Governance. The mention of the CISO as the specific role delivering updates is a firm-specific fact (VP+ cybersecurity leadership role), elevating to Level 3, but no verifiable claims push it to Level 4.

thinking:
Classify this paragraph.

Category: This is about board oversight of cybersecurity - Audit Committee oversight, quarterly updates to the board, how information flows. Primary question: "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- "Audit and Risk Committee" (named as "Audit Committee") - this is a standard board committee, not firm-specific
- "CISO" - firm-specific named role (VP+ level)
- "quarterly basis" updates - generic cadence
- "Chair of the Audit Committee" - generic
- "annual education session" - generic cadence

Wait - "CISO" is a firm-specific role.

The "Audit and Risk Committee" is just their standard naming for what every company has, so that doesn't count as firm-specific. Looking at the domain terms like "incident response plan," "cybersecurity threat developments," and "third-party assessments" - these are all generic concepts that don't reveal firm-specific details. The only firm-specific identifier here is the CISO role, which puts this at Level 3.


fact: CFO is the primary person responsible for overseeing the cybersecurity risk management program

fact: Oversight of cybersecurity programs since the second half of 2021

fact: Not a full-time cybersecurity function for the CFO

reasoning: The paragraph primarily describes who is responsible for cybersecurity oversight (CFO), his limitations, and how he is organized to handle it — squarely MR by the person-removal test, as removing the CFO's details leaves almost nothing. The specific timeframe 'since the second half of 2021' is a verifiable claim about when oversight began, pushing to Level 4.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the CFO's role in overseeing cybersecurity, his qualifications (or lack thereof), reporting lines, and reliance on outside IT support. This is about management's organizational role - who is responsible, how they're organized. MR.

Person-removal test: Remove CFO, his experience, his oversight since 2021, his reliance on outside firm → very little substantive program description remains. → MR confirmed.

Specific facts:
- CFO as primary person responsible for cybersecurity → named_role (firm-specific - CFO with cybersecurity responsibility is unusual)

- Oversight beginning in the second half of 2021 → specific_date (verifiable timeframe that could be checked, pushing this toward Level 4)
- Outside IT support firm (unnamed) → not firm-specific


reasoning: The paragraph describes the Fund's processes to assess, identify, and manage cybersecurity risks and notes the Adviser's cybersecurity program — answering 'what does the program do?' making it RMP. All language is generic ERM boilerplate ('processes to assess, identify, and manage material risks,' 'cybersecurity program') with no domain terms, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Describes that the Fund has processes for cybersecurity risk management, notes dependency on Adviser and third-party service providers, and states the Adviser has implemented a cybersecurity program.

Category: This is about what the cybersecurity program does - risk assessment, management. It's generic RMP language. No board oversight (BG), no management roles (MR), third parties are mentioned but not central (TP).

Specificity: Let me check for facts:
- "assess, identify, and manage material risks" → generic ERM language, L1

- References to "Adviser" and "cybersecurity program" are completely generic with no firm names or specific details, and there are no domain-specific terms or verifiable claims that would elevate this beyond boilerplate disclosure language. This is Level 1.


fact: PCI DSS compliance requirements

fact: vulnerability scanning

fact: penetration testing

fact: network assessments

fact: Company is subject to PCI DSS compliance requirements (firm-specific obligation)

fact: Cyber insurance underwriting process involves vulnerability scans

reasoning: The paragraph describes specific cybersecurity assessment activities (vulnerability scanning, penetration testing, network assessments) performed by third parties hired to serve the company, making it RMP per Rule 3. Specificity reaches Level 3 because the company's PCI DSS compliance obligations and the linkage of vulnerability scans to their cyber insurance underwriting process are firm-distinguishing details — not every public company is subject to PCI DSS or structures assessments around insurance underwriting.

thinking:
Classify this paragraph.

Content: Third-party assessments including vulnerability scanning, PCI DSS compliance, penetration testing, network assessments, cyber insurance underwriting.

Category: This describes what the cybersecurity program does - assessments and testing activities. Third parties are hired to serve the company (assessors, pen testers) → RMP per Rule 3.

Specificity: Domain terms: PCI DSS, vulnerability scanning, penetration testing, network assessments. "Cyber insurance underwriting process" - SI-adjacent but it's describing an activity. "PCI DSS compliance requirements" - this is a named framework.

