reasoning: The paragraph answers how the board oversees cybersecurity: delegation to Audit Committee, quarterly CISO reports, annual full-board briefings — classic Board Governance. The VP/CISO title is a firm-specific named role elevating to Level 3; cadences like 'quarterly' and 'no less frequently than once annually' are generic and don't qualify as verifiable facts.

thinking:
Classify this paragraph.

Category: Board governance - describes board/committee oversight, delegation, briefing frequency, reporting structure.

Specific facts:
- Audit Committee oversight (generic, every company has this)
- VP and CISO role - firm-specific (named role)
- Quarterly reports - generic cadence
- "no less frequently than once annually" - generic cadence

Let me check: CISO is a firm-specific named role. "Vice President and Chief Information Security Officer (CISO)" is firm-specific.

Specificity: Level 3 (Firm-Specific) due to CISO role.


content_category: Risk Management Process

fact: NIST CSF framework referenced

type: framework

fact: Global Information Security Policy (named internal policy)

fact: CISO role

fact: security architecture program

fact: endpoint detection

fact: privileged access management

fact: layered cybersecurity measures (defense in depth)

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes program activities (policies, frameworks, layered security measures) with the CISO as grammatical subject; person-removal test leaves substantial program description → RMP. Specificity reaches Level 3 via CISO role and the named 'Global Information Security Policy,' with multiple domain terms (endpoint detection, privileged access management, NIST CSF) supporting Level 2 as a floor.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content category: The paragraph describes what the cybersecurity program does (policies, framework, layered measures) with the CISO as grammatical subject but content about program activities. Person-removal test: remove CISO reference, substantial program description remains → RMP.

Specific facts:
- "Global Information Security Policy" - named internal program → firm-specific
- NIST CSF - framework reference → domain term
- CISO - named role → firm-specific
- "security architecture program" - domain term
- "endpoint detection" - domain term (EDR-adjacent)

- "security incident response and event management" - domain term (SIEM-adjacent)
- "privileged access management" - domain term
- "layered cybersecurity measures" - defense in depth concept → domain term

The CISO reference is firm-specific at Level 3, and the named internal policy combined with multiple domain terms and no verifiable claims keeps this at Level 3 overall.


content_category: Strategy Integration

fact: Specific named risk factor headings unique to this company's 10-K filing

fact: For more than 5 years, no known cybersecurity threats have materially impacted the company

fact: Penalties and settlements of which there were none

specificity_confidence: medium

reasoning: The paragraph contains both a backward-looking materiality assessment ('for more than 5 years, we have not identified any known cybersecurity threats...that have materially impacted us') and a forward-looking SEC 106(b)(2) statement ('risks that are reasonably likely to materially affect us'), making it Strategy Integration. The cross-reference alone would be N/O, but the substantive materiality conclusions dominate. Specificity is Firm-Specific due to the company-unique risk factor titles and the specific 'more than 5 years' no-material-impact claim, but these are negative self-assertions not independently verifiable, so they remain Level 3 rather than Level 4.

thinking:
Let me analyze this paragraph.

The paragraph has three main parts:
1. A cross-reference to Item 1A risk factors
2. A statement about no material cybersecurity incidents for more than 5 years
3. A forward-looking statement about risks that could materially affect them

For category: The cross-reference points elsewhere (N/O-ish), but the middle sentence is a materiality assessment ("for more than 5 years, we have not identified any known cybersecurity threats...that have materially impacted us") → SI. The last sentence is the SEC Item 106(b)(2) forward-looking materiality statement → SI. So this is Strategy Integration.

For specificity: The timeframe "more than 5 years" is a lower bound, but it's a negative assertion about absence of material incidents that can't be independently verified. Similarly, claims about penalties and settlements being nonexistent are self-reported negatives without external confirmation. The specific risk factor titles referenced are unique identifiers that would reveal the company's identity.

Now I'm reconsidering whether those cross-reference titles are truly firm-specific facts about cybersecurity posture or just pointers to other sections. The paragraph's materiality assessments push it toward SI classification, but the quantified timeframe claim—even though it's negative—is still the core issue. The "more than 5 years" quantifies when the absence occurred, but doesn't make the underlying assertion itself verifiable. I need the next thinking to rewrite. You've provided the current rewritten thinking and the guidelines, but I don't see the "next thinking" content that I should be rewriting.

Could you please share the next thinking that needs to be rewritten?


fact: mentions specific threat types: malware, ransomware, computer viruses

reasoning: The paragraph's central purpose is a materiality assessment ('have not identified any risks or incidents from cybersecurity threats that have materially affected our business strategy, results of operations or our financial condition'), making it SI under Rule 5. Specificity reaches Level 2 due to named threat types (malware, ransomware) which pass the ERM test, but no firm-specific or verifiable facts elevate it further.

thinking: Strategy Integration - materiality assessment paragraph.


content_category: Third-Party Risk

reasoning: The paragraph centrally addresses how third-party/vendor cyber risks are managed — contractual security addenda and incident reporting requirements imposed ON subcontractors — making it Third-Party Risk. The language uses no domain-specific terminology beyond what any ERM professional would use (contract addenda, incident reporting), names no specific roles, frameworks, or verifiable facts, keeping it at Level 1.

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

Facts: "security and privacy addenda to our contracts" - this is a contractual requirement imposed on vendors. "subcontractors connecting to our network are instructed to report cybersecurity incidents" - requirement imposed on vendors.

These are requirements imposed ON vendors → TP.

Specificity: No domain terms that pass the ERM test. "Security and privacy addenda" - would an ERM professional use this? Yes, this is standard contract language. "Report cybersecurity incidents" - generic. No firm-specific facts, no verifiable claims.

This falls into Level 1 classification.


content_category: Board Governance

category_confidence: medium

reasoning: The paragraph's first two sentences describe the Audit Committee's receipt of cybersecurity reports and access to summaries — answering how the board oversees cybersecurity (BG). The final sentence is a materiality assessment (SI), but by text volume BG content dominates. No domain terms pass the ERM test ("cybersecurity threats and risk," "processes" are generic), Audit Committee is not firm-specific, and the negative materiality assertion is not externally verifiable, leaving Level 1.

thinking:
Let me analyze this paragraph.

Content: Two parts - (1) Audit Committee receives reports from cybersecurity function about threats/risks/processes, and has access to reports. (2) Materiality assessment statement.

Category: The first part is about board oversight (Audit Committee receiving reports = BG). The second part is a materiality assessment = SI per Rule 5. The materiality statement is a significant portion. Let me assess which dominates. The first two sentences describe board oversight. The last sentence is a clear SI materiality assessment. It's roughly split, but the materiality statement is a full SEC 106(b)(2) assessment.

Looking at the text distribution more carefully, the board governance content takes up roughly two sentences while the materiality assessment is one longer sentence, so by volume the first part edges out. I'm going to categorize this as BG since the board oversight discussion has slightly more text, even though the materiality statement is a strong concluding element. The primary question this paragraph answers is about board oversight of cybersecurity, with the materiality statement serving as a secondary conclusion. Looking at the specificity, everything here is generic governance language—Audit Committee access, periodic reports, the cybersecurity function itself—with no firm-specific facts or verifiable details. The materiality assertion is just a negative self-statement. This is clearly Level 1 boilerplate.


content_category: None/Other

reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for materiality discussion, with no substantive cybersecurity disclosure of its own. Per Rule 5, cross-references like 'see Item 1A' are N/O. No specific facts elevate specificity above Level 1.

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


reasoning: The paragraph describes the board's delegation of cybersecurity oversight to the Audit Committee, directly answering how the board oversees cybersecurity → Board Governance. It contains only generic governance elements (Board of Directors, Audit Committee, risk oversight) that exist at virtually every public company, with no domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

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

Specificity: "Audit Committee" is generic (every company has one), "Board of Directors" is generic. No domain terms, no firm-specific facts, no verifiable claims. → Level 1.


reasoning: This is a cross-reference directing readers to Item 1A Risk Factors for materiality information, with no substantive cybersecurity disclosure of its own. Per Rule 5, cross-references like 'risks that may materially affect us, see Item 1A' are N/O. No specific facts elevate specificity above Level 1.

thinking: Cross-reference to Item 1A with no substantive cybersecurity content.


reasoning: The paragraph contains a backward-looking materiality conclusion ('no such incident has had any such impact to date'), which per Rule 5 qualifies as SI, despite the bulk of the text being a cross-reference to Item 1A for further materiality discussion. No domain terms pass the ERM test, the negative materiality assertion is not externally verifiable, and the cross-referenced risk factor title is not a firm-specific cybersecurity fact, keeping specificity at Level 1.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. Generic statement about maintaining protocols and monitoring
2. "no such incident has had any such impact to date" - negative assertion about material impact
3. Cross-reference to Item 1A for materiality assessment

The cross-reference points elsewhere for the actual materiality assessment. Per Rule 5, cross-references like "risks that may materially affect us, see Item 1A" → N/O.

But there's also "no such incident has had any such impact to date" which is a backward-looking materiality statement.

