fact: ransomware attack

fact: late May 2023 timing of the Cybersecurity Incident

reasoning: The paragraph describes a real cybersecurity incident — a ransomware attack in late May 2023 — including investigation, expert engagement, and law enforcement coordination, making it clearly Incident Disclosure. 'Late May 2023' is a specific, verifiable timeframe tied to a real event (publicly reported), elevating specificity to Quantified-Verifiable.

thinking:
Incident disclosure - describes a real ransomware attack with timing and response actions.

Specific facts: "ransomware attack" (domain term), "late May 2023" (specific date), law enforcement engagement.

"Late May 2023" is a specific timeframe tied to a real event - verifiable. "Ransomware" is a domain term.


content_category: Board Governance

fact: Cybersecurity Leadership Team

category_confidence: high

specificity_confidence: high

reasoning: The paragraph answers how the board oversees cybersecurity: Board delegates to Audit Committee, which receives reports from senior management and the Cybersecurity Leadership Team, making it clearly Board Governance. The named 'Cybersecurity Leadership Team' is a firm-specific entity that distinguishes this company's governance structure, elevating specificity to Level 3.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity - Board delegates to Audit Committee, receives reports. This is Board Governance.

Specific facts:
- "Cybersecurity Leadership Team" - named team (firm-specific)
- "Audit Committee" - generic, every company has this, NOT firm-specific

The "Cybersecurity Leadership Team" is a named non-generic team → firm-specific.

Specificity: Firm-Specific (Level 3)


content_category: Strategy Integration

reasoning: The paragraph opens with a backward-looking materiality assessment ('not aware of any cybersecurity incidents or threats that have materially impacted us or our business, financial condition, and results of operations'), making SI the primary category per Rule 5. The remaining sentences are generic speculation ('could adversely affect') and a cross-reference to Risk Factors. No domain terms, firm-specific facts, or verifiable claims are present—the negative materiality assertion is a self-reported claim about absence, not externally verifiable.

thinking:
Materiality assessment + speculation + cross-reference.

The first sentence is a backward-looking materiality assessment: "not aware of any cybersecurity incidents or threats that have materially impacted us" → SI per Rule 5.

The second sentence is generic speculation ("could adversely affect"), and the third is a cross-reference to Risk Factors.

Category: Strategy Integration (the materiality assessment is the lead and substantive claim).

Specificity: The negative materiality assertion is NOT externally verifiable per the rules. No domain terms, no firm-specific facts. This is generic boilerplate.

Wait - "not aware of any cybersecurity incidents or threats that have materially impacted us or our business, financial condition, and results of operations" - this is a materiality conclusion → SI.

The negative self-assertion lacks verifiable support and contains no domain-specific language, so it's Level 1 specificity.


content_category: Incident Disclosure

fact: Third-party vendor Pension Benefit Information, LLC (PBI)

fact: Progress Software Corporation's MOVEit Transfer software

fact: Approximately 850,000 customers' PII compromised

type: quantified

fact: Disclosed in Form 10-Q for quarter ended June 30, 2023

fact: MOVEit software vulnerability exploited

reasoning: This paragraph describes a specific cybersecurity incident — the MOVEit breach via PBI — with timeline, scope, and remediation details, making it Incident Disclosure. Multiple verifiable facts including named firms (PBI, Progress Software), a named product (MOVEit Transfer), and a specific quantity (~850,000 affected customers) elevate to Level 4.

thinking: Incident disclosure about MOVEit breach via PBI vendor.


content_category: Risk Management Process

reasoning: The paragraph lists specific protective and preventative cybersecurity measures, making it squarely about what the program does (RMP). 'Encryption of data in transit and at rest' and 'identity management and access control' are cybersecurity-specific concepts that pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Lists protective/preventative measures including identity management, access control, encryption, network security, monitoring, etc.

Category: RMP - describes what the cybersecurity program does (security measures/controls).

Specificity: Let me check the domain terms.
- "identity management and access control safeguards" - identity management, access control are domain terms
- "encryption of data in transit and at rest" - domain term (encryption at rest/in transit)
- "system and network security and monitoring" - borderline, "network security monitoring" could be domain

- "information protection and governance" - generic

The encryption and identity management concepts are specific enough to pass the ERM test, while the information protection language is too broad. This lands at Level 2 since there are no firm-specific facts or verifiable claims present.


reasoning: The paragraph states a materiality conclusion ('not aware of any cybersecurity incidents...that have had or are reasonably likely to have a material impact on the Company's business strategy, results of operations or financial condition'), which is a backward-looking and forward-looking materiality assessment → SI. The second sentence is a cross-reference to risk factors. No domain terms, firm-specific facts, or verifiable claims are present; the negative self-assertion about no material incidents is not externally verifiable.

thinking:
SI materiality rule check: "not aware of any cybersecurity incidents...that have had or are reasonably likely to have a material impact" → backward-looking materiality assessment → SI.

Second sentence is a cross-reference → N/O by itself, but the first sentence dominates.

Specificity: "not experienced any material cybersecurity incidents" type negative assertion — per rules, this is NOT externally verifiable. No domain terms, no firm-specific facts beyond the standard materiality statement.

This is a standard materiality conclusion.

So this lands at Level 1.


reasoning: The paragraph lists key elements of the cybersecurity risk management program (risk assessments, security team, training, incident response plan, third-party risk management), directly answering what the program does → RMP. Despite its length, every item is generic process language that any ERM professional could write — 'risk assessments,' 'security controls,' 'cybersecurity awareness training,' 'incident response plan,' and 'third-party risk management process' all fail the ERM test. References to AI/GenAI security are topical but stated in generic governance language without domain-specific technical detail.

thinking:
Let me classify this paragraph.

Content: Lists key elements of cybersecurity risk management program - risk assessments, security team, external service providers, training, incident response plan, third-party risk management, AI controls.

Category: This is describing what the cybersecurity program does - RMP. It lists program activities and components.

Specificity: Let me scan for specific facts.
- "risk assessments" - L1
- "security team" - L1
- "external service providers" - L1
- "cybersecurity awareness training" - L1
- "cybersecurity incident response plan" - L1

- "third-party risk management process" - L1
- "AI and generative AI (GenAI)" - domain reference but fairly generic
- "controls framework" - generic
- "data leakage" - somewhat domain-specific but still general

Most of this reads as standard process description. When I apply the ERM test, terms like risk assessments, security controls, incident response plans, and awareness training all show up as commonly confused L1 items. The mention of data leakage and unauthorized access to sensitive information adds some domain specificity, though it's still fairly broad, and the controls framework for emerging technologies like AI is somewhat generic without more concrete details.

Looking at this holistically, it's essentially L1 boilerplate—a generic checklist of program elements without the specialized terminology that would distinguish it as domain-specific. Even "data leakage" is borderline; while a non-security ERM professional might not use that exact phrasing, it's not quite specific enough to push this into higher territory. I'm calling this L1 across the board.


content_category: Third-Party Risk

reasoning: The paragraph centrally addresses how the company oversees third-party vendors—due diligence, data access assessment, controls, and contractual conformity—making Third-Party Risk the clear category. The language is entirely generic process description (due diligence, contractual obligations, controls) that any ERM professional could write without cybersecurity domain knowledge, yielding Level 1.

thinking:
Classify this paragraph.

Content: About third-party vendor review processes - due diligence, assessing data access, controls, contractual requirements. This is centrally about how they manage third-party vendor risk.

Category: Third-Party Risk (requirements imposed ON vendors, vendor oversight as central topic)

Specificity: Let me scan for facts.
- "third party vendor review processes" - generic
- "multiple levels of due diligence" - generic process description
- "contractual rights and obligations" - generic
- No domain terms that pass the ERM test, no firm-specific facts, no verifiable claims

This is all generic vendor oversight language any ERM professional could write.

So this lands at Level 1 - it's purely generic framework language without any specificity or concrete details.


fact: October 2023 cybersecurity incident

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

fact: Security Operations enhancements

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

fact: Customer passwords were reset

reasoning: The paragraph describes a real cybersecurity incident — unauthorized access to user accounts — along with timing, nature, and remediation steps, making it Incident Disclosure. The specific date (October 2023) and the named platform (23andMe.com) are externally verifiable facts, elevating specificity to Quantified-Verifiable.

thinking:
Classify this paragraph.

Content: Describes a real cybersecurity incident (October 2023, user data accessed/downloaded from 23andMe.com accounts), remediation steps taken, and a cross-reference to risk factors.

Category: Incident Disclosure - describes a real event with timing, nature, and remediation.

Specific facts:
- "October 2023" - specific date
- "23andMe.com" - named system/platform
- "Security Operations" enhancements - domain term
- "two-factor verification" (MFA) - domain term
- "detection tools and capabilities" - generic

- The incident itself is a real event with specific timing, and both the date and platform are externally verifiable facts that ground this in a concrete, documented occurrence.


fact: vulnerability management policy

fact: encryption of data

specificity_confidence: medium

reasoning: The paragraph describes what the cybersecurity program does—measures, processes, and policies to manage risks—making it RMP. 'Vulnerability management' and 'encryption' pass the ERM test as domain-specific terms, elevating to Level 2, though the paragraph is otherwise generic boilerplate listing common program elements.

thinking:
Classify this paragraph.

Content: Describes cybersecurity measures - technical, physical, organizational measures, processes, standards, policies to manage risks. Lists examples: incident response plans, incident detection and response policies, vulnerability management policy, disaster recovery plans, encryption of data.

Category: RMP - describes what the cybersecurity program does.