Now I'm checking the cadence and verifiability. "Quarterly vulnerability scanning" gives me a specific frequency, and PCI DSS is a named standard that qualifies as a domain term. Penetration testing and vulnerability scanning both pass the ERM test. The real question is whether anything here is firm-specific - "PCI DSS compliance requirements" does suggest they're actually subject to PCI DSS, which would be firm-specific, and "cyber insurance underwriting process" is a particular program detail. As for what's verifiable, the cadence like "quarterly" or "annual" is generic, but PCI DSS compliance itself could be verifiable, though the statement cuts off before I can fully assess that.

Actually, I'm reconsidering this. The phrase "as part of our PCI DSS compliance requirements" tells me the company has PCI DSS obligations, which is firm-specific information that distinguishes them from companies that don't handle payment card data. That pushes this to Level 3.


reasoning: The paragraph's central topic is assessing and managing cybersecurity threats from third-party service providers, making it TP; the second sentence about communicating threats to management is subordinate. The language is entirely generic—'assesses and manages,' 'information security,' 'review, response, and mitigation'—all fail the ERM test, with no domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

The paragraph discusses managing cybersecurity threats from third-party service providers, then mentions communicating threats to management. The central topic is third-party risk management.

Wait - let me re-read. First sentence: assessing/managing cybersecurity threats from third-party service providers. Second sentence: identified threats communicated to management.

The first sentence is about third-party risk. The second is generic process. The central topic is third-party risk management.

But is it really CENTRAL? It's two sentences - first about third-party, second about general process. I'd say TP is the primary focus.

Looking at the language used, there's nothing specific here - no domain terminology that would meet the ERM test. Terms like "assesses and manages cybersecurity threats," "third-party service providers," and "information security" are all generic without any firm-specific details or verifiable claims. This lands at Level 1.


fact: InfoSec Director role reporting on cybersecurity

fact: eRISC committee as recipient of cybersecurity updates

fact: CTO listed among escalation contacts

reasoning: The paragraph describes information flow from InfoSec Director through eRISC committee to the Board, squarely answering how the board stays informed about cybersecurity — Board Governance. The eRISC committee (a named non-generic committee) and InfoSec Director (Director-level with security qualifier) are firm-specific facts driving Level 3 specificity.

thinking:
Classify this paragraph.

The paragraph describes how the InfoSec Director reports to the eRISC committee and escalates to the Board via CEO, CFO, CTO, GC. The primary question answered is "How does information flow to the board?" → Board Governance.

Specific facts:
- "InfoSec Director" — named role with security qualifier (Director of InfoSec) → firm-specific
- "eRISC committee" — named non-generic committee → firm-specific
- CEO, CFO, CTO, GC — generic roles, not firm-specific

- Direct communication/escalation path described

This is Firm-Specific (Level 3) because of the InfoSec Director and eRISC committee references.


reasoning: This is a section header or risk factor title with no substantive cybersecurity disclosure — it's a generic statement about IT reliance and potential adverse impacts. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: Short header/title paragraph about IT risk, no substantive cybersecurity disclosure.


fact: Bimini identified as the parent/manager entity whose employees serve as executive officers

reasoning: The paragraph explains that as an externally managed company, ORC relies on its Manager's cybersecurity risk processes, making RMP the best fit since it describes how cybersecurity risk management is conducted (via delegation to the Manager). The named entity 'Bimini' is a firm-specific fact that distinguishes this company's arrangement.

thinking: Externally managed company relying on Manager's systems and cybersecurity processes. Mentions Bimini as the parent/manager entity.


reasoning: The paragraph contains both a cybersecurity insurance reference and the classic backward-looking and forward-looking materiality assessment ('have not materially affected and are not reasonably likely to materially affect... business strategy, results of operations or financial condition'), which is the definitive SI trigger under Rule 5. No domain terms pass the ERM test (insurance is a general business concept), no firm-specific facts, and no verifiable claims, keeping specificity at Level 1.

thinking:
Strategy Integration - cybersecurity insurance + materiality assessment statement.

Specific facts: "cybersecurity insurance" is a domain term but actually insurance is a business concept. The materiality assessment is the key SI trigger. "have not materially affected and are not reasonably likely to materially affect" is the classic SI language.

No verifiable facts, no firm-specific facts. The insurance mention is generic. The materiality statement is SI per Rule 5.