The negative assertion "no such incident has had any such impact to date" is a materiality conclusion, so that's SI. The paragraph's main structure is generic monitoring language, then a materiality conclusion embedded in the second sentence, then a cross-reference to Item 1A for the broader discussion. The materiality conclusion is present but the cross-reference dominates the overall structure. The paragraph really does contain a materiality conclusion—"no such incident has had any such impact to date"—which pushes toward SI. But the cross-reference is doing the heavy lifting here, directing readers to Item 1A for the actual risk discussion. I'm torn between treating this as primarily cross-referential (N/O) or giving weight to the embedded materiality statement (SI). The cross-reference feels like the dominant structural purpose, so I'll classify this as N/O, though the materiality language makes it a closer call than pure boilerplate. a cross-reference. The negative materiality assertion—"no such incident has had any such impact to date"—isn't externally verifiable per the rules, and there are no domain-specific terms or firm-specific facts beyond generic language. This is Level 1 Generic Boilerplate.


reasoning: The paragraph's central topic is how the company oversees third-party service providers—vendor diligence and risk-based assessments—making Third-Party Risk the primary category. The language ('vendor diligence,' 'assessed for risk based on nature of service, access to data') is generic ERM terminology that any non-security risk professional would use, with no domain-specific terms, firm-unique facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: About overseeing third-party service providers - vendor diligence, risk assessment based on service nature, data access, supply chain risk. Central topic is third-party risk management.

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

Specificity: "vendor diligence", "assessed for risk based on the nature of their service, access to data and systems and supply chain risk" - this is generic process description. No domain terms that pass the ERM test. "Supply chain risk" is generic ERM language. No firm-specific facts. No verifiable claims.

Level 1.


reasoning: The paragraph describes third-party service providers hired to assist the company with cybersecurity efforts, which per Rule 3 (third parties serving the company) maps to RMP rather than TP. The statement is extremely thin with no domain-specific terminology that passes the ERM test—'containment and remediation' is language any risk professional could use—no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Content: Says Franklin Templeton has third-party service providers for cybersecurity containment and remediation.

Category: This mentions third parties but it's a brief statement about having relationships with service providers who assist the company. Per Rule 3, third parties hired to serve the company → RMP. But this is so thin... it's about third-party relationships for containment/remediation. The third parties here serve the company (assessors, consultants), so RMP per Rule 3.

Actually, this is very brief. "containment and remediation" - are these domain terms? Containment and remediation are part of incident response terminology.

The language here is borderline—"containment" is fairly specific to cybersecurity contexts, but "remediation" is broad enough that an ERM professional could use it generically. These terms could apply to any risk scenario, so they're not uniquely technical. Given how sparse the disclosure is and how generic "third party service providers" sounds, I'm classifying this as Level 1 - Generic Boilerplate. I need the next thinking to rewrite. You've provided my current rewritten thinking and the guidelines, but I don't see the "next thinking" content that I should be rewriting.

Could you please share the next thinking chunk that needs to be rewritten?


reasoning: This paragraph is a biographical summary of David Shear's career history with no connection to cybersecurity oversight, management, or programs — it describes marketing and international business roles. None/Other paragraphs receive Generic Boilerplate.

thinking:
This is about a person's career history - David Shear, President International of RBI. No cybersecurity content at all.

Wait, this is in Item 1C which is cybersecurity disclosure. But the content is purely biographical about a business executive with no cybersecurity connection mentioned.

This is None/Other - no substantive cybersecurity disclosure.


content_category: Management Role

fact: CDIO (Chief Digital and Information Officer) chairs the security council

fact: Security council as a named management-level committee

fact: Security council composed of senior leaders from Legal and Regulatory, Corporate Security, Network Engineering, Internal Audit, Finance & Accounting and Risk and IT Infrastructure

fact: Reference to reported April 2024 cyber-attack — a specific, publicly known incident

reasoning: The paragraph primarily describes management's organizational structure for cybersecurity oversight: the CDIO-chaired security council, its cross-functional membership, and response teams — fitting MR under Rule 1 (management-level committee about structure/membership). Specificity reaches Level 4 because the 'reported April 2024 cyber-attack' is a specific, externally verifiable event (Frontier's publicly disclosed breach), even though it appears in a subordinate reference.

thinking:
Let me analyze this paragraph.

The paragraph describes:
1. CDIO chairs a security council - management-level committee
2. Security council composition - cross-functional departments listed
3. Processes for monitoring/materiality determinations
4. Escalation to Audit Committee
5. Reference to April 2024 cyber-attack
6. Cross-reference to Item 1A

Primary question: This is about how management is organized - the security council structure, membership, and responsibilities. But it also touches on processes (monitoring, materiality determinations) and governance (escalation to Audit Committee).

The CDIO chairing a security council, its composition - this is management organizational structure → MR.

When I remove the organizational elements like the CDIO and team composition, what's left is mostly procedural content about monitoring and escalation, but the core of the paragraph is really structured around describing the security council itself and who sits on it. The dominant framing is organizational structure, not process.

Looking at the specifics: the CDIO is a named role, the security council is a named committee chaired by that person, and the cross-functional departments are explicitly listed. The April 2024 cyber-attack reference is particularly telling—it's a specific, verifiable date tied to a real incident that Frontier Communications publicly disclosed, which makes this Level 4 specificity. The involvement of the Audit Committee in that incident further anchors this to a concrete, documented event.


reasoning: This is an introductory/preamble paragraph that frames the threat landscape and states Dell expends resources on cybersecurity, but provides no substantive disclosure about any specific program, governance structure, or incident—it merely sets the stage for the Item 1C section. N/O paragraphs always receive Generic Boilerplate.

thinking:
Classify this paragraph.

This is an introductory/framing paragraph about cybersecurity threats Dell faces. It mentions threats, potential adverse effects, and says they spend resources on cybersecurity. No specific program details, no governance specifics, no incident details.

Category: This is introductory framing. It mentions threats and says they spend resources. It doesn't answer any specific question deeply. It's a preamble. Could be N/O or RMP. It does mention "cybersecurity risk management, strategy, and governance" but only at a very high level. This is more of an introductory paragraph.

Looking at the specifics, the paragraph describes the threat landscape they face, acknowledges potential adverse effects, and makes a broad statement about spending resources on cybersecurity risk management—but it's all at such a high level that it reads as a section introduction rather than substantive disclosure. I'll classify this as None/Other since it's essentially a preamble without detailed information about any specific category. I'm reconsidering whether "advanced and persistent threat actors" qualifies as domain-specific terminology or just descriptive language. The phrase mirrors the APT concept but uses more generic wording rather than the technical acronym itself. Looking at it through an ERM professional's lens, they might not naturally phrase it this way, which suggests it's borderline. I'm settling on this as introductory framing with generic boilerplate specificity.


fact: NIST governance requirements and cybersecurity framework alignment

reasoning: While the first sentence mentions Board/Audit Committee oversight (BG), the majority of the paragraph describes ERM integration, IT-risk team collaboration, and NIST framework alignment — all program activities, making RMP the dominant category. Specificity reaches Level 2 via the NIST CSF reference (a named standard passing the ERM test), but 'aligned with' is aspirational rather than a verifiable certification claim, so it stays at Domain-Adapted.

thinking:
Let me analyze this paragraph.

Category: The paragraph covers multiple topics - board oversight, ERM integration, IT department collaboration, and NIST alignment. The first sentence is about board/audit committee oversight (BG). The rest describes program integration and alignment (RMP). The bulk of content is about how the program works - ERM integration, IT/risk team collaboration, NIST alignment. RMP wins.

Wait, let me reconsider. The first sentence is BG. Then ERM integration (RMP), IT department working with risk management (RMP), NIST alignment (RMP). Most text is RMP.

Specificity:

The NIST cybersecurity framework reference is a domain term but not firm-specific since it's just aligned with rather than customized. The Audit Committee and IT department are generic functions every organization has, so these don't add specificity. This lands at Level 2.


fact: Certificate earned in 2023

fact: Quarterly cybersecurity updates from CISO to audit committee

fact: Cybersecurity updates to full board three times per year

type: quantified

fact: Communication of incidents to CEO, CFO, and Chief Legal Officer

reasoning: The paragraph primarily answers how the board oversees cybersecurity — audit committee oversight, briefing frequency, and information flow — making it Board Governance. Specificity reaches Level 4 due to verifiable claims: a board member earned the NACD CERT Certificate in Cybersecurity Oversight in 2023 (verifiable credential and date), and the specific frequency of three board updates per year and quarterly CISO reports to audit committee are quantified facts.

thinking: Board governance paragraph with multiple specific facts.


reasoning: The paragraph describes Audit Committee education and expertise regarding cybersecurity oversight, answering how the board oversees cybersecurity, making it Board Governance. No domain terms pass the ERM test ('information security' is a topic reference, not domain expertise), no firm-specific facts (Audit Committee is generic), and no verifiable claims, leaving this at Level 1.

thinking:
Classify this paragraph about Zillow's Audit Committee education and expertise.

Category: This is about board-level oversight (Audit Committee) - how board members are educated and their expertise. This is Board Governance.

Specificity: Let me check for facts.
- "Audit Committee" - generic, every company has one → not firm-specific
- "members of management, third-party consultants, our independent registered public accounting firm and legal counsel" - generic descriptions
- "information security" - topic mention, not a domain term passing ERM test
- "expertise in the technology industry as well as corporate risk management strategies" - generic

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


reasoning: This is a cross-reference directing readers to Item 1A Risk Factors for additional cybersecurity risk discussion, with no substantive cybersecurity disclosure of its own. The materiality language is part of a heading reference, not an assessment. N/O paragraphs receive Generic Boilerplate.

thinking: Cross-reference to Item 1A Risk Factors. N/O.


fact: NEE Management and NEER provide IT/cybersecurity functions under agreements

fact: NEP's board oversees the provision of these services

reasoning: The paragraph describes an outsourcing arrangement where NEE affiliates provide cybersecurity functions, with NEP's board overseeing those services — this is a governance-chain paragraph describing oversight structure, defaulting to BG per Rule 1. Named affiliates (NEE Management, NEER) and the specific intercompany arrangement are firm-specific facts elevating to Level 3.

thinking:
Classify this paragraph.