Specificity: Let me check the terms:
- "incident response plans" - L1 (commonly confused)
- "incident detection and response policies and procedures" - borderline, "incident detection" is slightly more domain-specific
- "vulnerability management policy" - "vulnerability management" passes ERM test → L2

- "disaster recovery plans" - L1
- "encryption of data" - encryption is a domain term → L2

Overall, this lands at Level 2 since it includes domain-specific terminology like vulnerability management and encryption alongside more general terms.


content_category: Management Role

fact: threat intelligence

category_confidence: medium

reasoning: Governance-chain paragraph: first two sentences describe Board/Audit Committee oversight (BG), but the majority of text details management's responsibilities—assessing risks, developing risk methodology, supervising internal and external personnel. Per Rule 1, when management's organizational role is the primary content, it becomes MR rather than defaulting to BG. Person-removal test leaves some program description (risk methodology, prevent/detect/mitigate/remediate, threat intelligence, security tools) but the framing is about who is responsible, not what the program does. 'Threat intelligence' passes the ERM test as a cybersecurity-specific term, elevating to Level 2, but no firm-specific facts or verifiable claims are present.

thinking:
Let me analyze this paragraph.

Category: This paragraph starts with Audit Committee reporting to the Board (BG), then shifts to management team responsibilities. The bulk of the paragraph describes management's role and what they do. Let me check - the first two sentences are BG (board oversight, briefings). The rest is about management team responsibilities. The management content is more extensive.

Actually, looking more carefully: "management team is responsible for assessing and managing material risks" - this is about management's role. "developing and maintaining cybersecurity risk methodology" - this could be RMP.

The paragraph also covers management's supervision of both internal personnel and external consultants, which speaks to team composition and reporting structure. Their oversight of prevention, detection, mitigation, and remediation efforts describes the program's operational scope. If I strip away the management framing, what's left is substantive content about cybersecurity methodology, risk management processes, and the program's core functions - but the entire structure emphasizes management's responsibilities and authority rather than the program itself. Looking at the full paragraph now, I see management's role is central—they assess risks, develop methodology, supervise personnel and consultants, and oversee prevention through detection and remediation. The person-removal test on this management section still leaves substantial program description intact, which pushes toward RMP. But the grammatical structure keeps foregrounding management's supervisory responsibilities rather than the program activities themselves, making this genuinely mixed content where governance and program description are intertwined.

The real organizing principle here is the oversight chain—Board delegates to management, management oversees the program—so this reads as a governance-structure paragraph. That governance framing tips it toward BG overall. Management's responsibilities dominate the content here—developing risk methodology, overseeing personnel and consultants, implementing preventive and detective controls through threat intelligence and security tools. Even after removing person-specific references, the substantive program activities remain intact, which points toward Management Role as the classification. Though there's some overlap with governance and risk management program elements, the focus is clearly on what management does to run the cybersecurity function. I'm applying Rule 1 to determine the primary content: management's responsibilities dominate by word count, which would suggest MR. But the person-removal test leaves substantial program description intact, and Rule 2 clarifies that when a management team is the grammatical subject but the content describes what the program does—risk methodology, prevention, detection, mitigation, remediation, threat intelligence, security tools—it should be classified as RMP. That's my final answer.

Now checking for specificity: "Audit Committee" is generic, but "threat intelligence" is domain-specific terminology that a non-security ERM professional wouldn't naturally use, so that counts as domain language.  The other phrases like "security tools" and "prevent, detect, mitigate, and remediate" are fairly standard. I'm settling on Level 2 based on the threat intelligence reference, though I'm moderately confident since the document is genuinely mixed between generic and domain-specific language.


fact: Cybersecurity Incident related costs net of expected insurance receivable totaled $1.0 million in 2023

fact: System remediation concluded as of December 30, 2023

fact: Insurance proceeds exceeded receivable by $0.6 million in Q4 2024

fact: Systems reactivated and restored over the course of the week following the incident

reasoning: The paragraph describes a real cybersecurity incident — its impact on systems, containment, restoration timeline, and financial costs/insurance recovery — squarely answering 'what happened?' (ID). Multiple hard dollar figures ($1.0M, $0.6M) and a specific date (December 30, 2023) are externally verifiable, placing this firmly at Level 4.

thinking: Incident disclosure with specific financial figures and dates.


reasoning: The paragraph answers how the board oversees cybersecurity — audit committee oversight, quarterly meetings with management, and annual reviews — making it Board Governance. The VP of Information Technology is a VP-level title whose portfolio includes IT, qualifying as firm-specific, but no verifiable claims push it to Level 4.

thinking:
Classify this paragraph.

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

Specific facts:
- "audit committee" - generic, every company has one, NOT firm-specific
- "Vice President of Information Technology" - VP-level title whose portfolio includes IT → firm-specific
- "quarterly" meetings - generic cadence, not firm-specific
- "annually" review - generic cadence

Specificity: Level 3 (Firm-Specific) due to VP of Information Technology being a VP-level IT role.


fact: security controls

reasoning: The paragraph is centrally about how the company manages third-party cybersecurity risks through its TPRM program and vendor security assessments, making Third-Party Risk the clear category. The named 'TPRM program' with its acronym qualifies as a firm-specific named internal program, elevating specificity to Level 3, while 'security controls' is a domain term passing the ERM test.

thinking:
Classify this paragraph.

Content: About third-party risk management program (TPRM), gathering info from third parties to assess their security controls.

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

Specific facts:
- "third-party risk management (TPRM) program" - named internal program with acronym → firm-specific
- "security controls" - domain term? Let me think... "security controls" is a domain term that passes the ERM test.

Actually, "TPRM program" - is this firm-specific? It's a named program with a distinguishing identifier (the acronym).

Per the rules, named internal programs with distinguishing identifiers are firm-specific, so this lands at Firm-Specific (Level 3).


fact: patching and vulnerability management

fact: cybersecurity tabletop exercise

reasoning: The paragraph describes how management presents cybersecurity reports to the full Board, including briefing frequency and topics covered—squarely answering the board oversight question (BG). Domain terms like 'patching and vulnerability management' and 'cybersecurity tabletop exercise' pass the ERM test, elevating to Level 2, but no firm-specific facts (roles are generic 'management' and 'Board') or verifiable claims are present.

thinking:
Classify this paragraph.

Category: This describes how information flows to the board - briefing frequency and scope. That's Board Governance.

Specific facts:
- "semiannual briefings" - generic cadence
- "patching and vulnerability management" - domain term (passes ERM test)
- "cybersecurity tabletop exercise" - this is borderline; "tabletop exercises" without cyber qualifier is L1, but "cybersecurity tabletop exercise" has the qualifier
- "security awareness training" - domain term? ERM professional could say this... borderline

- "information security organization" - generic
- "technical threats" - generic
- "information technology security infrastructure" - generic
- "cybersecurity threat assessment" - borderline

The paragraph covers board briefing topics with mixed terminology. "Patching and vulnerability management" clearly passes the ERM test, while "cybersecurity tabletop exercise" and "security awareness training" are borderline domain terms that an ERM professional would recognize. The cadence references are generic, and most other terms like "technical threats" and "IT security infrastructure" lack the specificity needed for L2 classification.

Level 2 still seems appropriate here.


fact: phishing simulations

fact: targeted attack simulations

fact: identification and testing of vulnerabilities

reasoning: The paragraph describes what the Adviser's cybersecurity program does — vulnerability testing, phishing simulations, training, internal/external security reviews — all program activities, making it RMP. Domain terms like phishing simulations, targeted attack simulations, and vulnerability testing pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Describes the Adviser's cybersecurity program activities - vulnerability testing, phishing simulations, training, internal/external reviews, attack simulations. This is about what the program does → RMP.

Specific facts:
- "phishing simulations" - domain term (specific security practice)
- "cybersecurity awareness training" - borderline, but common enough
- "targeted attack simulations" - domain term (penetration testing variant)
- "vulnerability" testing - domain term

Specificity: Domain terms present → Level 2


fact: Senior Vice President of Engineering and CISO

fact: CISO reports to CEO

fact: Chief Privacy Officer reporting to General Counsel

fact: Privacy and Security Council

reasoning: The paragraph primarily describes management's organizational structure for cybersecurity—named roles, reporting lines, and committee membership—making it MR. While some program activities are mentioned (establishing priorities, integrating into ERM), the person-removal test leaves only generic descriptions. Multiple firm-specific facts (VP+ roles like SVP of Engineering/CISO, CPO, and the named Privacy and Security Council) elevate to Level 3.

thinking:
Let me analyze this paragraph.

Category: This describes management's organizational structure for cybersecurity - roles, reporting lines, committee membership. The person-removal test: remove all person-specific content and what remains is generic ("helps us understand cybersecurity threats and risks, establish priorities, and determine the scope, elements, and implementation of a cybersecurity program" and "integrating cybersecurity considerations into our overall risk management strategy"). Some program description remains but the primary focus is WHO is involved and HOW they're organized. This is MR.

Specific facts:
- SVP of Engineering - named role (VP+ level)

- CISO as a named role reporting directly to the CEO, along with the General Counsel and Head of Global Affairs also in named positions, and the Chief Privacy Officer reporting through the General Counsel - these are all firm-specific organizational relationships
- Privacy and Security Council as a named committee

No quantified claims here, just structural details that are specific to this company, pushing this toward Level 3.


reasoning: The first clause is a backward-looking negative assertion ('has not experienced any material cybersecurity breaches during the reporting period'), which per Rule 5 qualifies as a materiality assessment → SI. The second clause ('could have a material adverse effect') is generic speculation present in every 10-K and does not independently qualify. No domain terms, firm-specific facts, or verifiable claims elevate specificity above Level 1.

thinking:
Let me analyze this paragraph.