Specificity: Level 1 - no domain terms that pass ERM test, no firm-specific facts, no verifiable claims.


reasoning: The paragraph opens with a backward-looking materiality assessment ('have not encountered cybersecurity challenges that have materially impaired our operations or financial standing') and discusses cyber liability insurance — both SI topics per Rule 5. The negative materiality assertion is a non-verifiable self-report, the cross-reference to Item 1A is N/O filler, and 'cyber liability insurance' is standard ERM language that fails the domain expertise test, leaving no facts above Level 1.

thinking:
Let me analyze this paragraph.

Content: States no material cybersecurity incidents, references Item 1A, mentions cyber liability insurance, and discusses insurance limitations.

Category: The paragraph makes a backward-looking materiality assessment ("have not encountered cybersecurity challenges that have materially impaired our operations or financial standing") → SI per Rule 5. It also mentions cyber insurance (SI topic) and a cross-reference (N/O). The dominant content is SI.

Specificity:
- "have not materially impaired our operations or financial standing" → negative self-assertion, NOT verifiable
- "cyber liability insurance policy" → this is a firm-specific fact about having insurance...

The term "cyber liability insurance" is borderline domain-adapted—it's specific enough to insurance and ERM professionals but also broadly understood. The negative materiality assertion itself isn't verifiable per the rules. The cross-reference to Item 1A is just a navigation element. Overall, the paragraph is mostly generic boilerplate, so I'd classify it as Level 1.

But wait—the actual claim here is that PCS maintains a cyber liability insurance policy. That's firm-specific language, but it doesn't really distinguish them since many companies have cyber insurance. The rules require firm-specific facts to narrow down which company wrote it, and this doesn't do that. I'm going to categorize this as Generic Boilerplate / Strategy Integration.


reasoning: The paragraph describes the oversight chain from management to the Board via the Audit Committee, with the CEO responsible for cybersecurity under Audit Committee oversight—this is governance structure, defaulting to BG per Rule 1. No domain-specific terminology, firm-specific facts, or verifiable claims are present; 'Audit Committee' and 'CEO' are generic roles every company has, and 'third-party consultants' are unnamed.

thinking:
Classify this paragraph.

Content: Describes management's responsibility to manage cybersecurity threats and report to the Board. The CEO is primarily responsible under Audit Committee oversight, and uses third-party consultants.

Category: This describes the governance chain - Board → Audit Committee → CEO. The purpose is describing oversight structure and who is responsible. It mentions management's role but in the context of oversight. The CEO role and reporting to the Board... this is a mix of BG and MR. The paragraph describes oversight structure (BG) but also identifies the CEO as primarily responsible (MR). The framing is about oversight structure - "Under the oversight of the Audit Committee" - so BG.

The CEO's responsibility is actually the core focus here. Looking at the specific language: management's duty to manage threats and escalate to the Board signals oversight structure, while the statement that the CEO is primarily responsible for assessment and management is identifying the responsible party. The third-party consultant mention adds a resource management element. Rule 1 suggests governance-chain paragraphs default to BG when framed as oversight, but I need to check if the CEO's primary responsibility pushes this toward MR instead.

Reviewing the rule more carefully—MR applies when management's organizational role is the primary content. The CEO's responsibility is front and center here, though it's still wrapped in the oversight framework. The specificity check confirms this is generic: standard Audit Committee, generic CEO role, unnamed consultants, no domain-specific terminology. This lands at Level 1 Generic Boilerplate.


fact: CISO role

fact: Executive Steering Committee

fact: Committee includes CEO, CFO, EVP Engineering, Senior Director IT, and General Counsel

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity: the CISO's coordination role, the Executive Steering Committee's composition, multidisciplinary team deployment, and reporting lines to the Audit Committee/Board. While program activities are mentioned, the person-removal test leaves mostly generic program language ('protect information systems,' 'monitor prevention, detection, mitigation'). Specificity is Level 3 due to firm-specific facts: the CISO role, the named Executive Steering Committee, and its specific membership composition.

thinking:
Let me analyze this paragraph.

Category: This describes the CISO working with an Executive Steering Committee to implement a cybersecurity program, deploy teams, and monitor threats. The paragraph describes both management organization AND program activities. Let me apply the person-removal test: Remove CISO, Executive Steering Committee members, titles. What remains? "implement a cybersecurity risk management program intended to protect information systems from cybersecurity threats and to promptly respond to any Cybersecurity Events in accordance with incident response and recovery plans... multidisciplinary teams are deployed to provide governance over cybersecurity issues, address cybersecurity threats and to respond to Cybersecurity Events...