The paragraph says NEE's affiliates provide IT/cybersecurity functions to NEP, and NEP's board oversees these services. This is about governance structure - the board overseeing cybersecurity services provided by affiliates.

Category: This describes how the board oversees cybersecurity (provided by affiliates). It's Board Governance - the board oversight of cybersecurity risk management that's outsourced to affiliates.

Actually, it's a mix - it describes the outsourcing arrangement AND board oversight. The primary question answered is "how does the company handle cybersecurity?" - through affiliate agreements.

The board's oversight role is secondary to the organizational structure itself. The paragraph is fundamentally describing how cybersecurity is organized through affiliate agreements, with board oversight built into that structure. Given the governance-chain rule, when oversight structure is mentioned, it defaults to Board Governance. The named entities here - NEE Management, NEER, NEP - are firm-specific, and there are no domain-specific terms beyond generic cybersecurity and IT references, so this lands at Level 3 - Firm-Specific.


reasoning: The paragraph describes the responsibilities of the Director, IT — hiring, budgets, incident prep, approving processes — which is squarely about a management role's organizational duties. Person-removal test confirms MR: removing the title leaves no substantive program description. 'Director, IT' lacks a security qualifier and is not VP-level, so it does not qualify as firm-specific; the listed responsibilities (hiring, budgets, reviewing reports) are generic management functions that fail the ERM test for domain terminology.

thinking:
Classify this paragraph.

Content: About the Director, IT's responsibilities - hiring, integrating cyber risk, communicating priorities, approving budgets, preparing for incidents, approving processes, reviewing assessments.

Category: This is about a management role's responsibilities. Person-removal test: remove "Director, IT" and the paragraph collapses to a list of generic responsibilities without a subject. → MR.

Specificity: "Director, IT" - this is a Director-level title WITHOUT a security qualifier (it's IT, not IT Security or Cybersecurity). Per the rules, "Director of IT" is NOT firm-specific.

The responsibilities listed are too generic—hiring, budgets, risk management, communicating priorities—without any cybersecurity domain expertise showing through. → Level 1.


reasoning: Despite the heading referencing 'Management's Role,' the paragraph's primary content describes how the Audit Committee (a board-level committee) receives briefings from the COO, participates in strategic cybersecurity decisions, and conducts annual reviews — all answering 'how does the board oversee cybersecurity?' per Rule 1. Specificity stays Level 1 because COO and Audit Committee are generic roles present at every company, the briefing topics are standard ERM language, and no domain-specific terms, firm-unique facts, or verifiable claims appear.

thinking:
Let me analyze this paragraph.

Category: The heading says "Management's Role Managing Risk" but the content is primarily about how the COO briefs the Audit Committee and how the Audit Committee oversees cybersecurity. The Audit Committee is a board-level committee. The paragraph describes the information flow from COO to Audit Committee, the committee's participation in strategic decisions, and its annual review. This is primarily about board oversight structure (how information flows to the board, committee oversight). Per Rule 1, this is BG.

Specificity: Let me scan for facts:

- "Chief Operating Officer" and "Audit Committee" are generic roles and structures that every company has
- "minimum frequency of once per year" is a standard cadence, not firm-specific
- "Via Renewables, Inc." is just the company name
- The topics covered (cybersecurity landscape, emerging threats, incident reports, compliance) are all generic ERM language with no domain-specific details

There are no verifiable facts or firm-specific information here. This is Level 1 - Generic Boilerplate.


fact: external vendor risk management platform for evaluating, rating, monitoring and tracking vendor risk

fact: SOC 1 report requirement for hosted application vendors

fact: SOC 2 report requirement for hosted application vendors

reasoning: The paragraph centrally addresses requirements imposed on third-party vendors for hosted software platforms, including vendor risk management and specific attestation requirements, making it Third-Party Risk. SOC 1 and SOC 2 reports are domain-specific frameworks that pass the ERM test, elevating to Level 2. No firm-specific facts (no named roles, committees, or unique identifiers) push it to Level 3.

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


reasoning: The paragraph's central topic is how cybersecurity considerations govern selection, oversight, and due diligence of third-party service providers, making TP the primary category. All language ('risk-based approach', 'due diligence', 'selection and oversight') is generic ERM vocabulary with no domain-specific terms, firm-unique details, or verifiable claims.

thinking:
Classify this paragraph.

Central topic is third-party risk management - how they manage vendor cyber risks. Due diligence on third parties, selection and oversight.

Category: Third-Party Risk (TP) - central topic is managing third-party service provider cybersecurity risks.

Specificity: Let me scan for facts.
- "risk-based approach" - generic ERM language
- "due diligence on third parties" - generic
- "most critical systems, data or facilities" - generic

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


fact: vendor risk assessments

fact: review of the vendor's security program

reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party providers, including vendor assessments, questionnaires, and contractual obligations — making Third-Party Risk the clear category. The mention of vendor risk assessments and review of vendor security programs shows some domain knowledge beyond generic ERM language, but there are no firm-specific facts (no named program, no named roles) or verifiable claims, keeping it at Level 2.

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


fact: penetration testing firms

fact: forensic investigators

fact: security questionnaires

reasoning: The paragraph opens by listing third parties that assist the company (RMP per Rule 3) but its central, most-detailed content is the vendor management standard and processes for managing cybersecurity risks of providers—risk assessments, security documentation reviews, security questionnaires, security audits, and contractual obligations—making vendor oversight the dominant topic (TP). Specificity reaches Level 2 via domain terms like 'penetration testing,' 'forensic investigators,' and 'security questionnaires,' which pass the ERM test, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Category: This paragraph discusses third-party service providers extensively. The first sentence describes third parties hired to serve the company (assessors, pen testers) → RMP per Rule 3. But the second half discusses vendor management standards, processes to manage cybersecurity risks of vendors, risk assessments of vendors, contractual obligations on providers → this is TP. The central topic is how third-party cyber risks are managed, with the vendor management standard and processes being the core content. Actually, it's mixed - first part is about third parties helping them (RMP), second part is about managing vendor risk (TP).

Looking at text volume: roughly half is about third parties helping them, and the other half is about vendor management.

The bulk of the substantive detail centers on their vendor management processes—the standard itself, risk assessments, security documentation reviews, questionnaires, and audits—which makes TP the stronger categorization. The paragraph transitions from describing third-party usage to detailing how they oversee vendor cybersecurity risk, with the vendor oversight framework being the main structured content. Specificity-wise, I'm seeing domain terms like "penetration testing firms" and "forensic investigators," plus the named "vendor management standard." "Vendor management standard" is just generic terminology, not a named program with any distinguishing features, so it doesn't count as firm-specific. That leaves "penetration testing" as the only clear domain term, putting this at Level 2.


fact: VP of Information Technology

fact: Senior Vice President, Chief Financial Officer and Treasurer

fact: Senior Vice President, General Counsel and Secretary

fact: President, Chief Executive Officer and Chairman of the Board

reasoning: The paragraph identifies the specific senior management team responsible for cybersecurity and describes their collective qualifications, making it primarily about management roles and organization. The VP of Information Technology is a VP-level title with IT portfolio, qualifying as firm-specific; the other C-suite titles (CEO, CFO, GC) are generic governance roles present at most companies but are listed here as the specific team composition, contributing to firm-specificity. No verifiable claims (years, certifications, named individuals) are present.

thinking:
Classify this paragraph.

The paragraph describes management team composition and their qualifications. It names specific titles involved in cybersecurity leadership.

Category: Management Role - it's about who manages cybersecurity (roles, responsibilities, qualifications).

Specific facts:
- President, CEO and Chairman of the Board - generic roles
- SVP, CFO and Treasurer - generic
- SVP, General Counsel and Secretary - generic
- VP of Information Technology - VP-level IT title → firm-specific

No verifiable claims (no specific years, certifications, named individuals). "Significant prior work experience" is vague.

Specificity: Firm-Specific (Level 3) due to VP of Information Technology.


reasoning: The paragraph centrally addresses how third-party cyber risks are managed—due diligence assessments, contractual rights, compliance monitoring—making Third-Party Risk the clear category. The language (security assessments, monitoring compliance, data breaches) is standard vendor risk management vocabulary any ERM professional could produce; 'IT Security team' is equivalent to 'dedicated cybersecurity team' (listed as not firm-specific), and no domain-specific tools, frameworks, or verifiable facts appear.

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

Specific facts:
- "due diligence security assessments" - generic process
- "IT Security team" - named team with security qualifier? It's a generic team name, not a named committee. But "IT Security team" is a specific team composition reference... actually it's just a generic team name. Let me think - is "IT Security team" firm-specific? It's a common generic name. I'd say it's borderline but probably not firm-specific enough.
- "contractual rights to gather data on vendor systems" - this is about vendor oversight

- "periodic assessments and ongoing monitoring" - generic

The paragraph is centrally about third-party risk management. Category = Third-Party Risk.