"Although CLEAR has not experienced any material cybersecurity breaches during the reporting period, we acknowledge that cyber incidents, if they were to occur, could have a material adverse effect on our financial results."

Category: The first clause is a negative assertion about incidents, the second is speculation. Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI (negative assertion). The speculative part ("could have a material adverse effect") is NOT SI. But the negative assertion IS SI. The paragraph's primary purpose is making a materiality assessment (backward-looking negative assertion).

Now looking at specificity — the claim about not experiencing breaches is a self-assertion without external verification, and it lacks domain-specific terminology or firm-specific details that would meet the ERM standard. This lands at Level 1.


fact: CISO role

fact: Committee includes members of executive management and leaders of business functional areas

fact: CISO has over 20 years of experience in information security

fact: CIO Executive Education Certificate from Stanford University

reasoning: The paragraph describes who is responsible for cybersecurity (CISO and steering committee) and the CISO's qualifications—classic Management Role content that collapses under the person-removal test. Specificity reaches Level 4 via 'over 20 years of experience' (verifiable lower bound) and the Stanford CIO Executive Education Certificate (verifiable credential from a named institution).

thinking:
Let me analyze this paragraph.

Content: Describes CISO and steering committee roles/responsibilities, CISO qualifications.

Category: This is about management's organizational role - who is responsible, their qualifications, committee membership. Person-removal test: remove CISO, steering committee membership, 20 years experience, Stanford cert → almost nothing remains. → MR

Specific facts:
- CISO (named_role) → firm-specific
- Steering committee on information security (named_committee) → firm-specific
- "members of our executive management as well as leaders of business functional areas" (specific_team composition)

- The CISO's experience threshold of over 20 years and Stanford Executive Education Certificate are both verifiable credentials that push this to Level 4 specificity.


fact: CRO supervises the CISO

fact: CTO on executive team coordinating on cybersecurity

fact: CLO (Chief Legal Officer) on executive team

fact: Information Security Program (capitalized, named program)

reasoning: The paragraph primarily describes management's organizational structure for cybersecurity — the CISO reporting to the CRO, coordinating with a named set of C-suite executives. The person-removal test leaves only a thin generic program description, confirming MR. Multiple named VP+ roles (CISO, CRO, CTO) and the specific reporting line (CISO under CRO) are firm-specific facts, placing this at Level 3.

thinking:
Let me analyze this paragraph.

Category: This describes the CISO's role, reporting line (under CRO), coordination with executive team, and what they do (implement the Information Security Program). The person-removal test: remove CISO, CRO, CEO, CFO, CTO, CLO titles and reporting lines — what remains is "implement the Information Security Program, which is designed to protect the Company's information systems from cybersecurity threats and to promptly respond to any cybersecurity incidents in accordance with the Company's incident response and recovery plans." That's a generic program description but not very substantive. The paragraph is primarily about WHO is responsible and HOW they're organized (CISO under CRO, coordinating with executive team).

This leans MR because the firm-specific elements are concentrated in the organizational structure itself — the CISO, CRO, and CTO are named roles, and the reporting relationship between CISO and CRO is firm-specific, while the actual security program and incident response plans are described generically.


fact: CISO provides updates to Audit Committee and Board

fact: Chief Information Officer provides updates to Audit Committee and Board

reasoning: The paragraph describes how the Board and Audit Committee oversee cybersecurity risks, including briefing cadence and escalation protocols, squarely answering the Board Governance question. Specificity reaches Level 3 due to named VP-level roles (CISO, CIO) delivering updates, though the rest is standard governance language.

thinking:
Classify this paragraph.

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

Specific facts:
- Audit Committee oversight → generic, every company has this
- "comprised solely of independent directors" → generic governance fact
- "quarterly or as needed updates" → generic cadence
- CISO → firm-specific named role
- Chief Information Officer (CIO) → firm-specific named role
- Escalation protocols to Audit Committee and Board → generic process

Level 3 for CISO and CIO.


fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)

reasoning: The paragraph primarily answers how the board oversees cybersecurity — the Audit Committee receives quarterly reports and evaluates cybersecurity risks as part of its annual assessment, then relays findings to the Board. While ERM integration and Internal Audit review are mentioned, the dominant frame is governance oversight. Specificity is Firm-Specific due to named CIO and CISO roles reporting to the Audit Committee; Audit Committee itself is generic and doesn't count.

thinking:
Let me analyze this paragraph.

Category: This describes board/committee oversight (Audit Committee receiving reports, evaluating risks, providing info to Board). The governance chain (Board → Audit Committee → CISO/CIO) is described for oversight purposes → Board Governance.

But it also mentions ERM integration and Internal Audit reviewing controls. The primary frame is oversight structure though.

Specific facts:
- CISO (named_role) → firm-specific
- CIO (named_role) → firm-specific
- Audit Committee - generic, every company has one → not firm-specific
- "quarterly basis" - generic cadence

- Internal Audit Group → not clearly firm-specific enough
- "annual assessment" - generic

The named roles (CISO and CIO) push this to Level 3, even though most other elements are generic governance practices.


reasoning: The paragraph's central topic is managing cybersecurity risks from third-party service providers and supply chain, including requiring vendors to manage risks and submit to audits → TP. The language is entirely generic ('processes to identify, monitor and address material risks,' 'manage their cybersecurity risks in specified ways,' 'cybersecurity audits') — an ERM professional could write all of this without domain expertise, yielding Level 1.

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

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

"cybersecurity audits" - this is a domain term that passes the ERM test? Actually, "audits" is pretty generic. But "cybersecurity audits" is somewhat domain-specific.

The paragraph describes processes for managing third-party risks - vendor oversight is the central topic → TP.

Looking at specificity: "identify, monitor and address material risks" - generic.

The language throughout feels quite generic - standard vendor risk management concepts applied to cybersecurity without much specificity. "Cybersecurity audits" is really just a generic audit practice with cybersecurity added on. This looks like Level 1 boilerplate language that any ERM professional could produce.


reasoning: The paragraph contains a negative incident assertion ('To date, we have not had a cybersecurity incident'), which per the SI materiality rule constitutes a backward-looking assessment of cybersecurity's impact on the business. The speculative risk language ('could have a material adverse effect') is explicitly not SI, and the generic detection/prevention language is too thin for RMP, making the negative assertion the most substantive claim. Specificity is Level 1 because the language is entirely generic — no domain terms pass the ERM test, the negative assertion is not externally verifiable, and no firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: Mix of risk language, a negative incident assertion, some program description, and a cross-reference.

Category: The paragraph opens with speculative risk language ("could have a material adverse effect"), mentions no material incidents to date, describes some proactive measures, and cross-references Item 1A.

"To date, we have not had a cybersecurity incident" - this is a negative assertion about incidents. Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI. But here it says "not had a cybersecurity incident" (not even "material"). This is a backward-looking assessment.

The dominant frame is speculative risk language rather than a definitive statement about cybersecurity's impact, though the negative incident assertion does lean toward SI. The cross-reference to Item 1A pulls in an N/O element, and the detection language is fairly generic risk management without much substance. The paragraph mixes several elements—speculative risk language that doesn't qualify as SI, a negative incident assertion that does, some generic detection language, and regulatory cross-references. The negative assertion "we have not had a cybersecurity incident" is the clearest SI indicator, but it's buried among content that reads more like risk disclosure than strategic assessment. I'm leaning toward SI based on that assertion, though the dominant tone is really about potential adverse effects rather than actual strategic positioning.

Looking at specificity, the language stays generic throughout—"cybersecurity incident," "IT assets," standard detection and investigation language. The negative self-assertion itself isn't verifiable under the rules, and there are no firm-specific facts, named roles, or frameworks present. This reinforces that while the SI marker exists, the overall paragraph lacks the substantive detail that would push it higher on specificity.

The cross-reference to Item 1A doesn't add specificity either, so I'm settling on Level 1 as the appropriate classification.


fact: ransomware attack

fact: March 2020 — specific date of the ransomware incident

fact: confidential information was stolen, including potential trade secrets and employee personal information

reasoning: The paragraph opens with an SI materiality conclusion but the bulk of the text describes a real cybersecurity incident — the March 2020 ransomware attack, its scope (systems accessed, confidential information stolen), response (isolated source, restored operations), and potential consequences. Per Rule 4, the incident frame dominates the text volume, making this ID over SI. Specificity reaches Level 4 via the specific date 'March 2020' tied to a verifiable real-world ransomware event.

thinking:
This is a complex paragraph that combines multiple elements. Let me analyze it.

The paragraph starts with a materiality assessment ("have not identified risks... that have materially affected or are reasonably likely to materially affect us") → SI per Rule 5.

Then it describes an actual incident (March 2020 ransomware attack) → ID.

Then it discusses potential business/financial impact of that incident → mixed ID/SI.

Per Rule 4: Mixed with incident frame dominant → ID. But actually, the paragraph STARTS with an SI materiality conclusion, then describes the incident as context, then discusses potential impacts.

Let me look at the text distribution.

The materiality statement is one sentence. The incident description (what happened, what was stolen, potential consequences) takes up most of the paragraph. The financial/business impact assessment frames are interwoven. The paragraph opens with SI (materiality assessment), then pivots to describing a real incident (ransomware attack in March 2020 - timeline, scope, response, consequences). The incident details dominate the middle. Then it returns to materiality/impact framing.

