fact: Information Security Steering Committee ("ISSC") — named management-level committee

fact: Committee composed of executives from Legal, Accounting, Internal Audit and Risk Management, Cybersecurity and Facilities departments

fact: Services agreement with LMC for establishing the committee

reasoning: The paragraph describes a management-level committee (ISSC), its departmental composition, and its oversight scope — this is about how management is organized (MR per Rule 1: management-level committee about structure/membership). Specificity is Level 3 due to the named committee (ISSC), specific departmental membership, and the firm-specific LMC services agreement reference.

thinking:
Let me analyze this paragraph.

Content: Describes a management-level committee (ISSC) with its composition and responsibilities. This is about how management is organized to handle cybersecurity - the named committee, its membership departments, and oversight scope.

Category: This is a management-level committee (Information Security Steering Committee). Per Rule 1, management-level committees → MR if about structure/membership. This paragraph describes the committee's composition and oversight responsibilities, so MR.

Specificity:
- "Information Security Steering Committee ("ISSC")" → named committee, firm-specific

- The committee draws from Legal, Accounting, Internal Audit and Risk Management, Cybersecurity and Facilities departments, plus there's a services agreement with LMC involved - all firm-specific organizational details. The risk categories they oversee (information security, fraud, vendor, data protection and privacy, business continuity and resilience) are standard risk domains rather than unique terminology.

This is Level 3 - Firm-Specific.


content_category: Incident Disclosure

fact: February 2023 ransomware attack

fact: ransomware attack

fact: unauthorized release of sensitive personal information of current and former employees

fact: expenditures to scan leaked files, notify individuals, and provide free credit monitoring

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes the consequences and remediation of an actual cybersecurity incident (the February 2023 ransomware attack), including data exfiltration scope and specific remediation steps, making it Incident Disclosure. 'February 2023' is a specific date tied to a real, publicly known ransomware event at B&G Foods, which is externally verifiable, elevating specificity to Level 4.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classifying this paragraph about B&G Foods' cybersecurity disclosure.

This describes what happened in a real cybersecurity incident - the February 2023 ransomware attack, its consequences (unauthorized release of personal information), and remediation actions taken. It references a real event with specific details.

Category: This is about what happened - timeline, scope, response, remediation. That's Incident Disclosure. There's mention of expenditures but the frame is about what happened and what they did in response, not a financial/business impact assessment.

Specific facts:
- "February 2023" - specific date

- "ransomware attack" - domain term
- "credit monitoring" - remediation measure
- Named the type of data compromised (sensitive personal information)

The February 2023 ransomware attack is a publicly reportable event that could be verified, making this clearly an incident disclosure with verifiable specificity.


content_category: None/Other

reasoning: The paragraph states regulatory context (subject to banking oversight) and cross-references another section for details, without providing any substantive cybersecurity disclosure itself. No specific facts elevate specificity above Level 1.

thinking: Regulatory context + cross-reference. No substantive cybersecurity disclosure.


content_category: Strategy Integration

reasoning: The paragraph states conclusions about whether cybersecurity risks have materially affected business strategy/operations/financial condition and asserts no material incidents occurred — both are materiality assessments triggering SI under Rule 5. No domain terms, firm-specific facts, or verifiable claims are present; negative self-assertions about absence of incidents are not externally verifiable.

thinking: Materiality assessment paragraph.


content_category: Risk Management Process

reasoning: The paragraph describes the company's incident response plan and its components (roles, responsibilities, recovery steps), which answers 'what does the cybersecurity program do?' → RMP. The language is entirely generic — 'incident response plan,' 'roles, responsibilities,' and 'steps to recover' are all standard ERM vocabulary with no domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Describes an incident response plan with roles, responsibilities, and recovery steps. This is about what the cybersecurity program does → RMP.

Specificity: "incident response plan" - this is generic (L1 per the rules). "defining roles, responsibilities, and steps to recover" - generic process language. No domain terms that pass the ERM test, no firm-specific facts, no verifiable claims.

Level 1.


fact: CSO (Chief Security Officer) role leading cybersecurity program implementation

reasoning: Person-removal test: removing the CSO and executive leadership references leaves a substantive description of the cybersecurity program (protecting systems, incident response, multidisciplinary teams), so this is RMP rather than MR. Specificity is Firm-Specific due to the CSO title (VP-level security role), but no verifiable claims or domain-specific terminology beyond generic program language.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes what the CSO does and how the program is organized. The person-removal test: remove CSO and executive leadership team references. What remains? "implement a cybersecurity program designed to protect information systems from cybersecurity threats and to promptly respond to any cybersecurity incidents in accordance with incident response and recovery plans. multidisciplinary teams throughout the Company are deployed to address cybersecurity threats and respond to cybersecurity incidents." Substantive program description remains → RMP.

Specificity:
- "CSO" (Chief Security Officer) → firm-specific named role (VP+ level)

- "multidisciplinary teams" → generic
- "incident response and recovery plans" → L1 (generic)
- "cybersecurity program" → generic

The CSO is a firm-specific fact (Level 3). No verifiable claims. No domain terms that pass the ERM test - "incident response and recovery plans" is borderline but listed as commonly confused L1. Level 3 due to CSO.


fact: Deutsche Bank Group runs security incident management covering the company

fact: DWS as intermediary entity with communication protocol to notify the company

fact: Involvement of compliance, legal and data privacy teams in incident management

category_confidence: medium

reasoning: The paragraph describes security incident management processes—response to cyberattacks, communication protocols, notification procedures—making RMP the best fit as it answers 'what does the cybersecurity program do?' Deutsche Bank Group and DWS are named entities running the program, and the specific team composition (compliance, legal, data privacy) elevates this to Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes Deutsche Bank Group's security incident management process, including response to cyber events, involvement of compliance/legal/data privacy, and communication protocol for notifying RREEF if their data is at risk.

Category: This is about how a parent/affiliated entity (Deutsche Bank Group/DWS) manages cybersecurity incidents and notifies the company. It describes incident response processes and communication protocols. This is RMP - describing what the cybersecurity program does (incident management, response processes). Could also be TP since Deutsche Bank Group is managing cyber risk on behalf of the company. But Deutsche Bank Group is the parent company managing security for subsidiaries - this is more about the program's incident management process.

Actually, I'm settling on RMP as the right category since it's fundamentally describing the incident management processes and response procedures that the Deutsche Bank Group cybersecurity program executes, including how they notify RREEF when data is at risk. The specificity here is solid too—I've got named entities like Deutsche Bank Group and DWS, plus firm-specific details about which teams get involved in incident response.


content_category: Management Role

fact: CISO role responsible for information security program

fact: CRO oversees risk function including information security

fact: CISO reports to CRO

fact: CRO oversees information security, compliance, legal, operational (business continuity, model risk, third party risk), and enterprise risk areas

fact: CISO has over 18 years of experience in information technology leadership

type: quantified

fact: Eight years of experience in leading information security oversight

reasoning: The paragraph centers on management roles (CISO, CRO), their reporting relationship, responsibilities, qualifications, and team composition — classic MR content per the person-removal test. Specificity reaches Level 4 due to quantified experience claims ('over 18 years,' 'eight years') which are lower-bound verifiable against employment records.

thinking:
Classify this paragraph.

Category: This is about management roles - CISO, CRO, their responsibilities, reporting lines, qualifications, team composition. Person-removal test: remove names/titles/qualifications and very little remains except generic program description. → MR

Specific facts:
- CISO (named role, firm-specific)
- CRO (named role, firm-specific)
- Reporting line: CISO reports to CRO
- CRO oversees information security, compliance, legal, operational (business continuity, model risk, third party risk), enterprise risk

- Leadership experience is quantified: over 18 years in IT leadership, with eight years specifically in information security oversight. The team's qualifications are described more vaguely as "various" degrees and certifications, making them less verifiable. This pushes the specificity to Level 4.


content_category: Board Governance

reasoning: The paragraph describes how the Audit Committee oversees cybersecurity risks through annual briefings and ERM matrix reviews, squarely answering 'how does the board oversee cybersecurity?' → Board Governance. The vocabulary (risk assessment, risk management, control decisions, service provider arrangements, test results, security incidents) is entirely standard ERM language that any non-security risk professional would use; no cybersecurity domain terms pass the ERM test, no firm-specific facts (Audit Committee and Risk Committee are generic board-level entities), and no verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Audit Committee briefed on cybersecurity risks annually, reviews ERM matrix, assessment of compliance with cybersecurity policies including various topics.

Category: This is about board-level oversight (Audit Committee) - how the board oversees cybersecurity. → Board Governance

Specific facts:
- "Audit Committee" - generic, every company has one → NOT firm-specific
- "at least once each calendar year" - generic cadence
- "Risk Committee" - this could be a named committee... but "Risk Committee" is fairly generic at the board level. Actually, per the rules, board-level committees like Audit Committee and Risk Committee → BG.

The language throughout is standard enterprise risk management terminology—risk assessment, risk management, control decisions, service provider arrangements, test results, security incidents—all generic ERM concepts rather than domain-specific cybersecurity vocabulary. The "Enterprise risk management matrix" is also a standard ERM framework. Even "Risk Committee" presenting to the Audit Committee doesn't signal a firm-specific structure; it's a fairly common board-level arrangement.

Looking at this holistically, there are no domain terms that would pass the ERM test, no firm-specific facts, and no verifiable claims. This is Level 1 generic boilerplate.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risk, briefing frequency, and integration with enterprise risk — squarely answering 'how does the board oversee cybersecurity?' → Board Governance. No domain-specific terminology passes the ERM test ('cybersecurity risk management program,' 'enterprise risk' are generic), 'Audit Committee' is not firm-specific, and 'at least once each year' is a generic cadence — leaving no facts above Level 1.

thinking:
Classify this paragraph.