For specificity: "IT Security team" - this is a named team. Actually, per the rules, "dedicated cybersecurity team" is NOT firm-specific. "IT Security team" is similarly generic. But wait - it has a security qualifier. Let me reconsider... The rules say named teams like "Legal, Compliance, and Finance" are firm-specific. "IT Security team" is pretty generic though.

Domain terms: "security assessments", "data breaches" - do these pass the ERM test? "Security assessments" in the context of vendor due diligence is pretty generic. "Data breaches" is commonly used. These are standard terminology, not firm-specific language.

Looking at the overall vocabulary - "due diligence security assessments," the processes described (assessments, monitoring, contractual rights) - this is all standard ERM language that any risk professional would use. "IT Security team" doesn't elevate it because it's just a generic functional team name, not a firm-specific reference. I'm settling on Level 1 - Generic Boilerplate.


fact: security questionnaires for vendor assessment

fact: information security addenda in contracts

fact: procuring results of audits and compliance reviews from providers

fact: obtaining overviews of network infrastructure from providers

reasoning: The paragraph centrally addresses how Zillow manages cybersecurity risks from third-party service providers, including vendor oversight processes and contractual requirements imposed on providers, making it Third-Party Risk. Specificity reaches Level 2 via domain-specific vendor assessment practices (security questionnaires, information security addenda, network infrastructure reviews) that pass the ERM test—these are cybersecurity-specific assessment mechanisms, not generic vendor management language. No firm-specific or verifiable facts are present.

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

Specific facts:
- security questionnaires (domain term)
- statements of work and information security addenda (domain term)
- audits and compliance reviews (borderline)
- network infrastructure review (domain term)
- cloud-based technology mention
- risk-based assessment levels for third parties

This is clearly Third-Party Risk. The paragraph describes how they manage vendor cyber risks, with requirements imposed ON vendors.

For specificity: security questionnaires, information security addenda, audits and compliance reviews, network infrastructure overviews - these show domain knowledge about vendor assessment practices. The ERM test: "security questionnaires" and "information security addenda" and "network infrastructure overviews" are cybersecurity-specific vendor assessment tools.

This is a Level 2 assessment—there's no firm-specific detail like named roles or committees, and no verifiable claims to anchor it to their actual practices.


reasoning: The final sentence is a direct SEC Item 106(b)(2) materiality assessment ('not aware of any risks from cybersecurity threats that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition'), making SI the primary category. No domain terms passing the ERM test, no firm-specific facts, and the negative materiality assertion is not externally verifiable, leaving specificity at Level 1.

thinking:
The paragraph has two main parts: (1) forward-looking disclaimer about cyber incidents and a cross-reference to Risk Factors, and (2) a materiality assessment statement at the end.

The last sentence is a classic SI materiality statement: "we are not aware of any risks from cybersecurity threats that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition." This is the SEC Item 106(b)(2) language → SI.

Specificity: The materiality assessment is a negative self-assertion. No domain terms that pass the ERM test. No firm-specific facts. No verifiable claims. This is generic boilerplate.

The backward and forward-looking materiality assessment—"not aware of any risks that have materially affected or are reasonably likely to materially affect"—is pure SI language, but it's unverifiable as a negative self-assertion with no domain specificity or firm-specific facts to support it. Level 1.


fact: ERMC (Enterprise Risk Management Committee) — named management-level committee

fact: Vice President of Information Technology

fact: Key employee with over 20 years of experience in information technology and cybersecurity

reasoning: The paragraph primarily answers who in management is responsible for cybersecurity—naming the ERMC, VP of IT, and legal/compliance function, along with qualifications—making it Management Role. The person-removal test leaves only thin program description. Specificity reaches Level 4 because 'over 20 years of experience' is a verifiable lower-bound claim.

thinking:
Classify this paragraph.

Category: This is about management's organization for handling cybersecurity. It names roles (VP of IT, ERMC, legal and compliance function), describes responsibilities, and mentions qualifications. Person-removal test: remove VP of IT, ERMC, key employee with 20 years experience, senior management team - what remains? "responsible for assessing and managing material risks from cybersecurity threats" and "overall cybersecurity risk management program and supervises internal cybersecurity personnel and retained external cybersecurity consultants." Some program description remains but the primary focus is on who is responsible and their qualifications. This is MR.

Now I'm checking the specific facts for firm-specificity. The ERMC is a named committee structure that's firm-specific, the VP of Information Technology title is firm-specific, and the "over 20 years of experience" is a quantified, verifiable credential. The "cyber incident response" phrasing is borderline since incident response appears in the commonly confused terms, but with the training context here I'll set it aside.


reasoning: The paragraph describes the oversight structure for cybersecurity involving senior leadership, the Audit Committee, and the Board—answering 'how does the board oversee cybersecurity?' No domain-specific terms pass the ERM test; 'holistic process for overseeing and managing cybersecurity and related risks' is generic language any business professional would use, and Audit Committee/Board of Directors are standard governance entities present at every public company.

thinking:
Classify this paragraph.

Category: This is introductory/overview language about cybersecurity oversight. It mentions the process is "supported by" senior leadership, Audit Committee, and Board. It's describing the governance/oversight structure at a high level. The primary question answered is about oversight structure → Board Governance.

Specificity: Let me scan for facts.
- "senior leadership team" → generic
- "Audit Committee" → every company has one, not firm-specific
- "Board of Directors" → generic
- "holistic process for overseeing and managing cybersecurity and related risks" → generic ERM language

- No domain terms, no firm-specific facts, no verifiable claims. This lands at Level 1.


fact: CISO role

fact: Audit, Risk and Finance Committee (non-generic board committee name)

fact: Information Security Program (named internal program)

fact: Information Security group

reasoning: The paragraph describes how cybersecurity information flows from management (CISO, Information Security group) up to the board-level Audit, Risk and Finance Committee, making its primary question 'How does the board oversee cybersecurity?' → Board Governance. Specificity is Firm-Specific due to the named CISO role, the non-generic 'Audit, Risk and Finance Committee,' and the named 'Information Security Program.'

thinking:
Classify this paragraph.

Category: This describes how information flows from management (CISO, Information Security group) up to the board committee (Audit, Risk and Finance Committee). It's about oversight structure - governance chain. The primary question answered is "How does the board oversee cybersecurity?" → Board Governance.

Specific facts:
- CISO (named role, firm-specific)
- "Information Security group" (named team)
- "Audit, Risk and Finance Committee" (named committee - non-generic)

- "Information Security Program" (named program)
- "at least quarterly" updates (generic cadence, not firm-specific)
- Internal Audit function mentioned

Level 3 facts: CISO, "Audit, Risk and Finance Committee" (non-generic committee name), "Information Security Program"


reasoning: This paragraph describes the regulatory environment (banking oversight, SEC disclosure rules) rather than any substantive cybersecurity program, governance, or incident disclosure. It is contextual/background information without disclosing the company's own cybersecurity measures, making it None/Other with no specific facts.

thinking: Regulatory context paragraph about financial privacy laws and SEC rules.


fact: penetration testing firms

fact: managed cybersecurity service providers

reasoning: Third parties hired to serve the company (consultants, pen testers, managed service providers) describe components of the internal cybersecurity program, making this RMP per Rule 3. 'Penetration testing' and 'managed cybersecurity service providers' are domain-specific terms that pass the ERM test, elevating to Level 2.

thinking:
Classify this paragraph.

Content: describes working with third parties to help with cybersecurity. The third parties are hired to serve the company (assessors, pen testers, consultants). Per Rule 3, third parties hired to serve the company → RMP.

Specificity: "penetration testing" is a domain term (passes ERM test). "managed cybersecurity service providers" - this is domain-adapted. The rest is generic.

Level 2.


reasoning: This is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk descriptions, with no substantive cybersecurity disclosure of its own. No specific facts elevate specificity above Level 1.

thinking: Cross-reference to Item 1A risk factors. Classic N/O.


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

fact: multi-layered defenses

fact: monitoring and patching of vulnerabilities

reasoning: The paragraph primarily describes what the cybersecurity program does—risk assessments, framework adoption, vulnerability management, incident response planning—making it RMP. The final sentence mentioning Audit Committee oversight is subordinate. Specificity reaches Level 2 via NIST CSF framework reference and domain-specific terms like multi-layered defenses and patch management, but no firm-specific or verifiable facts elevate it further.

thinking:
Let me analyze this paragraph.

Content: Describes the cybersecurity program's approach, framework usage, processes, and mentions Audit Committee oversight at the end.

Category: The primary question answered is "What does the cybersecurity program do?" - RMP. The last sentence mentions Audit Committee oversight but it's a single sentence in a paragraph dominated by program description.

Specific facts:
- NIST CSF → framework (domain term/framework)
- "multi-layered defenses" → domain term (defense in depth concept)
- "vulnerability monitoring and patching" → domain term (patch management)
- Audit Committee oversight → generic, not firm-specific

- The NIST CSF is a named framework, multi-layered defenses reflects defense in depth, and patching vulnerabilities is patch management—all domain terms that pass the ERM test. Beyond the generic Audit Committee mention, there aren't any firm-specific facts or verifiable claims here, so this lands at domain-adapted specificity.


fact: Named individual 'Koichi' is responsible for maintaining internal security measures

reasoning: The paragraph identifies a named individual (Koichi) as the person responsible for maintaining internal security measures, making it minimally about a management role rather than pure disclaimer. The named individual is a firm-specific fact, elevating specificity to Level 3, though the paragraph is otherwise a thin forward-looking hedge with no substantive program description.

thinking:
Classify this paragraph.