The opening materiality statement is brief, but the bulk of the paragraph is devoted to the incident itself—what occurred, what was compromised, and the potential ramifications. The financial and business impact language is woven throughout rather than concentrated in one section. So while this starts as an SI frame, the incident description is substantial and central to the overall message, making this genuinely mixed content where the incident narrative carries significant weight. The incident itself is clearly the narrative center here, even though materiality language frames it. The specific date of March 2020 and the term "ransomware" give this concrete, verifiable details that push it toward Level 4 specificity—this is a real event with domain-specific terminology, not a generic risk discussion.


fact: VP of IT role (VP-level title with IT/security portfolio)

fact: NVP of Finance role

fact: Cybersecurity Response Committee

fact: Over 24 years of experience in IT and information security

fact: Previously served as CISO of a healthcare company

fact: Member of cyber emergency response team at several companies

fact: Over 50 years of collective experience managing enterprise risks

reasoning: The paragraph is entirely about the qualifications, experience, and credentials of management personnel (VP of IT, NVP of Finance, Cybersecurity Response Committee members), making it clearly Management Role. Specificity reaches Level 4 via verifiable lower-bound claims: 'over 24 years' of IT/infosec experience and 'over 50 years of collective experience,' both checkable against resumes/records.

thinking:
Let me analyze this paragraph.

Content: Describes qualifications and experience of VP of IT, NVP of Finance, and Cybersecurity Response Committee members. This is about who these people are and what qualifies them - classic Management Role.

Specific facts:
- VP of IT (named role, VP-level with IT portfolio) → firm-specific
- "over 24 years" in IT/infosec → quantified-verifiable (lower bound, ≥24)
- CISO of a healthcare company (prior role) → other_specific
- Cyber emergency response team membership → domain_term

- NVP of Finance also holds a named role at VP-level → firm-specific
- Cybersecurity Response Committee is a named committee → firm-specific
- "over 50 years of collective experience" represents a verifiable lower bound across the group
- Professional certifications mentioned but not specifically named, so they're harder to verify


fact: Three Directors with cybersecurity risk management experience

fact: Ann Bordelon, Chair of the Audit Committee, named as having cybersecurity experience

fact: Paulette Dodson named as having cybersecurity risk management experience

fact: Noah Glass named as having cybersecurity risk management experience

reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity threats, including briefing content and board member expertise — classic Board Governance. Specificity reaches Level 4 due to the hard count of three directors and three named individuals (Ann Bordelon, Paulette Dodson, Noah Glass) whose cybersecurity experience claims are externally verifiable.

thinking:
Classify this paragraph.

Category: Board Governance - describes board/committee oversight of cybersecurity, board member expertise.

Specific facts:
- Audit Committee (generic, not firm-specific)
- Three named directors: Ann Bordelon, Paulette Dodson, Noah Glass - named individuals in cybersecurity context → firm-specific
- Ann Bordelon as Chair of the Audit Committee → firm-specific
- "three Directors" with cybersecurity risk management experience → quantified (3 is a hard number, verifiable)

Specificity: Quantified-Verifiable due to named individuals and specific count of 3 directors.


content_category: None/Other

reasoning: The paragraph's primary content is a cross-reference to Item 1A Risk Factors, with only a single generic sentence about senior leadership evaluating risks — no substantive cybersecurity disclosure. No domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

The first sentence is generic about senior leadership evaluating cybersecurity risks. The second sentence is a cross-reference to Item 1A. This is mostly a cross-reference paragraph with minimal substantive content.

Category: The first sentence vaguely touches management/governance but is too thin. The second sentence is a cross-reference. This is largely N/O due to the cross-reference nature and lack of substantive disclosure.

Wait - "evaluated by senior leadership" could be BG or MR, but it's extremely thin. The dominant content is the cross-reference. Let me think about whether the first sentence is substantive enough.

The opening statement about senior leadership evaluating cybersecurity risks is too vague and generic to constitute real disclosure—there are no domain-specific details, firm-specific facts, or verifiable claims here. Combined with the cross-reference that makes up the bulk of the paragraph, this reads as N/O.


reasoning: The paragraph describes a governance chain from Board → Audit Committee → CFO, which per Rule 1 defaults to Board Governance when the purpose is describing oversight structure. No domain-specific cybersecurity terms pass the ERM test (enterprise risk assessment, risk management process are generic ERM language), no firm-specific facts (Audit Committee and CFO are generic), and no verifiable claims, leaving this at Level 1.

thinking:
Let me analyze this paragraph.

Category: This describes both board oversight (Board of Directors, Audit Committee) and management roles (CFO). The paragraph starts with board oversight structure then transitions to management responsibility. The board/committee oversight is about half, and the CFO's role is about half. The primary question answered is "how does the board oversee cybersecurity" AND "how is management organized." The governance chain from Board → Audit Committee → CFO is described. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. But the last two sentences focus on management's role. This is genuinely split.

Looking at the sentence breakdown, the first three sentences establish the board and committee oversight structure, while the final two focus on CFO responsibilities. The paragraph's core purpose is mapping out this governance chain from the Board down through the Audit Committee to the CFO level. Since the oversight structure is the primary frame, this falls under BG.

Specificity: The Audit Committee and Chief Financial Officer are standard roles found across most organizations, not firm-specific details.  "Enterprise risk assessment" and "cybersecurity risk management program" are both generic ERM terminology without any domain-specific language or verifiable claims. This is Level 1 content.


fact: CCO (Chief Compliance Officer) role

fact: CIO role

fact: CISO role

fact: Operational Risk functions

fact: Morgan Stanley's Cybersecurity Program

reasoning: The paragraph answers how the board oversees cybersecurity — describing periodic updates from specific roles to the Board — making it Board Governance. Firm-specific facts include named roles (CCO, CIO, CISO), the Operational Risk functions team, and the explicit reference to Morgan Stanley's Cybersecurity Program, but no hard verifiable numbers push it to Level 4.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity - BG. The paragraph describes how the board oversees cybersecurity, receives updates, etc.

Specific facts:
- CCO (Chief Compliance Officer) - named role
- CIO - named role
- CISO - named role
- "Morgan Stanley's Cybersecurity Program" - named program/firm
- "Operational Risk functions" - could be firm-specific team

Specificity: We have CISO, CIO, CCO as firm-specific roles (VP+ level). We also have "Morgan Stanley" as a named firm. These are firm-specific facts → Level 3.

The reference to Morgan Stanley's Cybersecurity Program is a named firm reference, and there are no verifiable claims with hard numbers, so this stays at Level 3.


fact: Chief Information Security Officer (CISO) role

reasoning: Person-removal test: removing the CISO and management references leaves a substantive program description (protecting information systems, deploying multidisciplinary teams, incident response plans, real-time monitoring) → RMP. The reporting-to-Audit-Committee clause is subordinate. Specificity is Level 3 due to the CISO role; remaining language ('incident response and recovery plans', 'prevention, detection, mitigation and remediation') is generic and fails the ERM test.

thinking:
Classify this paragraph.

Category: The paragraph describes how the CISO and management implement a cybersecurity program, deploy teams, monitor incidents, and report to the Audit Committee. Person-removal test: remove CISO and management references - "a program designed to protect information systems from cybersecurity threats and to promptly respond to any cybersecurity incidents. Multidisciplinary teams throughout the Company are deployed to address cybersecurity threats and to respond to cybersecurity incidents in accordance with the Company's incident response and recovery plans. Monitor the prevention, detection, mitigation and remediation of cybersecurity incidents in real time, and report such incidents to the Audit Committee when appropriate." Substantial program description remains → RMP.

Now I'm checking the specificity of the language used. The CISO is a named, firm-specific role at VP level, which pushes this toward Level 3, while most other elements like incident response plans, the monitoring framework, and the Audit Committee are generic governance terms that don't add firm-specific detail.


reasoning: The paragraph is a generic hedging statement about ongoing cybersecurity risk exposure and a vague commitment to improvement—it does not substantively answer any of the six category questions (no program details, no governance structure, no materiality assessment, no incident). None/Other paragraphs receive Generic Boilerplate.

thinking:
Classify this paragraph.

This is a generic statement about cybersecurity risk exposure and commitment to strengthening posture. No specific measures, no materiality assessment, no program details.

"remain exposed to the risk of cybersecurity threats" - generic
"controls currently in place provide a meaningful level of protection" - vague
"committed to continuing to strengthen its cybersecurity posture as resources allow" - generic

This doesn't answer any of the six substantive questions meaningfully. It's generic forward-looking/hedging language. But does it make a materiality-adjacent statement? "provide a meaningful level of protection" is not a materiality assessment per Rule 5.

This is just vague reassurance without any real substance. I'm categorizing it as generic boilerplate—there's no meaningful cybersecurity disclosure here, just hedging language that avoids any concrete commitments or risk assessments.


fact: VP of IT provides reports to the Audit Committee

fact: emerging threat landscape

fact: information security systems

fact: information security program

reasoning: The paragraph primarily answers how the board oversees cybersecurity — delegation to Audit Committee, reporting cadence, and information flow from management to the board — making it Board Governance. The VP of IT is a VP-level title with IT portfolio, qualifying as firm-specific (Level 3), while domain terms like 'threat landscape' and 'information security program' provide Level 2 support.

thinking:
Let me analyze this paragraph.

Category: This describes board/committee oversight structure and how information flows to the board. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- VP of IT (named role, VP-level IT title - but "VP of IT" without security qualifier... the rules say "VP/SVP/EVP of IT" IS firm-specific)
- "at least annually" reporting cadence - generic
- Audit Committee - generic, every company has one
- CEO - generic
- Updates on cyber risks, threats, project status, assessments, emerging threat landscape - describes content of reports

- VP of IT definitely counts as firm-specific per the rules. Now I'm checking whether the domain terminology passes the ERM test. "Threat landscape" and "information security program" are security-specific enough that a general ERM professional wouldn't naturally use them, so those count as domain-adapted language.