Category: Board/Audit Committee oversight of cybersecurity risks, briefing frequency → Board Governance.

Specific facts:
- "Audit Committee" — every company has this, NOT firm-specific
- "at least once each year" — generic cadence, not firm-specific
- No domain terms that pass the ERM test
- No verifiable facts

Specificity: Level 1 — Generic Boilerplate


reasoning: The paragraph's primary purpose is stating materiality conclusions — that no cybersecurity threats have materially affected business strategy, results of operations, or financial condition, and none are reasonably likely to do so. This is the SEC Item 106(b)(2) backward-and-forward-looking assessment, making it Strategy Integration. Despite mentioning insurance coverage and preventative measures, all language is generic boilerplate with no domain terms, firm-specific facts, or verifiable claims.

thinking: Strategy Integration - materiality assessments present.


fact: vulnerability scans

fact: penetration tests

reasoning: The paragraph primarily answers what the cybersecurity program does — risk assessment methodology, tools, monitoring, and testing — making it RMP. The opening sentence about business/financial impact is scene-setting, not a materiality assessment. Specificity reaches Level 2 via 'vulnerability scans' and 'penetration tests,' which pass the ERM test as security-specific practices, but nothing firm-specific or verifiable is present.

thinking:
Classify this paragraph.

Category: It describes what the cybersecurity program does - risk assessment, tools, vulnerability scans, penetration tests. This is RMP.

Specificity: Let me scan for facts.
- "vulnerability scans" - domain term (passes ERM test)
- "penetration tests" - domain term (passes ERM test)
- The rest is generic boilerplate language.

No firm-specific facts, no verifiable claims. Level 2.


content_category: Third-Party Risk

fact: VRM (Vendor Risk Management) referenced as a named internal function performing vendor due diligence

specificity_confidence: medium

reasoning: The paragraph is centrally about requirements imposed on high-risk and vital vendors—reviewing their information security controls, DR/BC programs, and geographic risk—making it Third-Party Risk. The named internal function 'VRM' elevates specificity to Firm-Specific, though the due diligence factors themselves (third-party audit, DR/BC, country risk) are fairly standard and do not demonstrate deep cybersecurity domain expertise beyond ERM-level vocabulary.

thinking:
Classifying this paragraph about vendor risk management due diligence.

Category: This is centrally about requirements imposed ON vendors - reviewing vendor's security controls, DR/BC programs, geographic risk. This is Third-Party Risk.

Specificity: "VRM" is a named team/function (Vendor Risk Management). "third-party audit" of information security controls, disaster recovery, business continuity - these are somewhat generic. "VRM" as a named internal function is firm-specific? It's an abbreviation for what appears to be an internal team. Let me think... "VRM" refers to a specific internal function/team.

The specific evaluation criteria—third-party audits of security controls, disaster recovery and business continuity testing, geographic risk assessment—are fairly standard practices across the industry, even though "VRM" as a named internal team suggests some firm-specificity. The terminology itself is generic enough that I'd lean toward this being moderately specific rather than highly firm-specific. The proper noun usage of "VRM" as a specific organizational unit within this company does qualify it as firm-specific under the rules, so I'll classify this as Third-Party Risk, Firm-Specific (Level 3).


fact: National Institute of Standards and Technology (NIST) framework

type: framework

fact: Center for Internet Security Controls

reasoning: The paragraph describes the foundation of the cybersecurity program—frameworks and standards it is based on—making it RMP. Named frameworks (NIST, CIS Controls) are domain-specific terms that pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Category: It describes the cybersecurity risk management program's basis on frameworks. This is about what the program does/how it's structured → RMP.

Specificity:
- NIST → named framework, domain term (Level 2)
- Center for Internet Security Controls (CIS Controls) → named framework, domain term (Level 2)
- "enterprise risk management program" → generic ERM language
- No firm-specific facts, no verifiable claims

Level 2.


reasoning: The paragraph's central assertion is a backward-looking materiality conclusion ('risks from cybersecurity threats have not materially affected our Company'), which maps to Strategy Integration under Rule 5. No domain terms passing the ERM test, no firm-specific facts, and the negative materiality assertion is not externally verifiable, keeping specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: States defensive measures exist, acknowledges past incidents without detail, concludes risks haven't materially affected the company, cross-references Item 1A.

Category: The key statement is "risks from cybersecurity threats have not materially affected our Company" — this is a backward-looking materiality assessment → SI per Rule 5.

Specificity: "have not materially affected" is a negative self-assertion, not externally verifiable. No domain terms, no firm-specific facts, no verifiable claims. The cross-reference to Item 1A is N/O content. "cyber-attacks" is generic. No domain terms that pass the ERM test.

Level 1.


fact: DISH TV and SLING TV services remained operational during the incident

fact: As of March 31, 2023, all significant systems had been restored

reasoning: The paragraph describes the status and resolution of an actual cybersecurity incident (services operational, systems restored, incident concluded), making it Incident Disclosure. The specific date 'March 31, 2023' for system restoration and named services (DISH TV, SLING TV) are externally verifiable facts, elevating to Quantified-Verifiable.

thinking: Incident disclosure about a real cybersecurity event.


reasoning: The paragraph describes the governance chain from IT employee → CEO → Board, with the purpose of explaining how cybersecurity risk information flows upward to the board, fitting BG. No domain terms pass the ERM test ('prevention, detection, mitigation and remediation' is generic risk language), 'CEO' is not firm-specific, and 'information technology employee' is not a VP+ role, so specificity remains Level 1.

thinking:
Classify this paragraph.

Content: IT employee monitors systems, prevention/detection/mitigation/remediation of incidents, consults with CEO, CEO reports to Board.

This describes a governance chain - IT employee → CEO → Board. The purpose is describing oversight structure and how information flows. It's a mix of BG (how info flows to board) and MR (management roles). The primary frame is the oversight/reporting structure. The governance chain description with board reporting makes this BG per Rule 1.

Specificity:
- "CEO" - generic, every company has one

- "prevention, detection, mitigation and remediation" - these are generic process terms, not domain-specific
- "cybersecurity incidents" - generic
- "information technology employee" - not a VP+ role, not firm-specific
- No domain terms that pass the ERM test - "prevention, detection, mitigation and remediation" could apply to any risk domain

This is Level 1 - Generic Boilerplate.


fact: vulnerability assessments

fact: information security

reasoning: The paragraph describes how the Board and Audit Committee oversee cybersecurity risk, including briefing content and escalation thresholds, with the Executive Director of IT reporting up — classic Board Governance. Domain terms like 'vulnerability assessments' and 'information security' pass the ERM test, elevating to Level 2, but the Executive Director of IT title lacks a security qualifier and is below VP level, so it does not qualify as firm-specific.

thinking:
Classify this paragraph.

Category: Board/Audit Committee oversight of cybersecurity risks, briefing frequency, how information flows to the board, mentions Executive Director of IT at the end but in context of reporting to the board. This is Board Governance.

Specific facts:
- "Audit Committee" — generic, every company has one → not firm-specific
- "vulnerability assessments" — domain term, passes ERM test
- "Executive Director of IT" — This is a named role. Not VP-level or above, and no security qualifier. "Executive Director of IT" — hmm, this isn't a standard VP/SVP/EVP title.

Now I'm checking the title rules more carefully. "Executive Director of IT" is a Director-level position without a security qualifier, so it doesn't meet the firm-specific threshold. The domain term "vulnerability assessments" still passes though.

For the ERM test, "threat environment" seems like something a general ERM professional might use, and "information security" is clearly a domain term that qualifies. Based on these domain-specific terms, this falls into Level 2 (Domain-Adapted).


reasoning: The paragraph's primary purpose is a materiality assessment — stating that no risks have materially affected or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which is the SEC Item 106(b)(2) formula triggering SI under Rule 5. The remainder is a cross-reference to Item 1A and generic forward-looking disclaimer. No domain terms passing the ERM test, no firm-specific facts, and the negative materiality assertion is not externally verifiable, so specificity stays at Level 1.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. A materiality assessment statement - "has not identified any specific risks...that have materially affected or are reasonably likely to materially affect" → SI (Rule 5)
2. A cross-reference to Item 1A → N/O
3. Generic forward-looking disclaimer → N/O

The materiality assessment is the substantive content here. It's a backward-looking and forward-looking materiality conclusion per Rule 5 (both "have materially affected" and "reasonably likely to materially affect"). This is SI.

The materiality statement itself is just a negative assertion without verifiable support, and the rest is boilerplate language about information systems with no firm-specific details or domain-specific terminology that would meet the ERM test. This lands at Level 1.


fact: March 2023 specific date of incident

fact: $2.7 million loss recognized (net of funds recovered and professional fees)

fact: Independent forensic investigation conducted

fact: Audit committee informed and provided regular updates

reasoning: This paragraph describes an actual cybersecurity incident — fraudulently-induced wire transfers in March 2023 — including timeline, response actions, and outcome, making it Incident Disclosure. The $2.7 million loss figure and March 2023 date are externally verifiable facts, elevating specificity to Quantified-Verifiable.

thinking: Incident disclosure with specific details.


fact: Disclosure that there are currently no third parties that could introduce significant cybersecurity risk

reasoning: The paragraph is centrally about managing cybersecurity risks from third-party service providers—selection, diligence, monitoring, and contractual requirements—making it Third-Party Risk. The unique admission 'although there are currently none' distinguishes this company's posture from generic boilerplate, elevating specificity to Firm-Specific.