The remaining content covers monitoring threat prevention, detection, mitigation and remediation, plus reporting mechanisms to the Audit Committee and Board. So even after removing the people and titles, there's still substantial program substance about what activities happen and how they're tracked. But the paragraph's structure is fundamentally about organizational roles—the CISO coordinates with the Executive Steering Committee, teams get deployed, and there's a clear reporting hierarchy up to the Board. The core question being answered is really about how cybersecurity management is organized and who reports to whom, even though program activities are woven throughout. This looks like it straddles Management/Reporting and RMP categories, with the organizational structure being the primary focus. Looking at the specifics now: the CISO is named, the Executive Steering Committee is firm-specific, and the membership includes the CEO, CFO, EVP Engineering, Senior Director IT, and General Counsel—that's a particular organizational composition. The generic program elements like incident response and prevention don't override the firm-specific governance structure. This lands at Level 3.


reasoning: The paragraph's central topic is how the company manages cybersecurity risks from third-party suppliers, vendors, and service providers, making Third-Party Risk the best fit. The language is entirely generic — CCO is a standard governance role (like CEO/CFO), 'the Adviser' is unnamed, and terms like 'cybersecurity threats' and 'cybersecurity preparedness' fail the ERM test, leaving no facts above Level 1.

thinking:
Let me analyze this paragraph.

Content: Discusses how the company manages cybersecurity risks from third parties (suppliers, vendors, service providers), mentions reliance on Adviser's personnel, and the CCO's oversight role regarding these entities.

Category: The central topic is third-party cyber risk management. It's about how they oversee cybersecurity risks from third parties. → Third-Party Risk

Specific facts:
- CCO (Chief Compliance Officer) - this is a generic role every company has, not firm-specific
- "Adviser" - references a specific entity (likely an investment adviser), somewhat firm-specific

- Risk management, legal, IT, compliance personnel are standard departments across organizations
- "The Adviser" is a defined term pointing to a particular entity but unnamed, which hints at the company's structure as externally advised—somewhat firm-specific but not explicitly named
- Domain terminology like "cybersecurity threats" and "cybersecurity preparedness" are generic industry language
- Overall, this reads as generic boilerplate with no firm-specific details that would pass the ERM test—Level 1 specificity


fact: Do not carry a separate cybersecurity commercial insurance policy

reasoning: The paragraph states a backward-looking materiality conclusion ('have not materially affected') and a forward-looking one ('reasonably likely to materially affect'), both triggering SI under Rule 5. The explicit disclosure that the company does not carry a separate cybersecurity insurance policy is a firm-specific fact distinguishing this company's posture, but no externally verifiable claims are present (negative assertions about incidents are not verifiable).

thinking:
Strategy Integration - materiality assessment plus insurance disclosure.

Specific facts: "do not carry a separate cybersecurity commercial insurance policy" is firm-specific. The materiality statement is SI per Rule 5.

No verifiable facts (negative assertions aren't verifiable). The insurance disclosure is firm-specific.


fact: Dedicated CISO manages the information security program

fact: CISO has more than 20 years of experience

fact: CRO provides periodic reports alongside CISO

fact: RACC (Risk, Audit and Compliance Committee) appoints the CISO and oversees the program

fact: Reports to RACC at least quarterly

fact: Application and product security, cyber defense, information technology compliance among CISO's areas of expertise

fact: Incident response procedures for escalation

reasoning: The paragraph's primary focus is the CISO's role, qualifications, team responsibilities, and reporting lines to the RACC, making Management Role the best fit despite substantial RMP and BG content. Specificity reaches Quantified-Verifiable because 'more than 20 years of experience' is a lower-bound claim checkable against the CISO's career history.

thinking:
Let me analyze this paragraph.

Category: This paragraph covers multiple topics - CISO role/qualifications, reporting to RACC committee, program activities. The person-removal test: removing CISO details, there's still substantial program description (incident response procedures, evaluations, vendor engagement). But the paragraph starts with CISO management, qualifications, reporting lines to RACC. It's a mix of MR and BG and RMP.

The primary question answered: "How is management organized to handle cybersecurity?" - CISO role, qualifications, reporting. But there's also significant RMP content (incident response procedures, program evaluation). And BG content (RACC oversight, reporting to RACC).