This is a short disclaimer about an individual named Koichi believing he can maintain security measures, but no guarantee against breaches. This is speculative/disclaimer language with no substantive cybersecurity disclosure.

Category: This is essentially a forward-looking disclaimer. It mentions "Koichi" maintaining "adequate internal security measures" but then says there's no guarantee. This is speculative hedging language. It doesn't describe any actual program, process, or governance structure in detail. It's closest to None/Other or possibly a very thin RMP statement.

Actually, it does reference a person (Koichi) and their belief about maintaining security.

But the substance here is really just a disclaimer—there's no actual description of any security program or process. Given that this appears to be from a very small company with minimal operations, I'm leaning toward classifying this as None/Other rather than a substantive cybersecurity disclosure. The substantive part here is that a named individual manages security measures, which qualifies as a management role disclosure rather than generic boilerplate—so I should categorize this as Management Role with the firm-specific detail about Koichi.


fact: Chief Risk Officer oversees the enterprise risk management program

reasoning: The paragraph primarily answers what the cybersecurity program does by describing its integration into the overall ERM program, sharing methodologies and reporting channels — this is classic RMP ERM-integration content. The Chief Risk Officer is a firm-specific executive role (C-suite equivalent) elevating specificity to Level 3, though the remaining language about shared methodologies and governance processes is generic.

thinking:
Classify this paragraph.

Content: Describes integration of cybersecurity into ERM program, overseen by Chief Risk Officer, shares methodologies/reporting/governance with other risk areas.

Category: This is about ERM integration of the cybersecurity program. It describes what the program does structurally (integration into ERM). The person-removal test: remove "Chief Risk Officer" - still has substantive content about ERM integration. This is RMP (ERM integration aspect).

Wait - could this be Strategy Integration? SI is about how cybersecurity affects business/finances. ERM integration is more about how the program operates. RMP includes "ERM integration" explicitly.

The Chief Risk Officer reference is a named C-suite role, which makes this firm-specific. Combined with the generic ERM language elsewhere, that pushes this to Level 3 specificity.


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


fact: The Business Continuity Institute (BCI)

fact: Disaster Recovery Institute International (DRII)

fact: business impact analyses

reasoning: The paragraph describes business resilience program activities—continuity planning, exercises, risk assessments—answering 'what does the program do?' → RMP. Named frameworks (BCI, DRII, ISO 22301) and domain terms like business impact analyses demonstrate domain expertise beyond generic ERM language, elevating to Level 2. No firm-unique facts or verifiable claims push higher.

thinking:
Classify this paragraph.

Content: Business resilience, controls from BCI, DRII, ISO 22301, business continuity planning, business impact analyses, risk assessments, continuity strategies, tabletop exercises.

Category: This is about what the program does - business resilience/continuity processes. RMP.

Specificity: BCI, DRII, ISO 22301 are named standards/frameworks → domain terms. "business resilience team" - is this firm-specific? It's a named team but fairly generic. "business impact analyses" - ERM professional would use this. "tabletop exercises" without cybersecurity qualifier → L1 per rules.

The named frameworks like BCI, DRII, and ISO 22301 are definitely domain-specific, which pushes toward Level 2. "Business resilience team" is a named team composition, so that could be firm-specific, but it's generic enough that I'm not confident it qualifies. The rules are pretty strict about what counts as firm-specific versus just standard ERM terminology.


reasoning: The paragraph's central topic is how the company oversees cybersecurity risks from third-party service providers — vendor questionnaires, annual risk assessments, and contractual obligations — making it Third-Party Risk. The language throughout (risk assessments, questionnaires, contractual obligations, regulatory and industry requirements) is standard ERM vocabulary that any non-security risk professional would use; no cybersecurity domain terms pass the ERM test, and there are no firm-specific or verifiable facts.

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

Specific facts: "risk assessments", "questionnaires", "annual third-party risk assessments", "contractual obligations for cybersecurity" - these are about vendor oversight requirements.

Domain terms: Not really passing the ERM test strongly. "Risk assessments and questionnaires" for vendors is standard ERM. "Third-party risk assessments" is generic. "Contractual obligations for cybersecurity, regulatory and industry requirements" - this is standard vendor management language.

This is TP category, and specificity is Level 1 - generic boilerplate.

The language throughout is just standard vendor risk management terminology that any ERM professional would recognize, without any domain-specific security details or unique approaches. Level 1.


fact: CIO role (CISO reports to CIO)

fact: Over 20 years in IT and information security

fact: Undergraduate degree in Information Systems from Xavier University

fact: MBA from Michigan State

fact: Combined total of over 25 IT and Cybersecurity certifications

fact: CISSP (Certified Information Systems Security Professional)

fact: CCSP (Certified Cloud Security Professional)

fact: CISM (Certified Information Security Manager)

reasoning: The paragraph focuses on the CISO's responsibilities, reporting line, team composition, qualifications, and credentials — all person-specific content that collapses under the person-removal test, making this MR. Specificity is Level 4 due to multiple externally verifiable claims: named certifications (CISSP, CCSP, CISM), specific educational institutions (Xavier University, Michigan State), and quantified experience (over 20 years, over 25 certifications).

thinking:
Classify this paragraph.

Category: This is about the CISO's role, qualifications, team, and certifications. Person-removal test: remove names, titles, qualifications, experience, reporting lines, team composition — very little remains. This is MR.

Specific facts:
- CISO (named role, firm-specific)
- CIO (named role, firm-specific)
- "over 20 years" in IT/infosec — quantified-verifiable (lower bound)
- Xavier University undergraduate degree in Information Systems — verifiable

- MBA from Michigan State — verifiable
- Over 25 Information Technology and Cybersecurity certifications — quantified-verifiable
- CISSP, CCSP, and CISM certifications — all verifiable

Specificity: Level 4 (multiple verifiable facts)


reasoning: The paragraph answers how the board oversees cybersecurity: delegation to Audit Committee, reporting to full Board, and management updates on incidents — all classic Board Governance content. No domain-specific terminology (ERM test fails for all terms used), no firm-specific facts (Audit Committee is generic), and no verifiable claims, so specificity remains Level 1.

thinking:
Classify this paragraph.

Category: Board governance - describes board/committee oversight structure, delegation to Audit Committee, reporting flows.

Specific facts:
- Audit Committee (generic, every company has one) → NOT firm-specific
- "management updates the Audit Committee, as necessary, regarding any material cybersecurity incidents" → generic oversight language

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

Level 1.


fact: IT Security Director role with security qualifier at Director level

fact: Reports to Chief Information Officer (CIO)

fact: Threat intelligence

reasoning: The paragraph primarily describes the IT Security Director's reporting line, responsibilities, and team qualifications — applying the person-removal test, little substantive program detail remains beyond the roles. Specificity reaches Firm-Specific due to the IT Security Director (Director-level with security qualifier) and CIO titles; 'decades of experience' and 'various cybersecurity certifications' are too vague to be verifiable.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the IT Security Director's role, reporting line, responsibilities, and the cybersecurity team's qualifications. Using the person-removal test: remove the IT Security Director title, reporting line, team qualifications — what remains? "assessing and managing cyber risk management program, prevention, detection, mitigation, and remediation of cybersecurity incidents, threat intelligence, external consultants." Some program description remains but the primary focus is on WHO is responsible and their qualifications. The paragraph is primarily about management roles and team composition → MR.

Wait, let me re-check.

The paragraph covers reporting line, responsibilities, team experience and certifications, plus threat intelligence and external consultants — most of this centers on the role and team structure rather than the program itself → MR.

Now looking at specificity: "IT Security Director" and "Chief Information Officer" are both firm-specific titles at the director/VP level, "threat intelligence" is a domain-specific term, while "cybersecurity certifications" is mentioned generically without naming particular ones, and "decades of experience" is vague rather than measurable.


fact: CIO has primary responsibility for the information security program

fact: 11 years with the Company (or its affiliates)

fact: Information security team under the direction of the CIO

reasoning: The paragraph primarily describes the CIO's responsibilities, qualifications, and team structure — person-removal leaves only brief process mentions (escalation, scorecards), so MR wins. Specificity is Level 4 due to multiple verifiable claims: specific years of experience (19 and 11) and named certifications (GISLA, CISA) checkable against issuing bodies.

thinking:
Classify this paragraph.

Category: This is about the CIO's role, qualifications, and team structure. Person-removal test: remove CIO, 19 years experience, certifications, team composition → what remains? "information security processes include escalation of certain risks and incidents... with monthly scorecard and quarterly dashboards also used to update the risk landscape." Some process description remains but the bulk is about the CIO's role and qualifications. → MR.

Specific facts:
- CIO (named role, firm-specific)

- 19 years of experience in technology risk management (quantified, verifiable)
- 11 years with the Company (quantified, verifiable)
- SANS Global Information Security Leader certification (verifiable)
- Certified Information Systems Auditor (CISA) certification (verifiable)
- information security team (named team - generic though)
- monthly scorecard, quarterly dashboards (cadence - generic)

Specificity: Level 4 due to verifiable certifications and specific year counts.


reasoning: Third parties hired to serve the company (assessors, consultants) are classified as RMP per Rule 3, not TP. The paragraph uses entirely generic language ('identify, assess, and manage material risks') and references only unnamed entities ('professional services firms,' 'legal counsel,' 'cybersecurity consultants'), with no domain terms passing the ERM test.

thinking:
Classify this paragraph.