Since VP of IT is firm-specific, this lands at Level 3.


fact: Security incident occurred in January 2023

fact: Incident impacted the advisor's computer systems

fact: Incident was reported to federal law enforcement

reasoning: The paragraph describes a real security incident — its timing, impact, response, and outcome — making it Incident Disclosure. The specific date 'January 2023' and the report to federal law enforcement are externally verifiable facts, elevating specificity to Quantified-Verifiable.

thinking: Incident disclosure about a real security incident at the advisor in January 2023.


reasoning: The paragraph describes the company's incident response process (initial assessment, cross-functional team review, materiality evaluation), which answers 'what does the cybersecurity program do?' → RMP. Despite the procedural detail, the vocabulary (initial assessment, scope, impact, cross-functional team, materiality) is standard ERM language with no cybersecurity domain terms, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Content: Describes incident response process - initial assessment, cross-functional team meeting, scope evaluation, materiality assessment. This is about what the cybersecurity program does in response to incidents - RMP.

Specific facts: "cross-functional team" is generic. "IT team" is generic. The paragraph describes incident response procedures but uses mostly generic language. "financial and non-financial measures of materiality" - this is process description. No domain terms that pass the ERM test really. "initial assessment to estimate scope and potential impact" - generic.

Actually, this is describing an incident response process in detail but without domain-specific terminology.

The language here is accessible to any ERM professional without specialized knowledge - there are no named roles beyond VP level, no specific frameworks referenced, and no verifiable facts that would distinguish this from generic incident response guidance.

Level 1.


reasoning: Despite the 'Management's Role' heading, the paragraph primarily describes information flowing FROM management TO the audit committee — quarterly briefings, reporting topics, and transparency for board decision-making — which answers 'how does the board oversee cybersecurity?' The bulleted topics (policies, threat landscape, incident reporting, investments, compliance) are generic reporting categories that any ERM professional would recognize; no domain-specific terms pass the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes management providing briefings to the audit committee. The heading says "Management's Role Managing Risk" but the content is about what information flows to the board/audit committee. This is about how information flows to the board - oversight structure. The briefings are FROM management TO the audit committee. This is describing the governance chain - how the board stays informed. Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure.

But wait - the heading says "Management's Role" and it describes what management provides. The primary question answered is "how does the board oversee cybersecurity?" since it's about what the audit committee receives. BG.

Now I'm checking the specificity. The briefings cover standard topics like policies, threat landscape, incident reporting, and compliance - all generic management reporting categories. "Incident response plans" is commonly confused and stays L1. "Threat landscape assessment" is fairly generic terminology that wouldn't distinguish this as domain-specific. There are no firm-specific facts or verifiable claims here, just standard governance reporting categories.


reasoning: The paragraph's primary content is the CISO's responsibilities—oversight, coordination, recommending adjustments, communicating risk posture—which are role descriptions rather than program activities. Applying the person-removal test, removing the CISO leaves a description of organizational duties (oversight, coordination, communication) rather than substantive cybersecurity operations, pointing to MR. The CISO title is a firm-specific VP+-level role, elevating specificity to Level 3, but no verifiable claims or domain-specific technical terms push it higher.

thinking:
Classify this paragraph.

The paragraph describes the CISO's role and responsibilities - providing oversight of the Program, coordinating with corporate functions, recommending adjustments, communicating risk posture.

Person-removal test: Remove CISO, titles, etc. What remains? "provides oversight and direction for the Program and coordinates with other corporate functions and business segments to address all aspects of the Program, including recommending adjustments in response to changes in technology, internal or external threats, business processes, and regulatory or statutory requirements, and communicates the information security risk posture to the relevant internal individuals, committees and departments." This describes the role's responsibilities, not program activities per se.

The content is really about the CISO's organizational responsibilities and how they function within the company structure - it's borderline between describing the role itself versus the program's activities. Since the CISO is a named, firm-specific position at the VP level and the paragraph focuses on what they do rather than what the program does, this leans toward MR classification. The specificity here is firm-specific, so that's a Level 3.


reasoning: The paragraph states a backward-looking materiality conclusion ('risks from cybersecurity threats have to date not materially affected us, our business strategy, results of operations or financial condition'), which is the SEC Item 106(b)(2) assessment → SI. No domain terms, firm-specific facts, or verifiable claims are present; the negative materiality assertion is a self-reported claim about absence and is not externally verifiable, and the cross-reference to Risk Factors is boilerplate.

thinking: Strategy Integration - materiality assessment statement.


fact: CISSP certification held by team members

fact: CCNP certification held by team members

fact: CISA certification held by team members

fact: CySA+ certification held by team members

reasoning: The paragraph describes the management team's qualifications for handling cybersecurity, making it MR (about who is responsible and what qualifies them). Specificity is QV because specific certifications (CISSP, CCNP, CISA, CySA+) are named as currently held, which are independently verifiable via their respective certification bodies.

thinking:
Classify this paragraph.

Category: This is about management team qualifications and certifications. MR.

Specificity: "CISSP, CCNP, CISA, and CySA+" are named certifications that are verifiable. "Extensive years of collective experience" is soft/vague. The certifications are specifically named and independently verifiable via certification bodies.

Wait - "hold multiple certifications, including CISSP, CCNP, CISA, and CySA+" - these are verifiable claims about holding certifications. Level 4.


reasoning: The paragraph opens with a backward-looking materiality assessment ('we do not believe that our business strategy, results of operations or financial condition have been materially adversely affected by any cybersecurity incidents'), which is the hallmark of SI per Rule 5. The remainder is general threat landscape commentary and a cross-reference to Risk Factors. No domain-specific terms pass the ERM test (e.g., 'cybersecurity capabilities,' 'cyber attacks' are generic), no firm-specific facts, and no verifiable claims, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

Content: The paragraph starts with a materiality assessment ("we do not believe that our business strategy, results of operations or financial condition have been materially adversely affected"), then discusses cyber threat landscape generally, mentions investing in enhancements, and ends with a cross-reference to Risk Factors.

Category: The opening statement is a backward-looking materiality assessment → SI per Rule 5. The rest is general discussion and a cross-reference. The materiality assessment is the lead and most distinctive content.

Specificity: Let me scan for facts:
- "we do not believe that our business strategy, results of operations or financial condition have been materially adversely affected" → This is a negative self-assertion about materiality, not externally verifiable

- The language around cybersecurity and cyber attacks uses generic terminology that any company would employ, nothing domain-specific or firm-particular
- No named individuals, committees, or internal structures mentioned
- No concrete, verifiable claims about actual incidents or outcomes
- The boilerplate nature is evident—this reads like standard language that could apply to any business, regardless of industry

This is clearly Level 1 generic boilerplate.


fact: Enterprise Risk Committee ("ERC") led by CEO

fact: Operational Risk Committee ("ORC")

fact: Chief Information Security Officer ("CISO")

fact: Cybersecurity team coordinates with Compliance, Human Resources, Internal Audit and Legal

reasoning: The paragraph describes how management is organized to handle cybersecurity: two named management-level committees (ERC, ORC), the CISO's reporting responsibilities, and cross-functional coordination—all focused on organizational structure and reporting lines rather than board oversight or program activities. Firm-specific due to named committees (ERC, ORC), CISO role, and specific departmental stakeholders listed.

thinking:
Let me analyze this paragraph.

Category: This describes governance/oversight structure with committees (ERC, ORC) and roles (CEO, CISO). The ERC and ORC are management-level committees. The paragraph describes how management is organized to handle cybersecurity - committee structure, membership, reporting lines, and the CISO's responsibilities. This is MR.

Wait - the ERC is led by the CEO and includes cross-functional representatives. The ORC applies ERC policy decisions. The CISO reports to ORC and ERC. This is about management organizational structure → MR.

The details here are quite specific to this firm: the ERC and ORC are named committees, the CISO role is firm-specific, and the coordination with Compliance, HR, Internal Audit, and Legal shows their particular team composition. The annual reporting cadence is also explicitly stated. This points to Level 3 specificity.


reasoning: The paragraph describes identifying internal risks to electronic records and mitigating them through employee communication/training at onboarding and annually — these are program activities, making it RMP. No domain-specific terminology passes the ERM test (security, confidentiality, integrity of records, employee communication are all generic risk management language), no firm-specific facts, and no verifiable claims, leaving it at Level 1.

thinking:
Classify this paragraph.

Content: Describes internal risks to security/confidentiality/integrity of electronic records, mentions the Sponsor identified risks and procedures, mentions internal threats and employee communication at onboarding and annually.

Category: This is about risk management processes - identifying risks and mitigating them through employee training/communication.

Specificity: Let me check for specific facts. "at onboarding and annually" - generic cadence. "personal information" - not domain-specific. "electronic records" - generic. No domain terms that pass ERM test, no firm-specific facts, no verifiable claims.

So this lands at Level 1.


fact: risk assessments for vendors

fact: reviewing vendors' written security programs

fact: security questionnaires

fact: vulnerability scans related to vendors

reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party vendors—vendor assessments, contractual obligations, and oversight processes—making it Third-Party Risk. Domain terms like vulnerability scans, security questionnaires, and reviewing written security programs pass the ERM test, but nothing is firm-specific (no named roles, programs, or teams) or verifiable.