Looking at the text distribution, the CISO's role and reporting structure dominate the first half while program activities fill the second half. The grammatical focus keeps returning to the CISO—their experience, their qualifications, their position in the hierarchy—which suggests Management Role is the stronger categorization, though the governance chain with RACC oversight pulls toward BG.

Now examining specificity: the CISO's 20+ years of experience is a quantified lower bound, the named roles (CISO, CRO) and committee (RACC) are all firm-specific, and the quarterly reporting cadence with "at least" qualifier provides some precision. The domain terminology around incident response and cyber defense adds technical grounding, though these are fairly standard terms in the field.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not identified risks...that have materially affected us') and a forward-looking SEC 106(b)(2) statement ('reasonably likely to materially affect us'), both triggering SI under Rule 5. No domain terms, firm-specific facts, or verifiable claims are present; the cross-reference to Item 1A is boilerplate.

thinking: SI materiality rule applies here.


fact: Advisory Committee of the Board of Managers of the general partner

reasoning: The paragraph describes how the Advisory Committee oversees cybersecurity risks, reports to the full Board of Managers, and receives periodic briefings — classic board governance oversight structure. The named 'Advisory Committee of the Board of Managers' is a firm-specific governance body unique to this partnership's structure, elevating specificity to Level 3, but no verifiable claims push it to Level 4.

thinking:
Board governance paragraph about oversight structure.

Specific facts: "Advisory Committee of the Board of Managers" is a named committee with a specific name. This is firm-specific.

No domain terms that pass ERM test - "cybersecurity risks," "risk management," "data privacy incidents," "information security initiatives" are borderline. "Information security initiatives" and "data privacy incidents" are fairly generic. Let me check - "cybersecurity and data privacy incidents" - this is generic language. "Key information security initiatives" - also generic.

No verifiable facts. Firm-specific: the Advisory Committee of the Board of Managers, the governance structure (general partner of our General Partner).


reasoning: The paragraph describes incident response and recovery plans and their periodic testing — program activities → RMP. All language is generic and fails the ERM test ('incident response plan,' 'recovery plans,' 'tested and evaluated on a periodic basis'), yielding Level 1.

thinking:
Classify this paragraph.

Content: Describes incident response and recovery plans, testing them periodically. This is about what the cybersecurity program does → RMP.

Specificity: "comprehensive incident response and recovery plans" - generic. "tested and evaluated on a periodic basis" - generic. "incident response" is commonly confused as L1. "recovery plans" - generic. No domain terms that pass the ERM test. No firm-specific facts. No verifiable claims.

Level 1.


reasoning: The paragraph contains the negative assertion 'To date, we have not had a cybersecurity incident,' which per the SI materiality rule counts as a backward-looking assessment of cybersecurity's impact on the business. The remainder is speculative risk language ('could have a material adverse effect') and a cross-reference to Item 1A, neither of which qualify as SI or any other substantive category. No domain-specific terminology passes the ERM test—'detect and investigate unauthorized attempts,' 'IT assets,' and 'internal processes and tools' are all generic language any ERM professional would use—so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: Mix of risk language, incident history claim, and some process description. The dominant frame is speculative risk ("could have material adverse effect", "risk of cyber incidents is prevalent") with a cross-reference to Risk Factors. There's a claim "To date, we have not had a cybersecurity incident" and some generic process description.

Category: The "could have material adverse effect" is speculation per Rule 5 (NOT SI). "To date, we have not had a cybersecurity incident" is a negative assertion - per Rule 5, "Have not experienced any material cybersecurity incidents" → SI.

The key tension here is that while the paragraph contains a negative assertion about incident history, most of the content is speculative risk language and cross-references. The negative assertion itself isn't qualified with "material," making it a backward-looking factual claim that counts as SI, but it's embedded within a paragraph dominated by non-SI speculation and regulatory risk discussion. the negative assertion is the strongest signal here, but the rest is generic boilerplate without any domain-specific language or named frameworks that would elevate it. "IT assets" and "unauthorized attempts" are too vague to meet the ERM test, so this lands at Level 1.


fact: penetration testing

fact: offensive testing

fact: maturity assessments

fact: cyber phishing tests

reasoning: The paragraph describes what the cybersecurity program does — assessments, third-party due diligence, incident response, training, and phishing tests — making it RMP. Third-party oversight is one component among many, not the central topic. Domain terms like penetration testing, offensive testing, and phishing tests pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Describes cybersecurity program activities - penetration testing, offensive testing, maturity assessments, third-party due diligence, incident response, employee training, phishing tests. This is about what the program does → RMP.