Content: Using third-party service providers to help identify, assess, and manage cybersecurity risks, including legal counsel and cybersecurity consultants.

Category: This is about third parties hired to serve the company (assessors, consultants) → per Rule 3, this is RMP, not TP.

Specificity: "identify, assess, and manage material risks from cybersecurity threats" - generic ERM language. "professional services firms, including legal counsel and cybersecurity consultants" - unnamed entities. No domain terms that pass the ERM test.

So this lands at Level 1.


fact: CISO role reporting to CFO

fact: over 20 years of information security experience

fact: over four years as a director in the information security management practice of a big four accounting firm

fact: B.S. in Network Security

fact: Information Security Steering Committee (ISSC)

fact: multiple information security certifications

reasoning: The paragraph primarily describes the CISO's reporting line, qualifications, and the ISSC's composition—answering how management is organized for cybersecurity. While ISSC activities remain after person-removal, the dominant content is the CISO's credentials and committee structure. Specificity reaches Level 4 via verifiable claims: 'over 20 years' of experience, 'over four years' at a big four firm, and a B.S. in Network Security—all externally checkable lower-bound or credential claims.

thinking:
Let me analyze this paragraph.

Category: This paragraph describes the CISO's reporting line, qualifications, and the ISSC committee. Let me apply the person-removal test. Remove CISO details (title, reporting to CFO, 20 years experience, certifications, B.S., director at big four firm). What remains? The ISSC tracks risks, reviews assessments, identifies controls. That's substantive program description but the paragraph is heavily about the CISO's role and qualifications, plus the ISSC structure/membership. It's a mix of MR and RMP.

The paragraph starts with CISO reporting line and qualifications (MR), then describes ISSC membership (MR) and activities (RMP).

Looking at the structure more carefully, the CISO's background and the ISSC's composition take up roughly half the space, while their actual activities—tracking risks, reviewing assessments, identifying controls—fill the other half. The paragraph frames everything through the lens of management organization, with the CISO as the central figure throughout, so this leans toward MR despite the substantive program content embedded within it. The CISO's background and the ISSC's structure are really the heart of this—the specific roles, experience levels, and committee composition matter more than the abstract activities. I'm settling on MR because the paragraph is fundamentally about how the organization is set up and who's running it, even though the risk management functions are mentioned.


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

thinking: SI materiality assessment + cross-reference to risk factors + N/O company name.


fact: data exfiltration

fact: forensic and remediation costs as materiality factors

reasoning: The paragraph describes how the company determines materiality of cybersecurity incidents—listing specific evaluation criteria—which is a risk management process activity. Terms like 'data exfiltration' and 'forensic and remediation costs' pass the ERM test as cybersecurity-specific vocabulary, elevating to Level 2. While it discusses materiality, it describes the PROCESS of determining materiality rather than stating a conclusion about whether cybersecurity has affected business outcomes, so it's RMP rather than SI. The cross-reference to Item 1A is incidental.

thinking: Materiality determination process with specific criteria listed, plus a cross-reference.


fact: Task Force provides information to Audit Committee regarding cybersecurity activities

reasoning: The paragraph describes how information flows from the Task Force to the Audit Committee, including briefing frequency and incident notification responsibilities — squarely answering 'how does the board oversee cybersecurity?' The 'Task Force' is a named non-generic organizational unit (not every company has one), elevating to Firm-Specific, though 'Audit Committee' and 'at least annually' are generic.

thinking:
Classifying this paragraph about MARA Holdings.

The paragraph describes how information flows from the Task Force to the Audit Committee - briefings, continuing education, notification of incidents. This is about board oversight structure (how information reaches the board).

Category: Board Governance - describes how information flows to the board/Audit Committee.

Specific facts:
- "Task Force" - a named committee (firm-specific? It's somewhat generic but in context it refers to a specific internal body)
- "Audit Committee" - generic, every company has one
- "at least annually" - generic cadence

"Task Force" - this seems like a named internal group.

The Task Force qualifies as firm-specific since it's a named organizational unit rather than a generic committee structure like Audit Committee. Not every company has a dedicated cybersecurity Task Force, so I'll count it as Level 3 specificity.


reasoning: The paragraph's central purpose is a materiality assessment — 'have not materially affected and are not reasonably likely to materially affect our company, including our business strategy, results of operations, or financial condition' — which is the canonical SI formula per Rule 5. No domain terms pass the ERM test, no firm-specific facts (mentions of past breaches are vague with no details), and 'December 31, 2023' is a reporting period anchor rather than a verifiable cybersecurity fact, leaving specificity at Level 1.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. Mentions past threats/breaches (vague)
2. States materiality assessment - "have not materially affected and are not reasonably likely to materially affect"
3. Cross-reference to Item 1A

The materiality assessment is the core content - this is a backward-looking and forward-looking SI assessment per Rule 5.

Specificity: The materiality statement is a negative self-assertion ("have not materially affected") which is NOT externally verifiable. "December 31, 2023" is a reporting period date, not a cybersecurity fact.

The reference to "breaches of our data within third party vendor's system" is too vague to be meaningful - there are no domain-specific terms that would satisfy the ERM test, no firm-specific facts, and nothing that's actually verifiable. This lands at Level 1.


fact: CIO responsible for information security program

fact: CIO has 25 years of experience in information technology

fact: CIO reports to the Chief Executive Officer

fact: Supported by a dedicated cybersecurity team within information systems department

fact: Multidisciplinary incident response team

reasoning: The paragraph's primary purpose is describing the governance oversight chain from Board → Audit Committee → CIO → team, answering how the board oversees cybersecurity, making it BG per Rule 1 despite significant MR content. Specificity reaches Level 4 due to the CIO's '25 years of experience' — a hard number that is externally verifiable against a resume.

thinking:
Let me analyze this paragraph.

Category: This covers board oversight (Board + Audit Committee), management roles (CIO), and some program elements. The paragraph answers multiple questions but the dominant frame is governance structure - how the board oversees cybersecurity and how information flows. But there's also significant MR content (CIO role, qualifications, reporting lines, team). Let me assess text allocation.

Board/governance content: Board + Audit Committee oversight, reports from management, updates on assessments/strategies. ~4 sentences.
Management role content: CIO responsible for program, 25 years experience, reports to CEO, supported by dedicated team and incident response team. ~3 sentences.

The governance chain flows from Board through Audit Committee to CIO to the teams below, which frames this primarily as a governance structure question, so I'm categorizing it as BG. For specificity, the CIO is a named firm role at Level 3, the 25 years of experience is quantified and verifiable at Level 4, while the dedicated cybersecurity team and multidisciplinary incident response team vary in how firm-specific they are.


reasoning: The paragraph states a backward-looking materiality conclusion ('have not been materially affected') which is a Strategy Integration assessment per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present — the negative assertion about no material impact is a self-reported claim, and the cross-reference to Item 1A adds no substantive content.

thinking: SI materiality rule applies here.


reasoning: The paragraph addresses both consultants assisting with cybersecurity program design (RMP per Rule 3) and contractual requirements imposed on third-party service providers (certification of security measures, breach reporting obligations), with the vendor-oversight requirements representing the more distinctive and central content → TP. All language is generic ('risk assessment processes,' 'cybersecurity policies and procedures,' 'reasonable security measures') with no domain-specific terminology passing the ERM test, no named firms, and no verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party service providers in two contexts: (1) consultants helping with risk assessment/program design (third parties serving the company → RMP), and (2) requirements imposed on third-party service providers (vendor oversight → TP).

The paragraph splits between RMP (consultants helping design/implement/monitor) and TP (requiring certifications from service providers). The second half about requiring certifications and breach reporting is about requirements imposed ON vendors → TP. But the first part is about third parties hired to serve the company → RMP.

Which is central? The paragraph starts with consultants helping the company (RMP) then shifts to requirements on service providers (TP).

Looking at the specific language: the consultants assisting with risk assessment and implementation work falls under RMP, while the requirements we impose on vendors—certifications and breach reporting—are clearly TP. The content is genuinely split between both categories, though the vendor requirements section takes up comparable space, so I'm leaning toward Third-Party Risk as the primary classification. is genuinely split between the consultants themselves and the requirements imposed on them, but the requirements are what really stand out here. There are no named firms or specific frameworks—just generic language around certifying security abilities, implementing reasonable measures, and reporting breaches promptly. This reads as Level 1 specificity.


reasoning: The paragraph's primary content is a backward-looking materiality assessment ('risks from cybersecurity threats have to date not materially affected us, our business strategy, results of operations or financial condition'), which is SI per Rule 5. The remainder is a vague mention of past breaches, a cross-reference to Item 1A, and an unrelated pharma competition sentence. No domain terms passing the ERM test, no firm-specific facts, and no verifiable claims — the negative materiality assertion is a self-reported claim about absence, not externally verifiable.

thinking:
Let me analyze this paragraph.

The paragraph states "risks from cybersecurity threats have to date not materially affected us, our business strategy, results of operations or financial condition" — this is a backward-looking materiality assessment → SI.

It also mentions "experienced threats to and breaches" — touches on incidents but vaguely, and the materiality assessment is the primary frame.

Then there's a cross-reference to Item 1A and a sentence about pharmaceutical industry competition that's not cybersecurity-related.