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


reasoning: The paragraph's central purpose is stating a materiality conclusion ('these incidents have not had a material impact on our business strategy, results of operations, or financial condition'), which is a backward-looking assessment triggering SI per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present—past incidents are referenced only vaguely, the cross-reference is boilerplate, and the negative materiality assertion is a self-reported claim not externally verifiable.

thinking:
Let me analyze this paragraph.

It discusses past incidents (not material), a materiality assessment, and a cross-reference to risk factors.

Category: The paragraph states a conclusion about whether cybersecurity has affected business outcomes ("these incidents have not had a material impact on our business strategy, results of operations, or financial condition") → SI per Rule 5. It also references past incidents but doesn't describe them in detail.

Specificity: "have not had a material impact on our business strategy, results of operations, or financial condition" is a negative self-assertion, not externally verifiable. No domain terms, no firm-specific facts, no verifiable claims.

The cross-reference to risk factors is just boilerplate, but the vague mention of past threats to data and systems combined with the materiality conclusion makes this primarily a SI disclosure. The specificity level is minimal—there are no domain-specific terms that would pass scrutiny, no concrete facts about the company, and nothing that could be independently verified.


fact: encryption

fact: data loss prevention technology

fact: authentication technology

fact: entitlement management

fact: access control

fact: anti-virus and anti-malware software

fact: transmission of data over private networks

fact: National Institute of Standards and Technology Cybersecurity Framework (NIST CSF)

type: framework

reasoning: The paragraph describes protective measures and controls of the cybersecurity program (RMP). It contains numerous domain-specific security terms (encryption, DLP, entitlement management, anti-malware) and references NIST CSF as informing the program, but 'informed by' is aspirational rather than a verifiable certification claim, so specificity stays at Level 2.

thinking:
Classify this paragraph.

Category: Describes what the cybersecurity program does - protective measures, types of risks addressed, framework. This is RMP.

Specific facts:
- Domain terms: encryption, data loss prevention technology, authentication technology, entitlement management, access control, anti-virus and anti-malware software, private networks - these pass the ERM test
- NIST CSF - framework reference (domain term/framework)

No firm-specific facts (no named roles, no specific committees). No verifiable claims. Level 2.


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

reasoning: The paragraph describes what the cybersecurity program does — risk assessment, monitoring, incident response, user awareness — answering the 'what does the program do?' question, making it RMP. Nearly all language is generic boilerplate ('comprehensive approach,' 'robust protective measures,' 'swiftly responding'), but the explicit reference to 'confidentiality, integrity, and availability' invokes the CIA triad, a foundational information security concept that a non-security ERM professional would not naturally use, nudging specificity to Level 2.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity program - policies, procedures, risk assessment, monitoring, incident response, training. This is about what the program does → RMP.

Specificity: Let me scan for facts.
- "confidentiality, integrity, and availability" - CIA triad is a domain concept, but it's so widely used... does it pass the ERM test? An ERM professional might use "confidentiality, integrity, and availability" but it's really a security-specific framing. Actually, CIA triad is foundational cybersecurity terminology. Let me think - would a non-security ERM professional naturally say "confidentiality, integrity, and availability"? Possibly not in that exact formulation. But it's borderline.

- The rest of the language is fairly generic—risk assessment, protective measures, user awareness, monitoring, incident response. The CIA triad stands out as the most security-specific terminology, though it's become common enough in corporate disclosures that it might not be a strong differentiator. Applying the ERM test strictly, I'd say it does qualify as a domain term since it's a foundational security framework concept.


reasoning: The paragraph's central topic is requirements imposed ON third-party service providers — contractual obligations, pre-engagement reviews, annual re-evaluation, and data deletion at termination — making Third-Party Risk the primary category. Despite some detail, the vocabulary (risk objectives, defined thresholds, enterprise risk program, contractual obligations, annual re-evaluation, industry best practices) is standard vendor risk management language any ERM professional would use; no cybersecurity-specific domain terms pass the ERM test, keeping this at Level 1.

thinking:
Let me analyze this paragraph.

Category: This paragraph discusses third-party risk management extensively - contractual obligations on vendors, annual re-evaluation, data deletion requirements. It also mentions ERM integration. The central topic is how third-party cyber risks are managed → Third-Party Risk.

Wait, let me re-read. The paragraph starts with third-party risk processes and ERM integration, then spends most of its text on requirements imposed ON vendors (contractual obligations, annual re-evaluation, data deletion). TP is the central topic.

Specificity: Looking at the concrete details here - Blend's internal audit team is mentioned by name, but the actual practices described are fairly standard: annual re-evaluations of service providers, contractual requirements for data deletion upon termination, and integration with their enterprise risk program. The language around "risk objectives" and "defined thresholds" shows ERM terminology, though the description of which third parties are in scope is somewhat generic.

The data deletion requirement at contract termination is a specific security practice that demonstrates some domain knowledge, and the mandatory pre-engagement review is solid vendor risk management. But stepping back, these are all standard ERM vendor risk practices - contractual obligations, periodic reviews, data governance requirements - that any enterprise risk professional would describe in roughly the same way. There's no mention of specific security frameworks, technical controls, or tools that would push this into Level 2 territory. This feels like Level 1.


fact: Vice President of IT title

fact: Randy Jepsen named as VP of IT

fact: Over 25 years of experience in the IT industry

fact: Russell Devendorf named as CFO

fact: CFO oversaw IT and risk management at a publicly traded homebuilder from 2008 to 2017

fact: Combined experience of almost 50 years

fact: The SMART Builder Solutions (named entity)

reasoning: The paragraph is primarily about who manages cybersecurity (VP of IT and CFO), their qualifications, career history, and responsibilities — classic Management Role content. Specificity is Quantified-Verifiable due to named individuals (Randy Jepsen, Russell Devendorf), specific verifiable years of experience (over 25 years, 19 years), a named external firm (The SMART Builder Solutions), and a specific date range (2008 to 2017).

thinking:
Management Role - about who is responsible, their qualifications, experience, reporting lines.

Specific facts:
- VP of IT (named_role, firm-specific)
- CFO (generic, not firm-specific)
- Randy Jepsen (named individual)
- 25 years of experience in IT (quantified, verifiable)
- 19 years at Smith Douglas and The SMART Builder Solutions (quantified, verifiable)
- Russell Devendorf (named individual)
- 2008 to 2017 (specific dates, verifiable)
- almost 50 years combined experience (soft number - "almost" hedges it)

- incident response plan (L1)
- cybersecurity insurance (CFO's past experience)

This is Level 4 due to the named individuals with specific, verifiable experience timelines and date ranges.


fact: CSO (Chief Security Officer) leads cybersecurity team

fact: CSO reports directly to Executive Vice President and Chief Operations Officer

fact: CSO has over 20 years of security experience

fact: CISSP (Certified Information Systems Security Professional) certification held by team members

fact: CISM (Certified Information Security Manager) certification held by team members

fact: Audit Committee receives quarterly reports from CSO

reasoning: The paragraph covers both board oversight (annual briefing, Audit Committee quarterly reports) and management roles, but the majority of text describes the CSO's role, reporting line to EVP/COO, qualifications, and team composition — person-removal collapses most of the paragraph, confirming MR. Specificity reaches Level 4 via 'over 20 years of security experience' (a verifiable lower bound) and named certifications (CISSP, CISM) which are independently verifiable via certification bodies.

thinking:
Let me analyze this paragraph carefully.

Category: This paragraph covers board oversight, management roles, and some program description. Let me apply the "what question" test.

- Board oversight: "Board of Directors considers cybersecurity... risk oversight function", "receives an annual briefing", "Audit Committee receives quarterly reports" → BG
- Management role: CSO, reporting to EVP/COO, CSO's experience, team qualifications → MR
- Program: "assessing and managing risks", "supervise internal and external cybersecurity personnel", "cybersecurity training" → RMP

This is genuinely mixed.

The opening establishes the governance structure with board and audit committee oversight, but the real substance focuses on the CSO's role, qualifications, and team composition. The board elements get minimal coverage while the management organization and personnel details dominate, so this leans toward MR despite the governance framing.

Looking at specificity, the CSO and EVP/COO titles are firm-specific roles, and the certifications like CISSP and CISM are named, verifiable credentials. The "over 20 years" quantifies experience in a measurable way. These concrete details about people and their qualifications push this firmly into MR territory—it's about who's running the security function and what they bring to the table, not just generic governance structures.


fact: CIO role with cybersecurity/technology responsibility

fact: CIO has over two decades (20+ years) of experience in technology development, management, and security

fact: CEO, CFO, and GC each have over 15 years of experience managing enterprise risks including cybersecurity

reasoning: The paragraph is entirely about management qualifications and credentials (who they are, what experience they have), making it MR by the person-removal test — removing person-specific content leaves nothing substantive. Specificity reaches Level 4 because 'over two decades' and 'over 15 years' are lower-bound quantified claims that could be checked against resumes or public records.

thinking:
MR - about management expertise/qualifications.

Specific facts:
- CIO (named role, firm-specific)
- "over two decades of experience" → lower bound, 20+ years, verifiable
- CEO, CFO, GC mentioned in cybersecurity context
- "over 15 years of experience" → lower bound, verifiable

Wait - CEO, CFO, GC are generic governance roles per the rules. CIO is VP-level equivalent for IT → firm-specific.

"over two decades" = "more than 20 years" → verifiable lower bound
"over 15 years" → verifiable lower bound


fact: Risk Committee (management-level committee providing updates to the board)

reasoning: The paragraph primarily answers how the board oversees cybersecurity — describing the flow of information (quarterly updates on material cyber events, annual program overview, enterprise risk assessment review) from management to the board of directors, making it Board Governance. The named 'Risk Committee' is a non-generic committee that elevates specificity to Firm-Specific, though the remaining content (quarterly cadence, annual overview, enterprise risk assessment) is generic governance language.

thinking:
Let me analyze this paragraph.