Third-party risk is mentioned but as one component among many → RMP per Rule 3.

Specific facts:
- penetration testing → domain term
- offensive testing → domain term
- maturity assessments → domain term
- cyber phishing tests → domain term
- incident response program → borderline, but "incident response" is common ERM language...

However, "cyber phishing tests" clearly passes the ERM test. The domain-specific terms here are penetration testing, offensive testing, and phishing tests. There's no firm-specific information beyond a generic program description—no named roles or verifiable claims. This lands at Domain-Adapted specificity, Level 2.


fact: October 3, 2024, cybersecurity incident involving unauthorized activity within IT networks

reasoning: The paragraph briefly references a real incident (Oct 3, 2024) but its primary purpose is the materiality assessment — 'has not experienced a cybersecurity incident that has resulted in a material impact to the Company's financial condition, results of operations, cash flows, or business strategy' — a backward-looking SI conclusion per Rule 5, with the remainder being cross-references. The specific date of October 3, 2024 tied to a publicly disclosed real cybersecurity event is externally verifiable, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

Content: Mixed paragraph that references a real incident (October 3, 2024), makes a materiality assessment, and cross-references other sections.

Category analysis:
- References a real cybersecurity incident (Oct 3, 2024) → ID
- States materiality conclusion ("has not experienced a cybersecurity incident that has resulted in a material impact") → SI
- Cross-references to other sections → N/O
- General intro about evolving threats → N/O

The materiality assessment is a clear SI trigger per Rule 5. The incident is mentioned but briefly - it's referenced rather than described in detail.

The paragraph's main thrust is that threats are evolving, we had an incident, but no material impact, with details elsewhere. The materiality conclusion is a backward-looking SI assessment per Rule 5, while the real incident disclosure (Oct 3, 2024, unauthorized activity) triggers Rule 4 - but since the materiality assessment and cross-references dominate over any detailed description of what happened, I'm categorizing this as SI.

The specificity here matters: October 3, 2024 is a concrete date tied to a real, externally verifiable incident of unauthorized activity in our IT networks. That pushes this to Level 4.


reasoning: The paragraph states generic risk language about hacking and system security without describing any cybersecurity program, governance structure, or materiality assessment — it reads as a general risk caveat rather than substantive disclosure. No domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

This is generic risk language about cybersecurity threats. No specific measures, no program details, no assessment of materiality impact. Just generic statements about risks.

"Could have" style speculation + generic statements. No substantive cybersecurity disclosure.

This is None/Other - no substantive cybersecurity content, just generic risk language.


reasoning: The paragraph centrally addresses how the company manages third-party cybersecurity risks through vendor assessments and contractual requirements, making TP the clear category. The language is entirely generic — 'assess their cybersecurity practices,' 'cybersecurity requirements in our contracts,' 'certain cybersecurity standards and protocols' — with no domain-specific terms, named standards, firm-specific details, or verifiable claims.

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


reasoning: The paragraph describes the company's engagement of external firms to conduct cyber risk assessments and resulting network upgrades — these are program activities (what the program does), and the third parties are hired to serve the company (assessors → RMP per Rule 3). Despite mentioning timeframes ('During 2024', 'In early 2025'), these are soft/generic timeframes not tied to specific verifiable dates; the third-party firms are unnamed; and terms like 'cyber risk assessment' and 'network upgrades' fail the ERM test as any enterprise risk professional could use this language, leaving no facts above Level 1.

thinking:
Classify this paragraph.

Content: Company engaged third-party firms for cyber risk assessments in 2024 and early 2025, made upgrades based on recommendations.

Category: This is about risk management processes - what the cybersecurity program does (risk assessments, upgrades). The third parties are hired to serve the company (assessors), so per Rule 3 → RMP.

Specific facts:
- "annual cyber risk assessment" - domain term? "risk assessment" is listed as L1 (fails ERM test).