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

Specific facts: The paragraph mentions contractual requirements, cybersecurity audits, diligence on third parties, monitoring. These are generic process descriptions. "there are currently none" is a firm-specific admission. But the language is mostly generic - "perform diligence," "continually monitor," "cybersecurity audits."

Let me check for domain terms vs ERM-generic: "cybersecurity threat risks," "cybersecurity audits," "diligence on third parties" - these are fairly generic. "cybersecurity audits" could pass ERM test marginally but it's borderline.

The key differentiator here is that admission about having no current third-party vendors - that's a concrete, firm-specific detail that elevates this beyond generic risk management language. So I'd classify this as firm-specific disclosure, Level 3, because it reveals something distinctive about their actual vendor landscape rather than just describing standard processes.


fact: In January 2024, board of directors participated in a cybersecurity training session provided by internal audit firm

reasoning: The paragraph primarily answers how the board oversees cybersecurity, describing audit committee delegation, briefing content, and board engagement — classic Board Governance. The specific date 'January 2024' for a board cybersecurity training session is an externally verifiable claim, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

Category: This describes board/audit committee oversight of cybersecurity - how information flows to the board, delegation, briefing content. This is Board Governance.

Specific facts:
- "audit committee" - generic, every company has one
- "vulnerability assessments" - domain term (L2)
- "third-party evaluations" - generic
- "internal audit firm" - generic
- "In January 2024, our board of directors participated in a cybersecurity training session provided by our internal audit firm" - specific date (January 2024) → verifiable

So Level 4 due to "January 2024" as a specific date tied to a real event.


fact: managed security service monitoring

fact: penetration testing

fact: vulnerability assessment

fact: Management Enterprise Risk Committee

fact: Vendor Management Committee

reasoning: While the first sentence mentions third parties hired to serve the company (which would be RMP per Rule 3), the bulk of the paragraph focuses on vendor oversight: due diligence reviews, contractual cybersecurity requirements, ongoing oversight procedures, and risk assessment of vendors — making third-party risk management the central topic → TP. Specificity reaches Level 3 due to the named firm-specific committees (Management Enterprise Risk Committee, Vendor Management Committee), which are non-generic and distinguish this company's governance structure.

thinking:
Let me analyze this paragraph.

Category: This paragraph discusses both third-party vendors used for security services AND vendor oversight/risk management. The first sentence describes third parties hired to serve the company (assessors, pen testers → RMP per Rule 3). But the bulk of the paragraph is about requirements imposed ON vendors - due diligence, oversight, contractual requirements, vendor management. Third-party risk management is the central topic for most of the paragraph. → TP.

Specific facts:
- "managed security service monitoring" → domain_term
- "penetration testing" → domain_term
- "vulnerability assessment" → domain_term
- "Management Enterprise Risk Committee" → named_committee (firm-specific, non-generic)

- "Vendor Management Committee" → named_committee (firm-specific)

Specificity: Level 3 (firm-specific committees).


reasoning: The paragraph states a backward-looking conclusion that no cybersecurity incidents have materially affected business strategy, results of operations, or financial condition — this is a materiality assessment triggering SI under Rule 5. The second sentence is a cross-reference to Item 1A. No specific facts elevate specificity: the negative materiality assertion is a self-reported claim about absence (not externally verifiable), and 'as of the date of this report' is a generic temporal anchor, not a specific date tied to a cybersecurity event.

thinking: Materiality assessment + cross-reference.


reasoning: The paragraph states a conclusion about whether cybersecurity risks are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition — this is the SEC Item 106(b)(2) forward-looking materiality assessment, triggering SI under Rule 5. No domain terms, firm-specific facts, or verifiable claims are present; 'consultants' is unnamed and generic, and the rest is standard materiality boilerplate.

thinking: Materiality assessment paragraph.


reasoning: The paragraph states a materiality conclusion ('have not materially affected or are reasonably likely to materially affect... business strategy, results of operations or financial condition'), which is the SEC Item 106(b)(2) assessment → SI. The second sentence is a cross-reference to Item 1A with speculative 'could' language, which does not override the SI classification. No domain terms, firm-specific facts, or verifiable claims elevate specificity beyond Level 1.

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


reasoning: Person-removal test: removing 'executive management team' leaves a description of mechanisms, controls, technologies, policies, and processes designed to prevent data loss — substantive program description → RMP. Outside advisors hired to serve the company also → RMP per Rule 3. All language is generic ERM-level ('mechanisms, controls, technologies, systems, policies, processes,' unnamed 'outside advisors') with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Describes a cybersecurity program managed by executive management team, includes mechanisms/controls/technologies/etc., and they use outside advisors.

Category: This is about what the program does (RMP) vs who manages it (MR). Person-removal test: remove "executive management team" - substantial program description remains about mechanisms, controls, technologies, policies, processes. → RMP

The outside advisors part - third parties hired to serve the company → RMP per Rule 3.

Specificity: Let me scan for facts.

Everything here is generic boilerplate—"executive management team," "mechanisms, controls, technologies, systems, policies," "prevent or mitigate data loss, theft, misuse," and "outside advisors and experts" are all standard ERM language with no firm-specific details or verifiable claims. → Level 1.


fact: Information Security Officer role primarily responsible for cybersecurity

fact: ISO reports directly to the Chief Risk Officer

reasoning: The paragraph introduces the ERM program but its primary content is the Information Security Officer's responsibilities, reporting line to the CRO, and organizational position—applying the person-removal test, removing the ISO and reporting structure leaves only generic ERM language, so MR wins. Specificity reaches Level 3 via the firm-specific Information Security Officer role and the named Information Technology Steering Committee.

thinking:
Let me analyze this paragraph.

Category: This describes the risk management program structure and the Information Security Officer's role, reporting lines, and position within the organization. The main content is about how management is organized - the ISO's responsibilities, reporting to CRO, and committees. But it also starts with ERM integration. Let me apply the person-removal test: remove the ISO, CRO, reporting lines - what remains? "Our risk management program is designed to identify, assess, and mitigate risks across various aspects of our company... Cybersecurity is a critical component of this program..." That's pretty thin on cybersecurity program specifics.

The paragraph's real focus is the ISO's position and reporting structure within the governance chain. Even though it mentions the ERM program upfront, the substance centers on the organizational role and oversight hierarchy - that makes this MR rather than BG. The ISO is a named, security-specific role, while the CRO is more generic, but the emphasis on reporting lines and management structure is what drives the categorization.

Looking at the specificity markers: the Information Technology Steering Committee is a named, non-generic committee that's firm-specific, whereas the Audit Committee is standard across companies. The board of directors is generic. That puts us at Level 3 for firm-specificity.


reasoning: The paragraph is primarily a cross-reference directing readers to Item 1A Risk Factors, with only a passing, generic mention of experiencing threats 'from time to time' — no substantive cybersecurity program, governance, or incident detail is disclosed. No domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

It mentions experiencing threats/incidents but only in passing ("from time to time, experienced threats to and incidents"), then points to Item 1A for details. The main content is a cross-reference. The mention of incidents is too vague to be ID. The materiality-like language isn't present. This is primarily a cross-reference paragraph.

N/O - it's a cross-reference to Item 1A with no substantive cybersecurity disclosure.


reasoning: The paragraph states a materiality conclusion — risks have not materially affected business strategy, results of operations, or financial condition, and includes the forward-looking 'reasonably likely to materially affect' language per Item 106(b)(2), making it Strategy Integration. No domain terms, firm-specific facts, or verifiable claims are present; the December 31, 2024 date is a reporting period anchor, not a cybersecurity fact, and the negative assertion about no material incidents is not externally verifiable.

thinking: SI materiality rule applies here.


reasoning: The paragraph focuses on management's responsibilities, qualifications (enterprise risk management experience), meeting cadence, and sponsorship of training—all centered on who is responsible and how they are organized, making it MR. CEO and CFO are explicitly generic governance roles per the rules, 'quarterly' is a generic cadence, and no domain terms pass the ERM test (cybersecurity risk assessment, awareness training, and incident response are standard ERM vocabulary), leaving this at Level 1.

thinking:
MR - about management roles and responsibilities, qualifications, meeting cadence.

Specific facts: CEO, SVP Finance and CFO (named roles), quarterly review cadence.

CEO is generic. SVP Finance and CFO - "Senior Vice President, Finance and Chief Financial Officer" is a firm-specific title at VP+ level. Actually, CFO is generic per the rules. But "Senior Vice President, Finance and Chief Financial Officer" as a combined title is somewhat firm-specific. Wait - the rules say "CEO, CFO, General Counsel" are NOT firm-specific. So CFO alone isn't. But "Senior Vice President, Finance and Chief Financial Officer" - the SVP part with Finance qualifier...

The rules are clear that generic governance roles like CEO and CFO aren't firm-specific, so this is just a longer version of the CFO title. Looking at the actual content, it's describing management responsibilities and qualifications around senior leadership experience with ERM oversight - that's MR material. The domain terms like cybersecurity risk management and incident response are generic, there are no firm-specific facts beyond the standard roles, and quarterly is just a standard cadence. So this doesn't cross into firm-specific territory.


fact: CISO provides updates to Audit Committee and Board

fact: CIO provides updates on cybersecurity-related matters

fact: Security & Resiliency global practice leader provides updates

reasoning: The paragraph describes the Board and Audit Committee's oversight of cybersecurity risk, including how information flows upward, making it Board Governance. Firm-specific roles (CISO, CIO, Security & Resiliency global practice leader) elevate specificity to Level 3.

thinking:
Classify this paragraph.

Category: Board Governance - describes board/committee oversight of cybersecurity, briefing frequency, information flow to the board.