Category: Strategy Integration — the materiality assessment is the primary content per Rule 5.

The negative materiality claim isn't externally verifiable, and the vague references to threats and breaches lack specifics. "Pharmaceutical industry" and "third-party vendors" are generic terms that don't meet the ERM test, and there are no firm-specific facts anywhere. This is Level 1 — Generic Boilerplate.


fact: Firewalls

fact: Intrusion detection/prevention systems (IDS/IPS)

fact: Data loss prevention (DLP)

fact: Antivirus, anti-malware

fact: Mobile Device Management (MDM)

fact: Principle of least privilege

fact: Encryption at rest and in transit

fact: Phishing awareness training

reasoning: The paragraph describes specific cybersecurity program activities across network security, endpoint security, access controls, data security, and training — all RMP activities. It is rich in domain terminology (IDS/IPS, DLP, MDM, least privilege, encryption at rest/in transit) that passes the ERM test, but contains no firm-specific facts or verifiable claims, placing it at Level 2.

thinking:
Classifying this paragraph about C3.ai's cybersecurity measures.

Category: RMP - describes what the cybersecurity program does (security tools, practices, controls)

Specificity: Multiple domain terms - IDS/IPS, DLP, endpoint security, antivirus, anti-malware, MDM, least privilege, encryption at rest and in transit, phishing. These pass the ERM test. No firm-specific facts or verifiable claims beyond domain terminology.

Level 2.


reasoning: The paragraph centrally addresses how the company manages third-party cybersecurity risks through vendor assessments and ongoing monitoring, making TP the clear category. The language is entirely generic — 'security assessments,' 'ongoing monitoring,' 'compliance with our cybersecurity standards' — all phrases any ERM professional could write without cybersecurity domain knowledge, yielding Level 1.

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

Specificity: "security assessments of key third-party providers" and "ongoing monitoring" - these are generic process descriptions. No domain terms that pass the ERM test. No firm-specific facts. No verifiable claims.

This is Level 1 - generic descriptions of vendor oversight.


reasoning: The paragraph states a backward-looking materiality conclusion ('none of these threats or incidents...has materially affected the Company'), which is a SI assessment per Rule 5. 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, and the cross-reference to Item 1A is boilerplate.

thinking: SI - materiality assessment + cross-reference


reasoning: This paragraph is a cross-reference to Item 1A Risk Factors with speculative 'could have a material adverse effect' language, containing no substantive cybersecurity disclosure. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: Cross-reference to Item 1A with speculative "could have" language. This is a classic None/Other.


fact: malware

fact: computer virus attacks

reasoning: The paragraph's central statement is a backward-looking materiality assessment ('have not materially affected us, including our business strategy, results of operations or financial condition'), making it SI per Rule 5. Specificity reaches Level 2 via specific threat types (malware, computer virus attacks), though the rest is generic; no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

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

It also mentions "we have, from time to time, experienced threats to and breaches of our data and systems, including malware and computer virus attacks" — this references actual incidents but very vaguely.

The primary question answered: "How does cybersecurity affect the business/finances?" — the materiality assessment is the core statement. The incident mention is subordinate and lacks specifics. SI.

Checking the specificity of "malware and computer virus attacks" — these are recognized threat types in the domain terminology, so they count as specific language even though the overall incident description remains vague and the materiality claim itself isn't verifiable. I'll keep this at Level 2.


fact: Cross-functional approach involving information technology, legal, and internal audit functions

fact: CISO

fact: CIO

fact: Technology & Operations Committee

fact: Updates provided on at least a quarterly basis

reasoning: The paragraph describes how cybersecurity information flows to board-level committees (Audit Committee and Technology & Operations Committee), making it primarily about board oversight structure → BG. Specificity reaches Level 3 via firm-specific facts: named roles (CISO, CIO), a non-generic committee (Technology & Operations Committee), and specific departmental composition (IT, legal, internal audit).

thinking:
Let me analyze this paragraph.

Category: This describes how information flows to board-level committees (Audit Committee, Technology & Operations Committee). It's about oversight structure and reporting to the board. This is Board Governance.

Specific facts:
- Cross-functional approach with IT, legal, internal audit functions - specific team composition by department → firm-specific
- CISO → named_role (firm-specific)
- CIO → named_role (firm-specific)
- Technology & Operations Committee → named_committee (firm-specific, non-generic)
- Quarterly basis → not firm-specific

- The topics covered—threats, incidents, security controls, assessments, program maturity, and risk mitigation—are general industry concepts, but the specific committee structure and named roles push this to Level 3 (Firm-Specific).


fact: Marriott brand standards relating to information security imposed on franchisees/licensees

reasoning: The paragraph's central topic is how franchisees and licensees (third parties) are responsible for information security at non-owned properties and what requirements Marriott imposes on them, making it Third-Party Risk. The reference to 'Marriott brand standards relating to information security' as a named internal requirement is a firm-specific detail, elevating specificity to Level 3.

thinking:
Classifying this paragraph about franchisee/licensee information security responsibilities.

Category: This is about third-party (franchisee/licensee) cybersecurity obligations - requirements imposed ON them. Central topic is how non-owned properties handle security and what Marriott requires of them. → Third-Party Risk

Specificity: "franchisees, licensees" - these are generic terms. "Marriott brand standards relating to information security" - firm-specific reference. "obligation to report relevant information security incidents" - generic process. The mention of specific counterparty types (franchisees, licensees) and "Marriott brand standards" is firm-specific.

The franchise/licensee structure combined with the reference to Marriott's internal brand standards makes this Level 3 - it's organizational detail specific to how this company operates, even though the underlying concept of third-party security requirements is common across the industry.


reasoning: The paragraph describes engaging external service providers to evaluate and enhance the company's security policies—per Rule 3, third parties hired to serve the company are RMP, not TP. The language is entirely generic ('information security policies and procedures,' 'specialized knowledge,' 'aligned with regulatory requirements') with no domain terms passing the ERM test, no firm-specific facts, and no verifiable claims.

thinking:
Classify this paragraph.

Content: About engaging external service providers to help with cybersecurity policies and procedures. The central topic is third-party engagement, but these are third parties hired to serve the company (assessors helping evaluate/enhance security), not vendor oversight. Per Rule 3, third parties hired to serve the company → RMP.

Specificity: No domain terms that pass ERM test. "information security policies and procedures", "cybersecurity policies and procedures" - generic. "external service providers" - generic. No firm-specific facts, no verifiable claims. Level 1.


fact: data security posture

reasoning: The paragraph describes how the Audit Committee oversees cybersecurity risks, including briefing frequency, topics covered, and escalation to the full Board—squarely answering the board oversight question. 'Data security posture' passes the ERM test as a cybersecurity-specific concept (an ERM professional would say 'risk posture'), but most other terms (incident response plan, business continuity planning, third-party assessments) are generic ERM language. No firm-specific or verifiable facts elevate beyond Level 2.

thinking:
Board governance paragraph about Audit Committee oversight.

Facts: "Audit Committee" (generic, not firm-specific), "quarterly" (generic cadence), mentions incident response plan, data security posture, third-party assessments, risk mitigation goals, business continuity planning.

Let me check domain terms: "data security posture," "incident response plan" — "incident response plan" is listed as commonly confused L1. "Data security posture" — would an ERM professional use this? Possibly not naturally; "security posture" is a cybersecurity domain concept.

"Data security posture" is a cybersecurity-specific term that an ERM professional would more likely call "risk posture," so that's a domain-specific indicator for Level 2. "Incident response plan" and "business continuity planning" are both flagged as commonly confused L1 terms. The rest like "third-party assessments" and "risk-mitigation-related goals" are too generic. So I'm seeing one clear domain term here, which puts this at Level 2 for Board Governance focused on Audit Committee cybersecurity oversight.


reasoning: The paragraph describes Board of Directors oversight of cybersecurity risk, reporting flows from management to the full board and Audit Committee — squarely answering the board governance question. All references (Board of Directors, Audit Committee, 'at least annually') are generic governance structures and cadences that every public company could claim, with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Board governance paragraph about board oversight of cybersecurity risks.

Facts: Audit Committee (not firm-specific - every company has one), "at least annually" reporting cadence (generic), full Board designated as primary responsible.

No domain terms that pass ERM test. No firm-specific facts beyond generic governance. No verifiable claims.

Level 1.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity with quarterly update cadence, squarely answering how the board oversees cybersecurity → BG. All terms (cybersecurity assessments, third party risk management, quarterly updates, Audit Committee) are generic ERM language that any public company could produce; no domain-specific, firm-specific, or verifiable facts are present.

thinking:
Classify this paragraph.

Category: Board/Audit Committee oversight, briefing frequency → Board Governance

Specifics: "Audit Committee" is generic (every company has one), "quarterly updates" is generic cadence. No firm-specific roles, no domain terms beyond generic "cybersecurity assessments, third party risk management." These are generic ERM terms.

Wait - "third party risk management" and "cybersecurity assessments" - do these pass the ERM test? An ERM professional would use these terms. No domain expertise shown.