- "2024" and "early 2025" - these are timeframes but not specific dates tied to verifiable events
- "third-party technology firm" and "independent cyber security firm" - unnamed, not firm-specific
- "upgrades being made to the Company's network" - generic

Looking at the language more carefully, "cyber risk assessment" and "network upgrades" are both too generic to pass the ERM test. There aren't any domain-specific terms that would elevate this beyond boilerplate language, so this lands at Level 1 - Generic Boilerplate.

The timeframes like "During 2024" and "In early 2025" are soft and unverifiable, and "annual" is just a standard cadence descriptor. This confirms it's Level 1 with no firm-specific facts or substantive claims.


reasoning: The paragraph's central topic is requirements imposed on third-party service providers regarding security measures, access to systems, and breach reporting—squarely Third-Party Risk. The language is entirely generic ('appropriate security measures,' 'consistent with all applicable laws,' 'reasonable security measures') with no domain-specific cybersecurity terms, firm-specific details, or verifiable claims, keeping it at Level 1.

thinking:
Classify this paragraph.

This is about requirements imposed ON third-party service providers regarding security measures. Central topic is third-party risk management.

Content category: Third-Party Risk (requirements imposed on vendors)

Specific facts: Let me scan for domain terms, firm-specific facts, verifiable claims.

The paragraph describes requiring third parties to confirm security measures, comply with laws, maintain reasonable security, and report breaches. This is generic vendor oversight language - no domain-specific cybersecurity terms (fails ERM test), no firm-specific details, no verifiable claims.

This falls into generic boilerplate territory - standard language you'd see in any vendor agreement without specialized detail or company-specific context.


fact: CISO role chairs the Cybersecurity Steering Committee

fact: Cybersecurity Steering Committee

fact: One director is the President of a major cybersecurity services provider

reasoning: The paragraph primarily answers how the board oversees cybersecurity—board education, reports on risks/threats, Audit Committee expertise, and how information flows from the CISO/Steering Committee to the board—making it BG. Specificity reaches Level 3 via the named CISO role, the Cybersecurity Steering Committee, and the specific claim about a director being president of a cybersecurity services provider, but no externally verifiable facts push it to Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes both the CISO's role chairing the Cybersecurity Steering Committee and board oversight. The paragraph covers: CISO meetings for strategic updates, updates to Board, Board education, Audit Committee expertise. The primary question answered is "How does the board oversee cybersecurity?" - board receiving updates, board education, board member expertise. The CISO/Steering Committee part is about information flow TO the board. This is BG.

Specific facts:
- CISO (named_role) - firm-specific

- Cybersecurity Steering Committee (named_committee) - firm-specific
- One Audit Committee director leads a major cybersecurity services provider - firm-specific claim without a named individual
- Audit Committee - generic reference

The firm-specific Level 3 facts are the CISO role, the Cybersecurity Steering Committee, and the claim about the director's external cybersecurity leadership position. There are no verifiable facts like names, numbers, or certifications provided.

Specificity: Firm-Specific (Level 3)


reasoning: This paragraph describes the general cyber threat landscape without any disclosure about the company's own cybersecurity program, governance, or incidents. It contains no domain-specific terms beyond generic references (malware, viruses) that any business professional would use, and no firm-specific or verifiable facts.

thinking: Generic risk landscape description, no company-specific content.


fact: CISO role

fact: CISO has served in the role since 2015

fact: Application security, intrusion detection, penetration testing, complex threat modeling, unconventional cyber-attack vectors as areas of experience

fact: RCOC (Risk and Compliance Oversight Committee or similar named committee)

reasoning: The paragraph centers on the CISO's qualifications, experience, team oversight, and reporting to a named committee — primarily answering 'how is management organized?' Person-removal collapses most content, confirming MR. Specificity reaches Level 4 because 'served in the role since 2015' is a verifiable tenure claim checkable against employment records, alongside domain terms (penetration testing, intrusion detection, threat modeling) and the firm-specific RCOC committee.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the CISO's role, qualifications, team, and reporting. The person-removal test: remove CISO, titles, qualifications, experience, reporting lines, team composition. What remains? "assessing, identifying and managing cybersecurity threats on a day-to-day basis" and briefing on "information security matters and discuss cybersecurity risks generally." The paragraph collapses substantially - it's primarily about WHO (the CISO), their qualifications, their team, and reporting lines. → MR

Specific facts:
- CISO (named_role) → L3

- Started in 2015, which is a verifiable date → L4
- Expertise spans application security, intrusion detection, penetration testing, threat modeling, and unconventional attack vectors → domain-specific terms → L2
- Information security team mentioned but lacks specificity without headcount details
- RCOC is a named committee → L3
- Quarterly cadence for RCOC meetings is generic without more context