Specific facts:
- Audit Committee semi-annually reviews - generic committee but with cadence
- CISO - named role (firm-specific)
- CIO - named role (firm-specific)
- "Security & Resiliency global practice leader" - named role (firm-specific)
- Semi-annually - generic cadence, not firm-specific

CISO and CIO are VP-level-or-above roles.

The "Security & Resiliency global practice leader" title is also firm-specific.


fact: Third-Party Risk Management Program (named internal program)

fact: Vendor Management Policy (named internal policy)

fact: Interagency Guidance on Third-Party Relationships: Risk Management (named regulatory framework)

fact: annual Internal Audit Risk Assessment (named audit process)

reasoning: The paragraph centrally addresses how the company manages vendor/third-party risk through its named program, policy, onboarding process, and periodic reviews — making Third-Party Risk the clear category. Specificity reaches Firm-Specific (Level 3) due to named internal programs (Third-Party Risk Management Program, Vendor Management Policy) and the referenced Interagency Guidance, though the compliance claim is aspirational rather than externally verifiable, keeping it below Level 4.

thinking:
Classify this paragraph.

Category: This is centrally about how third-party/vendor cyber risks are managed - vendor management program, onboarding, periodic reviews, policy. Central topic is TP.

Specific facts:
- "Third-Party Risk Management Program" - named program → firm-specific
- "Vendor Management Policy" - named policy → firm-specific
- "Interagency Guidance on Third-Party Relationships: Risk Management" - named framework → verifiable
- "annual Internal Audit Risk Assessment" - audit process

The Interagency Guidance is a real, named regulatory document - that's verifiable (it's a published guidance document from federal banking regulators).

Now I'm thinking about whether referencing compliance with a named regulatory guidance counts as verifiable or domain-adapted. Claiming "in compliance with" the Interagency Guidance is more like an aspirational alignment with an external standard rather than a concrete certification - similar to saying "aligned with NIST CSF" - so that pushes toward Domain-Adapted. The named programs themselves like "Third-Party Risk Management Program" and "Vendor Management Policy" are firm-specific, which puts this at Specificity Level 3.


fact: Security & Technology Committee

reasoning: The paragraph describes how the Board and a specific committee receive prompt notification and ongoing updates about cybersecurity incidents, which is squarely about information flow to the board — a core Board Governance topic. The named 'Security & Technology Committee' is a non-generic, firm-specific committee that elevates specificity to Level 3, while the rest is generic oversight language.

thinking:
Classify this paragraph.

This is about how the Board and a named committee receive information about cybersecurity incidents - this is board oversight/information flow.

Category: Board Governance (how info flows to the board)

Specific facts:
- "Security & Technology Committee" - named committee (firm-specific, non-generic)
- "established reporting thresholds" - generic process language

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


fact: phishing attempt

fact: In 2019, subject of a successful phishing attempt

reasoning: The paragraph's primary purpose is a materiality assessment: no material losses from cyber-attacks and no known risks reasonably likely to materially affect business strategy/results/financial condition — classic SI per Rule 5. The 2019 phishing incident is mentioned as brief context, not as a detailed incident disclosure. The specific year (2019) tied to a real phishing event is an externally verifiable claim, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. "We have not experienced any material losses relating to cyber-attacks, in 2019 we were the subject of a successful phishing attempt." - References a real incident (2019 phishing) and a negative materiality assertion.
2. "We do not believe that there are currently any known risks from cybersecurity threats that are reasonably likely to materially affect us or our business strategy, results of operations or financial condition." - Forward-looking materiality assessment (SEC Item 106(b)(2) language).

Category: The paragraph mentions a real incident briefly but the main thrust is materiality assessment.

The 2019 phishing incident serves as context for the materiality conclusion, with the dominant frame being financial and business impact assessment rather than incident disclosure. The backward-looking statement about no material losses combined with the forward-looking assessment of reasonably likely risks points to Strategy Integration. The specific date and phishing reference are verifiable details tied to an actual event, though mentioned in passing to support the materiality argument.


fact: ISO (Information Security Officer) reports directly to the board of directors

fact: Information Security Program (named internal program)

reasoning: The paragraph describes the ISO's reporting relationship to the board, including briefing frequency and scope—classic board oversight structure, making it Board Governance. The ISO role (a firm-specific security title at or near VP-equivalent level), the named Information Security Program, and the reference to the Interagency Guidelines for Safeguarding Customer Information (a specific regulatory framework) elevate this to Firm-Specific.

thinking:
Classify this paragraph.

The paragraph describes the ISO (Information Security Officer) reporting to the board of directors about the Information Security Program status. This is about how information flows to the board - Board Governance.

Specific facts:
- "ISO" (Information Security Officer) - named role, firm-specific
- "Interagency Guidelines for Safeguarding Customer Information" - named framework/standard
- "at least annually" - generic cadence, not specific
- "Information Security Program" - could be firm-specific named program

The ISO reporting to the board is about oversight structure → BG.

The ISO role and named Information Security Program push this to Level 3 specificity, with the regulatory standard and process descriptions around risk assessment, testing, and breach reporting adding domain-specific detail.


fact: Head of IT reports directly to CFO

fact: over twenty years of experience managing IT and cybersecurity

fact: Master of Science degree in Telecommunications and Computer Networks

fact: Project Management Professional certified

fact: Certified Scrum Master

fact: IT Infrastructure Library (ITIL) certified

reasoning: The paragraph's primary content is the Head of IT's reporting line, qualifications, and credentials — applying the person-removal test, the remaining content (ERM integration, generic risk management, materiality statement, cross-reference) is thin and generic, confirming MR. The SI materiality language ('not reasonably likely to materially affect us') is present but subordinate. Specificity reaches Level 4 via multiple externally verifiable claims: 'over twenty years' sets a checkable lower bound, and the named certifications (PMP, CSM, ITIL) and specific degree can be independently confirmed.

thinking:
Let me analyze this paragraph carefully.

Content category: This paragraph covers multiple topics. Let me break it down:
- Head of IT reporting to CFO, experience, qualifications → Management Role
- Responsible for assessing and managing cybersecurity risks → could be RMP
- ERM integration → RMP
- "identified and mitigated certain known cybersecurity threats, which we determined are not reasonably likely to materially affect us" → Strategy Integration (materiality assessment)
- Cross-reference to Risk Factors → N/O

The paragraph starts with management role details (Head of IT, qualifications, reporting line), then touches on ERM integration, then makes a materiality assessment, then has a disclaimer and cross-reference.

When I strip away the person-specific details—the Head of IT title, CFO reporting relationship, and qualifications—what's left is fairly generic language about assessing and managing cybersecurity risks within the ERM framework and a materiality determination about known threats. The bulk of the substance comes from those management role specifics in the opening, so Management Role appears to be the primary category here.

Looking at the specificity markers: "Head of IT" without a security qualifier doesn't meet the firm-specific threshold, reporting to CFO is generic, and the qualifications—over twenty years of experience, the Master's degree in Telecommunications and Computer Networks, and the PMP certification—are all verifiable credentials that fall into Level 4 specificity. I'm settling on Management Responsibility as the primary disclosure category since the qualifications section takes up the bulk of the paragraph by word count, even though the materiality language from SEC rules is present.


fact: Chief Information Officer (CIO) provides updates to the Board

fact: quarterly scorecard assessments

reasoning: The paragraph answers how the board oversees cybersecurity: full Board responsibility, receiving updates and scorecard assessments from the CIO, covering specific topic areas. CIO is a VP+-level role making this Firm-Specific (Level 3); no externally verifiable claims push it to Level 4.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity - Board receives updates from CIO. This is Board Governance.

Specific facts:
- "Chief Information Officer" (CIO) - named role, firm-specific (VP+ level)
- "quarterly scorecard assessments" - quarterly is generic cadence
- "emerging threat landscape" - not really domain-specific beyond ERM
- "information security infrastructure" - borderline

The paragraph describes how the board oversees cybersecurity via updates from the CIO. BG clearly.

For specificity: CIO is a firm-specific role (VP+ level).

This lands at Level 3 since there aren't any quantified or verifiable metrics present.


fact: reviewing relevant cybersecurity certifications

fact: third-party audit results

fact: technical and organizational controls

reasoning: The paragraph is centrally about requirements imposed on suppliers (reviewing their certifications, assessing their controls, evaluating risk profiles), making it Third-Party Risk per Rule 3. Specificity reaches Level 2 because terms like 'cybersecurity certifications,' 'third-party audit results,' and 'technical and organizational controls' demonstrate domain knowledge beyond generic ERM language, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: About third-party supplier risk assessments - security assessments of suppliers, reviewing certifications, audit results, controls.

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

Specific facts:
- "cybersecurity certifications" - domain term
- "third-party audit results" - could be domain (SOC 2-adjacent)
- "technical and organizational controls" - domain term
- "risk profile" - generic ERM

The paragraph describes requirements imposed ON vendors (reviewing their certifications, assessing their controls) → TP per Rule 3.

The language here shows domain-specific awareness—phrases like "cybersecurity certifications," "third-party audit results," and "technical and organizational controls" go beyond generic vendor assessment language and reflect familiarity with actual compliance frameworks like GDPR and ISO standards. This pushes it to Level 2 domain knowledge, though there aren't any firm-specific details present.


fact: Named program: Third Party Cyber Risk Management Plan

fact: SOC2 T2 attestation required from vendors

fact: Penetration testing documentation requested from vendors

fact: ISO 27001 certification and scope requested from vendors

fact: Security and privacy clauses included in third-party contracts

reasoning: The paragraph is centrally about how third-party cyber risks are managed — vendor due diligence, contractual requirements, and ongoing review — making it clearly Third-Party Risk. The named 'Third Party Cyber Risk Management Plan' is a firm-specific program identifier elevating to Level 3, with domain terms like SOC2 T2, penetration testing, and ISO 27001 demonstrating cybersecurity expertise at Level 2.

thinking:
Classify this paragraph.