Category: This describes how information flows to the board - regular updates, quarterly updates, annual overview. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

The enterprise risk assessment mention is about ERM integration but it's in the context of board oversight (reviewed and discussed with the board).

Specificity: Let me scan for facts.
- "Risk Committee" - this is a named committee but is it firm-specific? It says "members of the Risk Committee" - this could be a management-level or board-level committee. It's not "Audit Committee" (generic), but "Risk Committee" is fairly common.

I'll count it as firm-specific since it's a named committee, though Risk Committees are fairly common across companies. The quarterly and annual cadences are standard language, and the cybersecurity program overview and enterprise risk assessment are generic ERM terminology that doesn't reveal anything unique about this organization.

Looking at the board oversight context here—the Risk Committee members are part of management providing updates to the board—this is a management-level committee discussing governance activities, which makes it Level 3 for board governance.


reasoning: The paragraph contains a backward-looking materiality assessment ('have not experienced a cybersecurity event that was determined to be material') which is SI per Rule 5, plus a cross-reference to Item 1A for forward-looking materiality. The opening RMP sentences are generic and subordinate to the materiality conclusion. No domain terms pass the ERM test (assessments, testing, policies are all generic ERM language), and the negative materiality assertion is not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: Periodic assessments/testing, adjusting policies, past incidents (none material), cross-reference to Item 1A.

Category: The paragraph covers RMP (assessments/testing), SI (no material incidents, cross-reference to materiality), and N/O (cross-reference). The "have not experienced a cybersecurity event that was determined to be material" is a SI materiality assessment. The cross-reference to Item 1A for "reasonably likely to materially affect" is N/O per rules. The first two sentences are RMP but generic. The materiality conclusion is SI.

The materiality statement about not experiencing material cybersecurity events is the dominant element here—it's a backward-looking SI assessment that takes up more space than the generic RMP language. The cross-reference to Item 1A is N/O. On specificity, the language is quite generic: "periodic assessments and testing" lacks detail, "cybersecurity threats" is just topic naming without expertise, and there are no firm-specific facts or verifiable details that would elevate this beyond L1.


reasoning: The paragraph describes an IT consultant engaged to execute the company's cybersecurity program (risk assessment, policy design, monitoring, testing safeguards). Per Rule 3, third parties hired to serve the company are RMP, though the oversight/requirements language on the consultant creates some TP tension. All language (risk assessment, policies and procedures, monitor and test safeguards, security measures) is generic ERM vocabulary with no domain-specific terms, no named entities, and no verifiable facts.

thinking:
Let me analyze this paragraph.

Content: Describes an IT consultant engaged for risk assessment, policy design/implementation, monitoring/testing safeguards, and oversight of that consultant.

Category: This is about a third party (IT consultant) but the consultant is hired to serve the company (assessor/implementer). Per Rule 3, third parties hired to serve the company → RMP. However, the second half discusses oversight OF the consultant (ensuring they maintain security measures, report breaches) which sounds like vendor oversight → TP.

Let me re-read. The first part: "We engage an IT consultant in connection with our risk assessment processes.

This consultant assists us to design and implement our cybersecurity policies and procedures, as well as to monitor and test our safeguards." → RMP (third party serving the company).

The second part: "Our oversight over our IT consultant allows us to ensure it has the ability to implement and maintain appropriate security measures... to promptly report any suspected breach of its security measures that may affect the Company." → This is about oversight OF the vendor, ensuring the vendor maintains security measures → TP.

So the paragraph splits between using the consultant as a service provider for the company's program versus imposing vendor management requirements on them. The first half clearly fits RMP since the consultant is helping build and test the company's own safeguards. The second half is about vendor oversight—making sure the consultant themselves maintains security and reports breaches. The paragraph seems roughly balanced between these two aspects, but the central focus appears to be on the consultant's role in supporting the company's risk management program. I'm going back and forth on whether the consultant relationship is fundamentally about the company using an external resource to run its cybersecurity program (RMP) or about imposing vendor oversight requirements (TP). The consultant is the core of LENZ's IT function since they're a small biotech outsourcing everything, which pushes me toward RMP—the consultant is essentially executing the company's cybersecurity strategy rather than being a third party that needs monitoring.

Looking at the specificity, the language is all generic: "risk assessment processes," "monitor and test our safeguards," "cybersecurity policies and procedures," and an unnamed IT consultant. Nothing here passes the ERM test or includes domain-specific terminology, so this is clearly L1 across the board.

I'll go with RMP since the core question is what the cybersecurity program does, and the answer is that it operates through this consultant. The oversight language is just ensuring the consultant can execute that program effectively.


fact: Enterprise Risk Committee (ERC) led by TPG's CEO

fact: Operational Risk Committee (ORC)

fact: Chief Information Security Officer (CISO)

fact: CISO reports to ORC periodically and ERC at least annually

fact: Coordinates with compliance, human resources, internal audit, and legal

fact: CISO previously held leadership roles in Technology Risk at one of the world's largest banking institutions over a 17-year period

fact: Bachelor of Science in Electrical Engineering and Mathematics from University of Texas at Arlington

fact: Certified Information Systems Security Professional (CISSP)

fact: CISSP certification is a verifiable credential

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity — describing TPG's committee structure (ERC, ORC), the CISO's role and reporting lines, qualifications, and team composition, making it MR per Rule 1 (management-level committees about structure/membership). Specificity reaches Level 4 due to multiple verifiable claims: CISSP certification (checkable via (ISC)² registry), a degree from the University of Texas at Arlington, and a 17-year tenure in Technology Risk at a named type of institution.

thinking:
Let me analyze this paragraph.

Content: This is about an externally managed fund relying on TPG's cybersecurity infrastructure. It covers:
- Enterprise Risk Committee (ERC) and Operational Risk Committee (ORC)
- CISO role and reporting lines
- CISO qualifications and background
- Cybersecurity team composition

This mixes management roles (committees, CISO, reporting lines, qualifications) with some governance structure. The primary question answered is "How is management organized to handle cybersecurity?" — it describes committees, the CISO role, reporting lines, qualifications. But there's also governance-chain content.

Looking at the specific details, I'm seeing this is clearly management and reporting structure: TPG's CEO leads the ERC, the CISO reports to the ORC with periodic updates to the ERC, and the CISO coordinates across compliance, HR, internal audit, and legal. The CISO's background in Technology Risk leadership further reinforces this is about organizational hierarchy and role qualifications.


fact: Director of ITD reports to the CFO

fact: Over 7 years of experience leading cybersecurity teams and programs

fact: Management reports material cybersecurity risks to the Board on an annual basis

reasoning: The paragraph describes the full governance chain from Board → leadership team → ITD → Director of ITD → CFO, with board reporting cadence and escalation processes, making its primary question 'how does the board oversee cybersecurity?' (BG per Rule 1 governance-chain default). Though substantial text covers the Director of ITD's responsibilities and qualifications (MR content), the framing and purpose is oversight structure. Specificity reaches Level 4 because 'over 7 years of experience' is a lower-bound quantified claim verifiable against the individual's resume.

thinking:
Let me analyze this paragraph.

Category: This paragraph covers board oversight, management roles, and some program activities. The primary question it answers is about how the organization is structured to handle cybersecurity - it describes the governance chain (Board → leadership team → ITD → Director of ITD → CFO), the Director's responsibilities, and reporting to the board. It's a mix of BG and MR. The paragraph starts with board oversight but quickly shifts to management organization - the Director of ITD role, reporting to CFO, qualifications, responsibilities. The bulk of the content is about management's organizational role. But there's also significant board reporting content. Let me weigh: Board oversight (2 sentences at start and end), management role/structure (middle bulk).

The governance structure and board reporting point toward BG under Rule 1, but most of the paragraph actually focuses on the Director of ITD's qualifications, responsibilities, and reporting relationship to the CFO. Applying the person-removal test: if I strip out the Director, CFO, and experience requirements, what's left is the board oversight and escalation process - meaningful content, but the paragraph's core is really about the management role itself.

Looking at the sentence breakdown, three sentences clearly address governance and board reporting, while four focus on management details. It's genuinely close, but the volume and emphasis lean toward MR since the oversight structure serves mainly as a frame for discussing the Director's position and how they operate.

On specificity, "Director of ITD" isn't a security-qualified title, and while ITD is somewhat distinctive naming, the CFO reporting line and annual cadence are generic. The "over 7 years of experience" claim is a lower bound that's verifiable, so that pushes toward Level 2. The title "Director of ITD" doesn't qualify as firm-specific since it lacks a security qualifier, even though the role involves leading cybersecurity teams. The only verifiable fact here is the "over 7 years" of experience claim, which puts this at Level 4.


fact: CISO briefs the committee

fact: CIO briefs the committee

reasoning: The paragraph primarily answers how the board oversees cybersecurity — the Audit & Finance Committee's oversight role, briefing cadence, and information flow from management — making it Board Governance. CISO and CIO are firm-specific leadership roles (VP-level equivalents) that elevate specificity to Level 3, though the rest of the language is generic oversight boilerplate.

thinking:
Classify this paragraph.

Category: This is about board/committee oversight of cybersecurity. The Audit & Finance Committee oversees cybersecurity strategy, reviews policies, gets briefed. This is Board Governance.