The 2015 start date is checkable, making it a strong L4 claim.


reasoning: The paragraph describes the responsibilities of the CFO and Head of IT in managing cybersecurity, making it about management roles and responsibilities. Person-removal test confirms: removing the titles leaves generic responsibilities (hiring, budgets, approving processes) with no substantive program description. 'Head of IT' is below VP level without a security qualifier, so not firm-specific; all listed responsibilities are generic management activities that fail the ERM test for domain terminology.

thinking:
Classify this paragraph.

Category: This describes management roles (CFO and Head of IT) and their responsibilities. Person-removal test: remove "Our Chief Financial Officer and Head of IT" — what remains is a list of responsibilities (hiring, integrating risk, communicating priorities, approving budgets, preparing for incidents, approving processes, reviewing assessments). These are generic management responsibilities, not detailed program activities. The paragraph is about WHO is responsible and WHAT they're responsible for. This is MR.

Specificity:
- "Chief Financial Officer" — generic, every company has one
- "Head of IT" — below VP level, no security qualifier → not firm-specific

- The responsibilities listed are generic management activities with no domain-specific terminology, no firm-specific facts, and no verifiable claims. This is Level 1.


fact: threat assessments

reasoning: The paragraph describes engaging external experts (consultants, auditors) to support the company's own cybersecurity program — third parties hired to serve the company → RMP per Rule 3. The language is largely generic boilerplate ('specialized knowledge,' 'industry best practices'), but 'threat assessments' is a domain-specific security practice that passes the ERM test, nudging specificity to Level 2.

thinking:
Classifying this paragraph.

Category: This is about engaging third parties to support the company's cybersecurity program. The third parties here are hired to serve the company (assessors, consultants) → Rule 3 says this is RMP, not TP.

Specificity: Let me scan for facts.
- "cybersecurity consultants" - generic, not named
- "regular audits, threat assessments" - "threat assessments" passes ERM test as domain terminology
- "risk management systems" - generic ERM language
- "security enhancements" - generic

"Threat assessments" - would a non-security ERM professional use this? Possibly not in this specific form.

The language here is mostly boilerplate about hiring external experts, with "threat assessments" being the only somewhat domain-specific term, though it's borderline. I think this barely qualifies as Level 2 specificity.


reasoning: The paragraph centrally addresses how third-party service providers, suppliers, and external partners are managed for cybersecurity risk, making Third-Party Risk the primary category. Despite the capitalized 'Vendor Management program,' the language is entirely generic ERM terminology (vendor management, third-party service providers, audit functions) with no cybersecurity domain terms, firm-specific distinguishing details, or verifiable claims.

thinking:
Classify this paragraph.

Content: Vendor Management program for third-party service providers, suppliers, external partners with access to confidential information. Verified by internal and external audit.

Category: This is centrally about managing third-party cyber risks → Third-Party Risk.

Specific facts:
- "Vendor Management program" - named internal program? It's somewhat generic but capitalized, suggesting a named program. I'll consider it firm-specific.
- "independent internal and external audit functions" - generic process description.

Actually, "Vendor Management program" is capitalized but it's a very generic name. Every bank has vendor management.

The name "Vendor Management program" lacks the distinguishing identifiers needed to qualify as firm-specific—it's standard terminology that any organization would use. The supporting language around vendor management, third-party service providers, and audit functions are all boilerplate ERM concepts without domain-specific details. This falls into Level 1 - Generic Boilerplate.


fact: NIST CSF used as guide for program design and assessment

reasoning: The paragraph describes how the company designs and assesses its cybersecurity program using NIST CSF, which is a program activity → RMP. NIST CSF is a named cybersecurity framework (Domain-Adapted), but the explicit disclaimer that this does not mean meeting any particular standards prevents it from being a verifiable certification claim.

thinking:
Classify this paragraph.

Content: Describes using NIST CSF as a guide for their cybersecurity program design and assessment, with a disclaimer that it doesn't mean meeting particular standards.

Category: RMP - describes what the program does (uses NIST CSF as framework for risk management)

Specificity: NIST CSF is a named framework → Domain-Adapted (Level 2). The paragraph explicitly says "aligned with" not "certified" so it's not verifiable. Level 2.