Category: This is centrally about how third-party cyber risks are managed - vendor assessments, contractual requirements, ongoing reviews. → Third-Party Risk

Specific facts:
- "Third Party Cyber Risk Management Plan" - named internal program → firm-specific
- "SOC2 T2" - domain term / framework
- "penetration testing" - domain term
- "ISO 27001 certification" - domain term / framework
- "at least annually" - soft cadence, not verifiable
- Security and privacy clauses in contracts - TP content
- Questionnaire-based assessment - process

- The named program is firm-specific, while the frameworks and testing methodologies are standard domain terms, and there aren't any concrete verifiable metrics, so this lands at Level 3 specificity.


reasoning: The paragraph describes the company's processes for assessing and managing cybersecurity risks integrated into ERM, answering 'what does the program do?' → RMP. Every phrase ('processes for assessing, identifying and managing,' 'informed by industry standards,' 'designed to help protect') is standard ERM language that any non-security professional could write, with no named frameworks, domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Describes having processes for assessing, identifying, and managing cybersecurity risks, informed by industry standards, integrated into ERM, designed to protect information assets. This is about what the cybersecurity program does → RMP.

Specificity: Let me scan for facts.
- "processes for assessing, identifying and managing cybersecurity risks" → generic ERM language, L1
- "informed by industry standards" → vague, no named standard, L1
- "built into our overall enterprise risk management function" → ERM integration, generic, L1
- "protect our information assets and operations from internal and external cyber threats" → generic, L1

- "protect employee, collaborator and patient information" → mentions specific data types but still boilerplate

This is entirely generic language with no domain-specific terminology, firm-specific details, or verifiable claims that would satisfy the ERM test.


fact: February 2023 cyberattack — specific date of a real incident

reasoning: The paragraph's central purpose is a backward-looking materiality assessment: the February 2023 cyberattack 'did not have a material adverse impact on our consolidated financial position, results of operations or liquidity,' which is a Strategy Integration conclusion per Rule 5. While it references a real incident, the framing is financial/business impact rather than describing what happened (ID). The specific date 'February 2023' tied to a real cyberattack is an externally verifiable fact, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

The paragraph discusses the February 2023 cyberattack and states it did not have a material adverse impact, while also discussing forward-looking risks. The key question: what is this primarily about?

It contains a materiality assessment: "the February 2023 cyberattack and our remediation efforts did not have... a material adverse impact on our consolidated financial position, results of operations or liquidity" — this is a backward-looking SI assessment per Rule 5.

It also references a real incident (February 2023 cyberattack) — but the paragraph isn't describing what happened, it's assessing impact and discussing future risks.

This falls under Strategy Integration since it's making a conclusion about whether cybersecurity incidents have materially affected business outcomes. The February 2023 cyberattack reference is specific and tied to a real, verifiable event, which gives it concrete grounding.


fact: Software Approval Board — named internal governance body for software risk evaluation

fact: Cross-functional members from Quality, Internal Audit, Information Security, Business Systems, and R&D

reasoning: The paragraph centrally addresses how the company manages third-party cybersecurity risks — vendor diligence, software approval processes, and contractual requirements imposed on vendors — making Third-Party Risk the best fit. The named 'Software Approval Board' and its specific departmental composition (Quality, Internal Audit, Information Security, Business Systems, R&D) are firm-specific details that elevate this to Level 3.

thinking:
Let me analyze this paragraph.

Category: This is about third-party risk management - vendor diligence, software approval, contractual requirements on third parties. Third-party oversight is the central topic. → Third-Party Risk

Specificity: Let me scan for facts:
- "Software Approval Board" - a named internal committee/board, firm-specific
- Cross-functional members from "Quality, Internal Audit, Information Security, Business Systems, and R&D" - specific team composition by department, firm-specific
- "Information Security" as a department - this is part of the team composition

Domain terms: Not many that pass the ERM test strongly. "data breaches", "security incidents" are fairly generic.

The Software Approval Board with its specific departmental makeup across Quality, Internal Audit, Information Security, Business Systems, and R&D is clearly firm-specific, placing this at Level 3.


reasoning: Two of three sentences focus on vendor due diligence and ongoing third-party monitoring, making TP the central topic; the final sentence about internal annual assessments is secondary. The language throughout ('vendor due diligence,' 'risk-based approach,' 'ongoing monitoring,' 'industry-standard guidelines and tools') is generic ERM vocabulary that any non-security risk professional would use, with no domain-specific terms, named frameworks, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Vendor due diligence, third-party monitoring, risk-based approach, annual cybersecurity assessments.

Category: The first two sentences are about third-party/vendor oversight. The last sentence shifts to internal assessments. The central topic of the paragraph is split between TP (vendor due diligence, third-party monitoring) and RMP (annual assessments). The first two sentences are clearly about third-party risk management, and the third sentence is about internal assessments. I'd say TP is the central topic given 2/3 sentences.

Looking more closely at the language, the first two sentences focus on vendor due diligence and ongoing third-party monitoring using a risk-based approach, while the third sentence describes internal annual cybersecurity assessments. That confirms TP dominates at two-thirds of the content.

Now scanning for specificity—the language is fairly generic throughout. "Vendor due diligence," "risk-based approach," and "annual cybersecurity assessments" are all standard ERM terminology without concrete details about implementation or metrics. Everything here reads as L1 level specificity.


reasoning: The paragraph describes how the Audit Committee oversees cybersecurity risks and receives periodic reports from management — squarely answering the board oversight question → BG. No domain terms passing the ERM test, no firm-specific facts (Audit Committee is generic, 'third-party consultants' unnamed, 'periodic' is generic cadence) → Level 1.

thinking:
Classify this paragraph.

Content: Audit Committee oversees IT/cybersecurity risks with management and third-party consultants, receives periodic reports from management.

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

Specificity: "Audit Committee" is generic (every company has one). "third-party consultants" is unnamed. "periodic reports" is generic cadence. No domain terms that pass ERM test. This is Level 1.


reasoning: This paragraph states a backward-looking materiality conclusion ('have not...materially affected us, our business strategy, results of operation or financial condition'), which is a Strategy Integration assessment per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present — the negative self-assertion about no material impact is not externally verifiable.


fact: June 30, 2024 — specific date of cybersecurity incident detection

fact: Unauthorized third party gained access to certain information systems

fact: Retained external cybersecurity experts for investigation

reasoning: The paragraph describes an actual cybersecurity incident — unauthorized access detected, investigation launched, expenses incurred — making it clearly Incident Disclosure. The specific date 'June 30, 2024' is an externally verifiable fact (tied to a real event, cross-referenced to Note 14), elevating specificity to Quantified-Verifiable.

thinking: Incident disclosure with specific date and details.


reasoning: The paragraph answers how the board oversees cybersecurity — the audit committee receives reports, monitors management's efforts, and gets notified of material incidents — placing it squarely in Board Governance. No domain-specific terminology (ERM test fails for all terms used), no firm-specific facts (audit committee is generic), and no verifiable claims, keeping it at Level 1.

thinking:
Classify this paragraph.

Category: Board Governance - describes how the board/audit committee oversees cybersecurity, briefing frequency, information flow to the board.

Specificity: Let me scan for facts.
- "audit committee" - generic, every company has one → not firm-specific
- "annually" - generic cadence
- "management" - generic
- No domain terms that pass the ERM test - "cybersecurity threats and risks", "cybersecurity strategy and program" are generic
- No firm-specific facts

- No verifiable facts either

This is Level 1 - Generic Boilerplate.


reasoning: The paragraph describes qualifications (degrees, experience) of several officers in managing risks including cybersecurity, making it primarily about who is responsible and what qualifies them (MR). The titles listed (CFO, General Counsel, CAO) are generic corporate roles present at every company, not security-qualified VP+ roles. 'Approximately 20 years or more' is hedged in both directions and not firmly verifiable. No domain terms pass the ERM test—'managing risks arising from cybersecurity threats' is generic risk language.

thinking:
Let me analyze this paragraph.

Content: Describes qualifications of several officers (SVP CFO, SVP General Counsel, SVP CAO) - their degrees and experience managing risks including cybersecurity risks.

Category: This is about management roles - qualifications and experience of leadership. MR.

Specific facts:
- SVP CFO, SVP General Counsel, SVP CAO - these are generic C-suite titles, not security-specific VP+ roles
- "approximately 20 years or more of experience" - this is a lower bound but hedged with "approximately", making it soft. Actually "20 years or more" sets a floor, and "approximately" hedges it.

These are standard governance positions rather than security-focused executive roles, so they don't qualify as firm-specific. The experience claim is also hedged with "approximately," which weakens its verifiability.


fact: applying vendor-provided software fixes (patches)

fact: vulnerability scanning

fact: intrusion detection tools

reasoning: The paragraph describes specific cybersecurity program activities (patching, configuration management, vulnerability assessment, updating tools) in response to identified risks, making it RMP. Domain terms like patches, vulnerability scanning, and intrusion detection tools pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes management's response to identified risks - patching, configuration management, vulnerability assessment, updating scanning/IDS tools, investing in technologies.