Specific facts:
- "Audit & Finance Committee" - this is a named committee but it's essentially the Audit Committee variant, which every company has. Hmm, but "Audit & Finance Committee" is a specific name that not every company uses. Actually, the rules say "Audit Committee" is NOT firm-specific because every company has one.

"Audit & Finance Committee" is just a variant name, so I'll treat it as not firm-specific. The CISO and CIO are firm-specific named roles, and the briefing cadence is generic. Looking at the domain terms like "cybersecurity controls" and "cybersecurity threats and trends," those are standard terminology, so the firm-specific elements are really just the CISO and CIO roles. This lands at Level 3.


fact: Management team includes members from legal, finance, and internal audit

fact: threat intelligence

reasoning: The paragraph's primary subject is 'other members of our management team' and how they supervise cybersecurity efforts — describing management's organizational role and information channels (briefings, alerts, reports). While supervisory means are listed, they serve to explain the management role rather than detail program operations. Specificity reaches Level 3 because specific departments (legal, finance, internal audit) are named as team composition, and 'threat intelligence' is a domain term.

thinking:
Classify this paragraph.

The paragraph describes management team members (legal, finance, internal audit) supervising cybersecurity efforts through various means. Let me apply the "what question" test.

"How is management organized to handle cybersecurity?" — it's about management team members and their supervision role. But let me apply the person-removal test: remove person-specific content (titles, qualifications). What remains? "efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel; threat intelligence and other information obtained from governmental, public or private sources, including external consultants we engage; and alerts and reports produced by security tools deployed in the IT environment."

Substantial program description remains after removing the management team references, but the sentence structure centers on management's supervisory role and how they obtain information. The activities—briefings, threat intelligence, and security tool alerts—describe the information flow supporting that oversight function rather than standing as independent program elements.

The specificity markers point toward firm-specific details: the particular departments involved in management (legal, finance, internal audit) and domain-specific terminology like "threat intelligence" that wouldn't be universally understood outside enterprise risk management contexts.


reasoning: The paragraph's central question is how third-party cyber risks are managed — security assessments before engagement, ongoing monitoring, and compliance with cybersecurity standards — making TP the dominant category despite a closing materiality sentence (SI). Specificity stays Level 1: 'security assessments,' 'data breaches,' and 'ongoing monitoring' are generic process descriptions any ERM professional could write; 'Cybersecurity Manager' is below the Director-level threshold for firm-specific; 'quarterly' is a generic cadence; and the negative materiality assertion is not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party risk oversight processes, mentions security assessments, ongoing monitoring, quarterly assessments by Cybersecurity Manager and security engineers, and ends with a materiality statement.

Category: The central topic is third-party risk management. The paragraph is titled "Oversee Third-party Risk" and most content is about vendor oversight. The last sentence is a materiality statement (SI), but the dominant content is TP.

Wait - let me reconsider. The majority of the text is about third-party risk processes. The last sentence is a materiality/SI statement. By text volume, TP dominates.

Now I'm checking whether "Cybersecurity Manager" qualifies as firm-specific. The rules require Director-level titles with a security qualifier, and this is just a Manager-level position, so it doesn't meet that threshold.

Looking at the other language in the passage—"security engineers," "quarterly assessments," "security assessments"—these are all generic enough that an ERM professional would use them too. The materiality statement about not encountering cybersecurity challenges that materially impaired operations is the kind of thing any risk professional might say, though it's framed in cybersecurity-specific terms.

The "Cybersecurity Manager" title is specific, but it's below the Director level that the rules require for firm-specific designation. Without concrete tools, standards, or practices that demonstrate actual cybersecurity expertise beyond what a generalist would know, this reads as Level 1 boilerplate.

The last sentence about data breaches is clearly SI material, but Third-Party Risk dominates the overall text, so that's the primary category.


fact: ISO 27001:2022 information security standard used to drive risk assessment

fact: Security Operations Center (SOC) with enterprise event visibility

fact: Ferguson maintains a SOC — specific organizational claim

fact: Cybersecurity insurance coverage

reasoning: The paragraph answers 'what does the cybersecurity program do?' — describing processes, technical defenses, compliance, framework usage, and a SOC, making it RMP. ISO 27001:2022 is a domain-adapted framework reference (alignment, not certification), and the SOC is a domain term, but the specific organizational claim that Ferguson maintains a SOC is a firm-specific fact elevating to Level 3.

thinking:
Classify this paragraph.

Category: Describes what the cybersecurity program does - processes, resources, technical defenses, compliance, ISO standard usage, SOC. This is RMP.

Specific facts:
- ISO 27001:2022 - framework/domain term. "utilize the ISO 27001:2022 information security standard to drive our risk assessment" - this is alignment/use, not certification. Domain-Adapted level.
- Security Operations Center ("SOC") - domain term
- "Ferguson maintains a Security Operations Center ("SOC")" - named as SOC, domain term

- "enterprise event visibility" - somewhat domain-specific
- cybersecurity insurance - mentioned but generic

Now I'm distinguishing between what's truly firm-specific versus domain terminology. The SOC itself is a generic domain term, though Ferguson maintaining one with 24/7 operations could be firm-specific. The ISO 27001:2022 reference shows alignment with the standard for risk assessment rather than a certification claim, which puts it at Domain-Adapted level.

Looking at the specificity here: ISO 27001:2022, SOC, and vulnerabilities are all domain terms pointing to at least Level 2. But "Ferguson maintains a Security Operations Center" is a specific organizational claim similar to the 24/7 operations example, so I'd classify that as firm-specific. The cybersecurity insurance mention is a Strategy Integration element but appears minor among the other RMP components.


reasoning: The paragraph primarily consists of a forward-looking disclaimer ('could have a material adverse effect' — explicitly not SI per Rule 5), a hedged insurance mention ('may not be fully insured'), and a cross-reference to Item 1A Risk Factors. While cybersecurity insurance is briefly mentioned, the dominant content is disclaimer and cross-reference language, pointing this to N/O. None/Other paragraphs always receive Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Forward-looking disclaimer about potential incidents, mention of cybersecurity insurance, and a cross-reference to Item 1A Risk Factors.

Category: "Could have a material adverse effect" is speculation per Rule 5. The cybersecurity insurance mention is brief. The cross-reference to Item 1A is N/O. This is mostly disclaimers and cross-references. The insurance mention is a real fact but very brief. Let me think...

The paragraph has three parts:
1. Disclaimer about potential incidents ("could have a material adverse effect") - N/O per rules

2. The cybersecurity insurance statement is factual and could qualify as SI since insurance is explicitly listed in the examples, but the paragraph is dominated by disclaimers and cross-references
3. Cross-reference to Item 1A - N/O

Given that the bulk of the content is disclaimer language and cross-referencing rather than substantive disclosure about their insurance program, I'm leaning toward N/O overall, even though the insurance mention itself has SI characteristics.

Actually, Rule 6 is pushing me toward SI—it says any actual cybersecurity measure described triggers the relevant category, and maintaining insurance is a real measure. The "material adverse effect" language doesn't count as an assessment per Rule 5, but the insurance disclosure itself is substantive enough. I'll classify this as SI with moderate confidence, since the insurance mention, while brief, represents an actual cybersecurity measure despite the surrounding disclaimer language. purpose is disclaiming liability and pointing to risk factors. The insurance is mentioned in passing. I think N/O is more appropriate given the dominant content is disclaimers and cross-references.

Let me settle this with the "what question does this paragraph primarily answer?" test - it's really about "what could go wrong" and "where to find more info," neither of which maps cleanly to a substantive category. N/O seems right.

But Rule 6 complicates things since insurance is an actual measure. The paragraph's main thrust is still disclaiming and cross-referencing though, and the insurance mention is brief and hedged. When most of the text is boilerplate, that wins out - so N/O with Generic Boilerplate as the specificity.


fact: United States Computer Emergency Readiness Team (US-CERT) alerts

fact: Vice President of IT oversees information security program

fact: Information Security Manager role

reasoning: This is a governance-chain paragraph tracing information flow from Information Security Manager → VP of IT → CFO → Board, with board briefing frequency and scope as significant content; per Rule 1, governance-chain paragraphs describing oversight structure default to BG. Specificity reaches Level 3 because VP of IT is a VP-level title with IT portfolio (firm-specific), and US-CERT is a domain term passing the ERM test.

thinking:
Let me analyze this paragraph.

Category: This describes management's role in cybersecurity oversight, reporting lines, and how information flows up to the board. It's a governance-chain paragraph. The primary question is about how management is organized AND how the board oversees. Let me check - there's significant content about management roles (CFO, VP of IT, Information Security Manager) and their reporting lines, plus board briefing frequency. The governance chain goes from Information Security Manager → VP of IT → CFO → Board.

Per Rule 1, governance-chain paragraphs default to BG when describing oversight structure. But here, the first half is heavily about management organization (who oversees the program, reporting lines between management roles), while the second half describes board briefings.

The paragraph opens with management responsibility and focuses on the reporting structure, but ultimately it's laying out the full oversight chain from management through to the board. That makes it BG. The board briefing details—quarterly incident reviews and annual program summaries—are substantial enough to confirm this categorization.

Specificity: Scanning for concrete details, I see the CFO named as overseeing the program, though that's a generic title per the rules, and the VP of IT whose portfolio includes this responsibility. VP of IT qualifies as firm-specific since it's a VP-level title with an IT portfolio. US-CERT is domain terminology that passes the ERM test. The Information Security Manager role falls below Director level, so it doesn't meet the firm-specific threshold. The weekly reporting structure with specific content like US-CERT alerts and preventative maintenance findings adds some specificity, but the generic cadences don't push it higher. This lands at Level 3 due to the VP of IT designation.