Category: This describes what the cybersecurity program does in response to risks. The mention of "management" is just context - the substance is about program activities. Per the person-removal test, removing "management" leaves substantial program description. → RMP

Specificity: Let me check for domain terms that pass the ERM test:
- "patches" / "vendor-provided software fixes" → domain term (patch management)
- "vulnerability scanning" → domain term

- "intrusion detection tools" → domain term (IDS)
- "exploitable files and services" → shows domain knowledge
- "security configurations" → somewhat domain-specific
- "known vulnerabilities" → domain concept

These all pass the ERM test - an ERM professional wouldn't naturally discuss patches, vulnerability scanning, or intrusion detection without specialized knowledge. Any firm-specific facts? No named roles at VP+, no named tools, no specific numbers. → Level 2


reasoning: The paragraph introduces the company's cybersecurity program at a very high level—collecting data, importance of IT systems, and having a program to monitor and improve posture—which loosely answers 'what does the program do?' but with no substantive detail. No domain terms pass the ERM test; language like 'cybersecurity program,' 'cybersecurity posture,' and 'monitor and improve' are generic enough for any enterprise risk context.

thinking:
Classify this paragraph.

Content: Generic description of collecting data, importance of IT security, and having a cybersecurity program. No specific details about board oversight, management roles, specific processes, third parties, incidents, or materiality assessments.

Category: This is about having a cybersecurity program generally. It's introductory/overview language. It mentions "operations and business strategy" but doesn't make a materiality assessment. It's really just an introductory paragraph. Could be RMP but it doesn't describe any actual processes. It's mostly preamble. I'd say None/Other or RMP. It says they "established a strong cybersecurity program intended to continue to monitor and improve our cybersecurity posture" - this is extremely generic. No actual measures described.

Per Rule 6, this lacks substantive disclosure—it's just boilerplate stating they have a program without describing any actual processes or measures. I'm leaning toward RMP since it at least mentions the program's existence and purpose, though it's purely generic language. The specificity is minimal with no domain-specific terminology.


reasoning: The paragraph states a backward-looking materiality conclusion ('did not identify any cybersecurity threats or incidents that materially affected...') and a forward-looking assessment ('reasonably likely to materially affect'), triggering Rule 5 for Strategy Integration. No domain terms, firm-specific facts, or verifiable claims are present — 'In 2023' is a reporting period, the negative assertion about no material incidents is not externally verifiable, and the remainder is generic disclaimer and cross-reference language.

thinking: Materiality assessment paragraph.


fact: vendor onboarding cyber review process

specificity_confidence: low

reasoning: The paragraph centrally addresses how third-party cyber risks are managed — contractual requirements, risk-based monitoring, and vendor onboarding review — making TP the clear category. The language describes processes (evaluation, monitoring, contractual requirements, onboarding review) but mostly in generic terms. The mention of a specific 'cyber review process that is part of vendor onboarding' is a named internal program element that is somewhat firm-specific, though borderline. The rest is fairly standard third-party risk language without domain-specific terminology passing the ERM test. On reflection, 'contractually require certain third parties… to maintain cybersecurity programs and to report actual or suspected security incidents' and 'monitor and identify cybersecurity risks posed by third-party vendors based on their criticality and risk profile' are standard ERM-level descriptions. The vendor onboarding cyber review is a named process element that edges into firm-specific territory.

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


reasoning: The paragraph's entire content is about third-party vendor arrangements for IT and cybersecurity services, making third-party relationships the central topic. However, it describes no oversight processes, no specific vendors, no domain terminology, and no firm-specific details—just a generic statement that agreements exist and more vendors are being explored, leaving it at Level 1.

thinking:
Classify this paragraph.

Content: About third-party agreements for IT services and exploring vendors for cybersecurity needs. This is about third-party relationships but it's very generic - no specific oversight requirements imposed on vendors, no specific processes described.

Category: Third-Party Risk - it's centrally about third-party arrangements for IT/cybersecurity services. But wait - these are third parties hired to serve the company (hardware, software, telecom services). Per Rule 3, third parties hired to serve the company → RMP. But there's no real program description here either. It's just stating they have vendor agreements and are exploring more. This is quite thin.

The paragraph is really just describing the company's use of third-party IT vendors without detailing any oversight mechanisms or program components, so I need to determine whether this is fundamentally about third-party risk management or vendor management. Since there are no specific requirements or oversight activities described, and it's just a generic mention of having vendor agreements, this leans toward being too vague to clearly categorize as either TP or RMP. The key distinction is whether vendor oversight is actually being described—here it's not. There's just a statement about existing IT vendor agreements and a search for cybersecurity vendors, with no program activity or oversight mechanisms mentioned. This is clearly Third-Party Risk as the sole topic. The language is entirely generic with no domain-specific terminology or company details, so this lands at Level 1 specificity.


reasoning: This is a cross-reference to Item 1A Risk Factors with no substantive cybersecurity disclosure. N/O paragraphs always get Generic Boilerplate.


fact: malicious look-alike phishing sites (specific threat type)

fact: security posture (domain concept)

reasoning: The paragraph describes a real event — threat actors creating phishing sites targeting the bank's online platform — along with the outcome (no losses, attacks subsided), making Incident Disclosure the best fit despite the negative breach assertion and forward-looking monitoring language. Specificity reaches Level 2 via domain terms like 'phishing sites' and 'security posture,' but lacks firm-specific identifiers (no named roles, teams, or tools) or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Describes a real incident (phishing sites targeting online banking), states no data breaches, no losses, and that attacks subsided. Also mentions ongoing monitoring.

Category: This describes an actual incident - threat actors created phishing sites targeting the bank. It discusses what happened, the outcome (no losses), and resolution. This is Incident Disclosure.

Wait - let me reconsider. The paragraph also contains "We have not experienced any data breaches during the year" which is a negative materiality assertion. But the dominant frame is about a real event (phishing sites), timeline, and outcome. ID vs SI: the incident frame is dominant → ID.

Looking at the specificity here - the language uses domain terminology like "phishing sites" and "look-alike" variants, but beyond that it's mostly generic descriptions without firm-specific details or verifiable facts. The timeframe is vague ("beginning of the year"), and the negative assertions about data breaches aren't something I can actually verify from the text.


reasoning: The paragraph centrally addresses how third-party cyber risks are managed — due diligence, contractual provisions, and incident response for vendor incidents — making TP the clear category. All language is generic ERM-level ('due diligence,' 'contractual provisions,' 'appropriate cybersecurity measures') with no domain terms, firm-specific facts, or verifiable claims.

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


fact: $2.7 million of loss recognized (net of funds recovered and professional fees)

fact: Incident occurred early in Fiscal 2024

fact: Fraudulently-induced outbound wire transfers to a third-party account

fact: Independent forensic investigation conducted

fact: Federal and local law enforcement authorities contacted

fact: Cross-reference to Note 18 of consolidated financial statements

reasoning: The paragraph describes a real cybersecurity incident — fraudulently-induced wire transfers — with timeline (early Fiscal 2024), response actions, and investigation details, making it Incident Disclosure. The $2.7 million loss figure is a hard, externally verifiable number (confirmable via financial statements Note 18), driving specificity to Level 4.

thinking:
Incident disclosure - describes a real event with timeline, response, and financial impact.

Specific facts: "$2.7 million of loss" is quantified and verifiable. "Fiscal 2024" is a specific timeframe. "Note 18" is a cross-reference. The incident itself is a real event.


fact: NIST Cybersecurity Framework

fact: FFIEC Cybersecurity Assessment Tool

fact: Information Security Officer leads the program

fact: Information Technology Officer co-leads the program

reasoning: The paragraph primarily describes the cybersecurity program's objectives, framework alignment, and review cadence — answering 'what does the program do?' Person-removal test leaves substantial program content, confirming RMP over MR. Specificity reaches Level 3 due to firm-specific named roles (Information Security Officer, Information Technology Officer); the frameworks (NIST CSF, FFIEC) are domain-adapted (Level 2), and 'aligns with' rather than 'certified to' prevents Level 4.

thinking:
Classify this paragraph.

Category: The paragraph describes what the cybersecurity program does - its objective, framework alignment, and review cadence. The last sentence mentions leadership roles. Person-removal test: remove "led by our Information Security Officer in conjunction with our Information Technology Officer" - substantial program description remains about safeguards, framework alignment, review cadence. → RMP.

Specificity:
- NIST Cybersecurity Framework → domain term/framework (Level 2)

- FFIEC Information Technology Examination Handbooks → framework (Level 2)
- FFIEC Cybersecurity Assessment Tool → framework (Level 2)
- "Information Security Officer" → firm-specific role title with security qualifier (Level 1)
- "Information Technology Officer" → IT title without security qualifier, not VP-level explicitly (Level 0)
- "Information Security Program" → program name (Level 1)

For "Information Security Officer," I'm reconsidering whether this counts as a named role. In banking, "Officer" is a specific corporate designation, and combined with the security qualifier, it's comparable to CISO—so I'll treat it as a firm-specific named role. The "Information Technology Officer" lacks the security qualifier and isn't explicitly VP-level, so it doesn't meet the criteria. No verifiable claims here since alignment isn't certification and annual cadence is too generic.


fact: data encryption

fact: protecting data from unauthorized incorporation in large language models or other AI systems

reasoning: The majority of the paragraph describes program activities (network security, data encryption, employee training, AI/LLM data protection), making RMP the primary category despite the final sentence about board reporting (BG). Specificity reaches Level 2 via domain terms like 'data encryption' and the AI/LLM-specific data protection concern, which pass the ERM test, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes general security measures (network security, data encryption, employee training), mentions AI/LLM data protection concern, and notes Audit Committee/Board reporting cadence.

Category: Mixed - has RMP elements (measures) and BG elements (board reporting). The last sentence is about board oversight. Let me assess which dominates. The first two sentences describe program activities, the last describes board oversight. It's roughly split but I'd say RMP has more text (2 sentences vs 1).

Actually, rereading this more carefully - the paragraph is primarily about what the program does with security measures taking up most of the space, while the board reporting is mentioned more briefly at the end. That tips it toward RMP.

Specificity: "network security" and "data encryption" are domain terms that work for ERM, and "large language models" is a specific technology reference that adds precision. The "quarterly reports" detail is also concrete.

"Data encryption" definitely passes the ERM test - it's security-specific enough that a general ERM professional wouldn't naturally use it. "Network security" is borderline but leans toward domain-specific too. No firm-specific facts here, just generic governance structures and practices.

This is Level 2 - Domain-Adapted.


fact: CDO (Chief Digital Officer) role

fact: Interim CISO role

fact: CDO has over 20 years of experience in technology, digital growth, and e-commerce

fact: Interim CISO has nearly 20 years of experience in security and risk programs

fact: CDO holds master's degree from Ecole Supérieure de Commerce de Chambéry, Rhône-Alpes, France

fact: Interim CISO graduated from Miami University with bachelor's in management information systems and marketing

reasoning: The paragraph describes two management roles (CDO and interim CISO), their qualifications, experience, and reporting lines — squarely Management Role. Multiple verifiable facts elevate to Level 4: specific experience durations ('over 20 years', 'nearly 20 years') and named educational institutions (Ecole Supérieure de Commerce de Chambéry, Miami University) are independently checkable.

thinking:
Classify this paragraph.

Content: Describes CDO and interim CISO roles, their qualifications, experience, and education.

Category: Management Role - about leadership roles, qualifications, credentials, career history.

Specificity: Let me scan for facts.
- CDO (named role, firm-specific)
- interim CISO (named role, firm-specific)
- "over 20 years" of experience - lower bound, verifiable
- "nearly 20 years of experience" - verifiable lower bound
- Master's degree from Ecole Supérieure de Commerce de Chambéry - verifiable
- Bachelor's from Miami University - verifiable

- Both roles report directly to the CEO, establishing clear organizational hierarchy.


reasoning: The paragraph's central topic is third-party cyberattack risk and the company's outreach to providers to assess downstream implications of breaches, making Third-Party Risk the best fit. The language is entirely generic—'significant measures,' 'outreach to providers,' 'ascertain potential downstream implications'—with no domain-specific terms passing the ERM test, no firm-specific facts, and no verifiable claims, keeping it at Level 1.

thinking:
Classify this paragraph.

The paragraph discusses third-party cyberattack risk and mentions outreach to providers/third-parties regarding breaches. The central topic is third-party risk management.

Wait - let me re-read. It acknowledges third-party risk, mentions high-profile attacks at other companies, and describes measures including "outreach to our providers and other third-parties." The central topic is about managing third-party cyber risks.

But the measures described are very generic - "outreach to providers," "ascertain potential downstream implications." No domain terms that pass the ERM test. No firm-specific facts. No verifiable claims.

This falls under third-party risk management, but it's purely boilerplate language without any substantive detail—just generic statements about reaching out to providers and assessing downstream effects, with no domain-specific terminology or concrete facts to back it up.


fact: Franklin Templeton named as the entity imposing vendor requirements

reasoning: The paragraph's central topic is how third-party vendor cybersecurity risk is managed—compliance requirements imposed on vendors, questionnaires, and additional diligence—making it Third-Party Risk. The mention of 'Franklin Templeton' as the specific entity requiring vendor compliance is a firm-specific fact, but the rest of the language (confidentiality/security/privacy requirements, questionnaires, inquiries) is generic and does not demonstrate domain expertise, so specificity stays at Firm-Specific (Level 3).

thinking:
Classify this paragraph.

Content: About managing third-party cybersecurity risk - vendor compliance requirements, questionnaires, diligence. Central topic is third-party risk management.

Category: Third-Party Risk (requirements imposed ON vendors is the central topic)

Specific facts:
- "Franklin Templeton" - named firm (the advisor's parent)
- "questionnaires and inquiries" - generic process terms, not domain-specific

Specificity: "Franklin Templeton" is a named firm that's specific. That's firm-specific (Level 3).

Wait - is "Franklin Templeton" a named firm in the verifiable sense? It's the parent company/advisor.

Since it's a named entity that identifies this particular company, I'd classify it as Level 3.


fact: CISO provides reports to audit committee

reasoning: The paragraph describes how the audit committee receives cybersecurity reports and has access to related materials, which answers the board oversight question → Board Governance. The mention of CISO (a VP-level cybersecurity leadership role) elevates specificity to Firm-Specific, though the rest is generic oversight language.

thinking:
Classify this paragraph.

Category: This is about how the board (via audit committee) oversees cybersecurity - receiving reports from CISO, having access to materials. This is Board Governance.

Specific facts:
- CISO (named role, firm-specific)
- Audit Committee - generic, every company has one, NOT firm-specific

Specificity: CISO is firm-specific (Level 3).

Wait - "Audit Committee" is explicitly listed as NOT firm-specific. But CISO IS firm-specific per the rules.

Level 3.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity: the CFO coordinates efforts, receives reports from the cybersecurity team, and an escalation process flows to CEO/senior management/Board. The Board and Audit Committee are mentioned only as escalation endpoints, making this more about management's organizational role than board oversight. No domain terms pass the ERM test ('prevention, detection, mitigation, and remediation' is generic risk language), and CFO/CEO/Audit Committee are all generic governance roles, keeping specificity at Level 1.

thinking:
Classify this paragraph.

The paragraph describes the CFO's role in coordinating cybersecurity efforts and the escalation process. It's about how management is organized - reporting lines from cybersecurity team to CFO, and escalation to CEO, senior management, Audit Committee, and Board.

Category: This describes management's organizational role - the CFO coordinates efforts, there's an escalation process. It's about governance chain. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. But here the primary focus is on management's role (CFO coordinating, escalation to CEO/senior management). The board/Audit Committee is mentioned only as the end of the escalation chain. The paragraph is more about how management handles cybersecurity - MR vs BG.

Let me apply the person-removal test to clarify: stripping out the titles leaves "coordinates prevention, detection, mitigation, and remediation efforts through regular communication and reporting from the professionals on our cybersecurity team. We have an escalation process to inform senior management and the Audit Committee and Board of Directors." The core substance is about management's responsibilities and how information flows upward - that's MR. The Board and Audit Committee appear as recipients of escalated information, not as the primary focus of governance oversight. This leans toward MR.

Looking at specificity: CFO, CEO, Audit Committee, and Board are all generic governance roles, not firm-specific. The terms "prevention, detection, mitigation, and remediation" are standard ERM language. "Cybersecurity team" is generic. There are no domain-specific facts or firm-specific details that would elevate this beyond Level 1.


fact: control maturity assessments

fact: CIO/CDO role reporting to Audit Committee on cybersecurity

reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity including briefing frequency (annual) and information flow, squarely answering the Board Governance question. The CIO/CDO is a firm-specific C-suite role elevating specificity to Level 3; 'control maturity assessments' is a domain term but the named role is the highest fact.

thinking:
Classify this paragraph.

Category: Board/Audit Committee oversight of cybersecurity. This is Board Governance.

Specific facts:
- CIO/CDO role mentioned - firm-specific (named role at VP+ level equivalent)
- "control maturity assessments" - domain term
- "prevention, detection, mitigation, and remediation" - borderline, fairly standard
- "risk assessments" - L1
- Audit Committee - every company has this, not firm-specific

CIO/CDO is a firm-specific role (C-suite). "Control maturity assessments" passes the ERM test as a domain term.

The CIO/CDO reference pushes this to Firm-Specific (Level 3).


fact: cybersecurity audits of third parties

reasoning: The paragraph centrally addresses how third-party cybersecurity risks are managed — diligence, contractual requirements, and audits imposed on vendors — making TP the clear category. While it mentions cybersecurity audits and diligence on third parties with system/data access, the language is largely process-descriptive without strong domain-specific terminology. 'Cybersecurity audits' of vendors passes the ERM test narrowly as a security-specific oversight mechanism, elevating to Level 2, but nothing is firm-specific or verifiable.


reasoning: The paragraph describes management reporting to the audit committee about cybersecurity matters, which is about how information flows to the board — a Board Governance question. No domain terms, firm-specific facts, or verifiable claims are present; 'audit committee' is generic and 'cybersecurity threat risks' is standard ERM language.

thinking:
Classify this paragraph.

This is about reporting to the audit committee - describes information flow from management to board-level committee. This is Board Governance (how information flows to the board).

No specific facts - generic language about reporting to audit committee. "Audit committee" is not firm-specific (every company has one). No domain terms beyond basic "cybersecurity threat risks."

Level 1.


fact: CIO leads corporate cybersecurity program

fact: CIO also serves as Kronos CIO

fact: Corporate information systems owned and operated by Contran and provided through the ISA

fact: CIO reports to Valhi and Kronos chief executive officers

fact: CompX's cybersecurity program led by director of IT

fact: Kronos and CompX each have their own cybersecurity programs

reasoning: The paragraph primarily describes how management is organized to handle cybersecurity across multiple entities (Valhi, Kronos, CompX), detailing the CIO's responsibilities, dual role, reporting lines, and the director of IT's position — all organizational/role content pointing to MR. While some RMP content exists (annual third-party assessments, audits), it is secondary. Specificity is Firm-Specific due to the named CIO role, the unique multi-entity structure (Contran ISA, dual CIO role), though no externally verifiable quantified claims are present ('extensive experience' and 'many years' are soft).

thinking:
Let me analyze this paragraph.

Category: This describes management roles (CIO, director of IT), their responsibilities, reporting lines, and organizational structure across multiple entities. There's also some RMP content (third-party assessments, audits, annual reviews). The person-removal test: removing CIO, director of IT, their reporting lines and experience would leave "cybersecurity risks reviewed and tested annually through third-party assessments and internal and external IT audits" and "IT teams review cybersecurity risks at least annually, integrating findings into strategic risk assessments." That's substantive but the majority of the paragraph is about roles and organizational structure. I'll go with MR.

Now I'm breaking down what's actually firm-specific here. The CIO role itself is named and firm-specific, and the fact that this person also serves as Kronos's CIO adds organizational detail. The ISA with Contran and the subsidiary structure at Kronos and CompX are firm-specific elements. The Director of IT title at CompX without a security qualifier is generic, and the VP coordinating operations isn't security-focused either. The third-party assessments and audits are standard practices, and integrating findings into risk assessments is a generic process. So the firm-specific content centers on the organizational structure and named roles, while the actual cybersecurity activities are largely generic.


reasoning: The paragraph contains a forward-looking materiality assessment using SEC Item 106(b)(2) language — 'reasonably likely to materially affect our business strategy, result of operations or financial condition' — which triggers SI per Rule 5. The remainder is disclaimers and a cross-reference to Item 1A. No domain terms passing the ERM test, no firm-specific facts, and no verifiable claims are present, leaving specificity at Level 1.

thinking:
Let me analyze this paragraph.

The paragraph contains:
1. A statement that cybersecurity threats (not a previous incident) led to their program
2. A disclaimer about no assurance
3. A forward-looking materiality statement: "risks from certain cybersecurity threats that, if realized, are reasonably likely to materially affect our business strategy, result of operations or financial condition"
4. A cross-reference to Item 1A

The materiality statement "are reasonably likely to materially affect" matches the SEC Item 106(b)(2) forward-looking assessment → SI per Rule 5.

The negative framing about incidents is presented as motivation rather than a materiality assessment, but the real trigger is that forward-looking language about material effects. Looking at the specificity, there are no domain-specific terms that would pass an ERM test, no firm-specific facts beyond a generic "Information Security Program," and no verifiable claims—this reads as standard boilerplate at Level 1.


reasoning: The paragraph describes engaging consultants for risk assessment, policy design/implementation, and monitoring/testing safeguards—these are third parties hired to serve the company's program, which per Rule 3 maps to RMP rather than TP. The vendor certification requirements in the last sentence are subordinate to the program-description frame. All language is generic process description (risk assessment, policies and procedures, security measures, breach reporting) that any ERM professional could produce; no domain-specific terms, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party service providers in two contexts: (1) those hired to help with risk assessment, designing/implementing cybersecurity policies, and monitoring/testing safeguards (these serve the company), and (2) requirements imposed on third-party service providers regarding security measures and breach reporting.

Category: This is a mix of RMP (third parties hired to serve the company) and TP (requirements imposed on vendors). The first two sentences describe consultants helping the company's program → RMP per Rule 3. The last sentence describes requirements imposed ON third-party providers → TP. The paragraph seems roughly split.

The opening focuses on consultants engaged for risk assessment and policy implementation, which fits RMP, but the closing sentence shifts to requirements imposed on vendors themselves—that's TP. The TP requirements around security certification and breach reporting are substantial enough that they might tip the balance, though Rule 3 suggests hired third parties serving the company lean toward RMP. I'm going back and forth on this. The consultants helping with the company's cybersecurity program—assessing risks, designing policies, monitoring—that's clearly part of their risk management program. But then the last sentence shifts to requirements they're imposing on those same service providers around certification and breach reporting, which feels like third-party oversight. I think the requirements portion is substantial enough that Third-Party Risk is the better fit, even though the first part leans toward RMP.

Actually, no—I'm overthinking this. The paragraph is fundamentally answering what the cybersecurity program does, and engaging consultants for these functions is how the program operates. The vendor requirements are just part of that operational framework, not a separate vendor oversight discussion. This is RMP.

Now checking the specificity. Looking at the language—"risk assessment processes," "cybersecurity policies," "monitor and test our safeguards," "certify that it has the ability to implement and maintain appropriate security measures," "promptly report any suspected breach"—none of this contains domain-specific terminology or firm-specific facts. These are generic statements any risk professional could make about any organization. This is Level 1 boilerplate.


fact: September 14, 2023 announcement date

fact: Social engineering attack vector

fact: Attack on outsourced IT support vendor

fact: Loyalty program database acquired by unauthorized actor

fact: IRP (Incident Response Plan) activated

fact: Notified law enforcement and state gaming regulators

reasoning: This paragraph describes a real cybersecurity incident — the September 2023 social engineering attack — including timeline, attack vector, scope (loyalty program database), and response actions, making it clearly Incident Disclosure. The specific date of September 14, 2023 is an externally verifiable fact (publicly announced), elevating specificity to Quantified-Verifiable.

thinking: Incident disclosure with specific details.


fact: Chief Technology Officer (CTO)

fact: Chief Information Security Officer (CISO)

reasoning: The paragraph describes how the board oversees cybersecurity through periodic reports and incident reporting thresholds, squarely answering the board governance question. CTO and CISO are VP-level-or-above named roles that qualify as firm-specific, elevating to Level 3.

thinking:
Classifying this paragraph.

Category: This is about how the board oversees cybersecurity - board oversight, receiving reports from CTO/CISO, incident reporting thresholds. Primary question: "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- CTO (Chief Technology Officer) - named role, firm-specific
- CISO (Chief Information Security Officer) - named role, firm-specific

No verifiable facts (no specific numbers, certifications, named firms, etc.).

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


fact: endpoint monitoring (Red Canary provides 24/7 endpoint monitoring)

fact: cyber security trainings required monthly

fact: physical and cloud-based network data backup solutions

fact: Marco Technologies as Managed IT provider

fact: Red Canary for 24/7 endpoint monitoring

fact: High Point Networks for network data backup

fact: Return to Operations objectives of less than 24 hours

fact: cybersecurity trainings required on a monthly basis

fact: CFO coordinates and manages third-party cybersecurity providers

reasoning: The paragraph describes what the company's cybersecurity program does via third-party providers hired to serve the company (Marco Technologies, Red Canary, High Point Networks), making it RMP per Rule 3. Specificity reaches Level 4 due to multiple named third-party firms (externally verifiable entities) and a specific quantified RTO metric of less than 24 hours.

thinking:
Let me analyze this paragraph.

Content: Describes third-party technology providers (Marco Technologies, Red Canary, High Point Networks) and their roles, plus mentions the CFO's role in coordinating these providers.

Category: This is primarily about third-party providers performing cybersecurity functions for the company. The central topic is how third-party providers handle cybersecurity. But these are third parties hired to serve the company (assessors, service providers) → per Rule 3, that's RMP. Wait, let me re-read Rule 3: "Third parties hired to serve the company (assessors, pen testers) → RMP." So this would be RMP since these are vendors providing services TO the company.

These vendors deliver core cybersecurity activities—monitoring endpoints around the clock, conducting training, managing backups—so this falls squarely under Risk Management Process. The specific details about Marco Technologies, Red Canary, and High Point Networks are all verifiable, and the 24/7 monitoring capability is a concrete operational fact worth noting.


reasoning: This is a forward-looking materiality assessment using SEC Item 106(b)(2) language — 'reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition' — which per Rule 5 is a Strategy Integration conclusion. No domain terms, firm-specific facts, or verifiable claims are present, keeping specificity at Level 1.

thinking:
This is a single sentence stating that cybersecurity threats are "reasonably likely to materially affect" the company. This is the SEC Item 106(b)(2) forward-looking materiality assessment language → Strategy Integration per Rule 5.

Specificity: No domain terms, no firm-specific facts, no verifiable claims. This is generic boilerplate materiality language.

Wait - Rule 5 says "Are reasonably likely to materially affect" → SI (SEC Item 106(b)(2) forward-looking). So this is SI.

For specificity - there's nothing specific here.

So this disclosure gets a Level 1 rating.


fact: Information Security team

fact: Chief Information Officer (CIO)

fact: CIO has led IT efforts since 2016

fact: More than 20 years of experience as an IT leader in the homebuilding industry

fact: CIO reports to Corporate General Counsel

reasoning: The paragraph is entirely about the CIO's role, qualifications, career history, and reporting line — the person-removal test collapses it to near-nothing, confirming MR. 'More than 20 years of experience' is a verifiable lower bound, and 'since 2016' is a specific date, both elevating to Level 4.

thinking:
Classify this paragraph.

Category: This is about the CIO's role, qualifications, experience, and reporting lines. Person-removal test: remove all person-specific content and almost nothing remains. → MR.

Specific facts:
- CIO (named role, firm-specific)
- "since 2016" - specific date
- "more than 20 years of experience" - quantified, verifiable lower bound
- Reports to Corporate General Counsel - firm-specific reporting line
- Information Security team - named team

Specificity: "more than 20 years of experience" is a verifiable lower bound → Level 4.


fact: cybersecurity risk assessment required prior to contract

fact: assessments conducted by information security and enterprise risk management teams with input from key business stakeholders

fact: evaluation of vendor's security program and documentation

fact: information security-related contract terms required for third parties accessing sensitive information

reasoning: The paragraph centrally addresses how the company manages third-party cybersecurity risks — vendor assessments, ongoing monitoring, and contractual requirements — making it Third-Party Risk. The mention of specific teams conducting the assessments (information security and enterprise risk management teams with key business stakeholders) constitutes a firm-specific team composition, elevating to Level 3.

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


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party vendors, service providers, and external users, making Third-Party Risk the clear category. Despite mentioning 'risk-based approach' and monitoring of third-party systems, the language is entirely generic — no domain-specific terms pass the ERM test, no firm-specific facts, and no verifiable claims are present.

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