Specificity: Level 1 - Generic Boilerplate.


content_category: Incident Disclosure

fact: advanced persistent threats (APT) referenced as a threat type

fact: Rockstar Games named as affected subsidiary

fact: Early development footage for next Grand Theft Auto was downloaded

fact: 2K Games named as affected subsidiary in second incident

fact: September 2022 unauthorized access to vendor help desk platform credentials at 2K Games

fact: Malicious link sent to certain players via compromised help desk platform

reasoning: The paragraph opens with a materiality statement (SI) but the bulk describes two specific real-world incidents in September 2022 involving Rockstar Games and 2K Games, making the incident frame dominant → ID per Rule 4. Specificity is Level 4 due to multiple externally verifiable facts: specific dates (September 2022), named subsidiaries (Rockstar Games, 2K Games), and a widely-reported event (GTA source footage leak).

thinking:
Let me analyze this paragraph carefully.

It describes actual cybersecurity incidents (September 2022 network intrusion at Rockstar Games, unauthorized access to 2K Games vendor platform) along with a materiality assessment. The paragraph contains both incident details and a materiality conclusion.

Category: The dominant frame is incident disclosure - it describes what happened (timeline, scope, response) with specific real events. There's also a materiality statement at the start ("none of these threats or incidents...have materially affected the Company") which is SI. But the bulk of the paragraph is about actual incidents. Per Rule 4, mixed with incident frame dominant → ID.

Looking at the specificity, I'm seeing concrete details throughout: the September 2022 timeframe tied to actual events, named entities like Rockstar Games and 2K Games, specific products like Grand Theft Auto, domain terminology like "network intrusion" and "advanced persistent threats," and verifiable incident details that ground this in real occurrences rather than hypothetical scenarios.


fact: denial-of-service attacks, hacking, phishing, ransomware, malware, social engineering, vendor software supply chain compromises listed as threat types

fact: Vice President of IT responsible for information security program

reasoning: The paragraph is an introductory overview of the cybersecurity program covering governance structure, threat landscape, and risk context; while it mentions the Board/Audit Committee oversight chain, the bulk of text describes the risk environment and program purpose, making RMP the best fit. The VP of IT role (VP-level title with IT portfolio) is a firm-specific fact elevating specificity to Level 3, with domain-adapted threat terminology also present.

thinking:
Let me analyze this paragraph.

Content: Introductory paragraph about cybersecurity risk management. It mentions the VP of IT role, Board/Audit Committee oversight, and describes various cyber threats and risks.

Category: This is a mixed paragraph. It mentions governance (Board, Audit Committee), management (VP of IT), and describes threat landscape. The primary question it answers is "What does the cybersecurity program do?" but it's really more of an introductory overview. The governance chain description (Board → Audit Committee → VP of IT → program) per Rule 1 defaults to BG when describing oversight structure. But the bulk of the text is about threat landscape and risk description. Let me re-read...

Actually, looking at the structure more carefully, the paragraph opens with governance and oversight, then pivots to a lengthy description of the threat landscape and vulnerabilities we face, with a brief mention of third-party vendors. The governance elements are there but secondary to the risk description. Given the section header and the content mix, this reads as Risk Management Program material—it's setting the stage for what the program addresses rather than detailing governance processes.

On specificity, "Vice President of IT" is firm-specific since it's an actual title in their structure, while "Audit Committee" is standard across companies. The threat list—denial-of-service, hacking, phishing, ransomware, malware, social engineering, supply chain compromises—is generic risk language that doesn't reveal much about their particular vulnerabilities.


reasoning: The paragraph describes how information flows from the security team to the Audit Committee and Board via quarterly updates, squarely answering the board oversight question → Board Governance. No domain terms pass the ERM test ("cybersecurity systems testing" and "cybersecurity incidents" are generic), Audit Committee and Board of Directors are not firm-specific, and "quarterly" is a generic cadence, leaving this at Level 1.

thinking:
Classify this paragraph.

Category: This describes how information flows to the board/audit committee - quarterly updates from security team to Audit Committee/Board. This is about board oversight structure → Board Governance.

Specific facts:
- "security team" - generic
- "quarterly updates" - generic cadence
- "Audit Committee" - generic, every company has one
- "Board of Directors" - generic

The content mentions cybersecurity systems testing (domain term? No, "systems testing" is pretty generic), third parties, incidents. These are topics of the briefings, not domain terms showing expertise.

"Cybersecurity systems testing" is borderline but still something an ERM professional would use. This reads like standard boilerplate with no firm-specific details—no named executive roles, no specialized committees beyond the typical Audit Committee, and no domain language that signals real expertise. This is Level 1 - Generic Boilerplate.


reasoning: The paragraph states generic goals of a cybersecurity program (business continuity, protecting data/technology) without describing any specific processes, roles, or governance structures. It contains no domain terminology, firm-specific facts, or verifiable claims, remaining at Level 1.

thinking: Simple paragraph stating goals.


reasoning: The paragraph states a backward-looking conclusion that cybersecurity has not materially affected the company ('have not experienced any material cybersecurity incidents' and 'expenses...have been immaterial'), which is an SI materiality assessment per Rule 5. 'Last three fiscal years' is a soft timeframe and the negative assertion about absence of incidents is not externally verifiable, so no facts elevate specificity above Level 1.

thinking: Materiality assessment - negative assertion about no material incidents and immaterial expenses.


fact: Regular vulnerability scanning (internal and external)

fact: Penetration testing via independent security professionals

fact: Threat intelligence feeds for real-time threat information

fact: Security questionnaires for vendor assessment

fact: Third-party attestation review as part of vendor due diligence

reasoning: The paragraph primarily answers 'what does the cybersecurity program do?' by describing vulnerability scanning, penetration testing, threat intelligence monitoring, and a risk assessment framework — all program activities → RMP. Third-party vendor risk is one component of the broader program (Rule 3). Multiple domain terms pass the ERM test (vulnerability scanning, penetration testing, threat intelligence feeds, security questionnaires, third-party attestation), but no firm-specific facts (no named roles, committees, or individuals) and no verifiable claims (no named firms, certifications held, or hard numbers), so specificity stays at Level 2.

thinking:
Let me analyze this paragraph.

Content category: This describes what the cybersecurity program does - vulnerability scanning, penetration testing, threat intelligence monitoring, risk assessment framework, and third-party vendor risk assessment. The main question answered is "What does the cybersecurity program do?" → RMP.

The third-party content is substantial but it's presented as part of the broader program description. The paragraph starts with the overall program and lists multiple activities, with vendor risk being one component. Per Rule 3, third parties mentioned as one component of internal program → RMP.

Specificity: Let me list facts:
- "vulnerability scanning" (internal and external) → domain term

- "Penetration testing" → domain term
- "threat intelligence feeds" → domain term
- "risk assessment framework" → this is generic ERM language
- "third-party vendor risk assessment" → could be either
- "security questionnaires" → domain term
- "third-party attestation" → domain term (like SOC 2 style)
- "security and vulnerability scans" → domain term

The paragraph mentions "independent security professionals" but unnamed. No named roles, no specific individuals, no verifiable claims.

Domain terms that pass the ERM test: vulnerability scanning, penetration testing, threat intelligence feeds, security questionnaires. These are cybersecurity-specific.

No firm-specific facts here either—no named executives, committees, or team structures. No verifiable details like numbers, dates, certifications, or vendor names. This lands at Domain-Adapted (Level 2) for specificity.


fact: Chief Information Officer

fact: vCISO (virtual CISO)

reasoning: The paragraph describes how the Board delegates cybersecurity oversight to the Audit Committee and how information flows upward, squarely answering the board governance question. Specificity reaches Level 3 due to firm-specific roles (CIO and notably vCISO, indicating the company uses a virtual CISO rather than a full-time one), but no externally verifiable claims push it to Level 4.

thinking:
Classify this paragraph.

Category: Board Governance - describes board/committee oversight structure, delegation to Audit Committee, how information flows to the board.

Specific facts:
- "Chief Information Officer" - named_role (firm-specific, VP+ level)
- "vCISO" - named_role (firm-specific, virtual CISO)
- Audit Committee - generic, every company has one, not firm-specific

vCISO is a firm-specific detail - it tells you this company uses a virtual CISO rather than a full-time one.

There are no verifiable facts like specific numbers, dates, or certifications, but the CIO and vCISO roles make this firm-specific at Level 3.


reasoning: The opening sentence delivers a backward-looking and forward-looking materiality assessment ('have not materially affected us or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition'), which is the hallmark of SI under Rule 5. The remainder is generic speculation about potential costs and cross-references to Item 1A. No domain terms pass the ERM test, no firm-specific facts, and the negative materiality assertion is not externally verifiable, so specificity stays at Level 1.

thinking:
The paragraph starts with a materiality assessment, then cross-references Risk Factors, then speculates about potential impacts.

First sentence: "To date, we do not believe risks from cybersecurity threats...have materially affected us or are reasonably likely to materially affect us, including our business strategy, results of operations or financial condition." → This is a backward-looking and forward-looking materiality assessment → SI per Rule 5.

Rest is speculation and cross-references → N/O territory.

The primary content is the materiality assessment in the first sentence, which is SI. The rest is generic speculation and cross-references.

Looking at the specificity now — the materiality statement is just a negative self-assertion without external verification, and the language around cybersecurity incidents and threat protection measures is entirely generic boilerplate. There are no domain-specific terms or firm-specific facts beyond the materiality conclusion itself, so this lands at Level 1.


reasoning: The paragraph states a backward-looking and forward-looking materiality conclusion ('have not materially affected or are reasonably likely to materially affect'), which is the hallmark of Strategy Integration per Rule 5. The remainder is a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims are present — the date is a reporting-period anchor and the negative materiality assertion is not externally verifiable.

thinking:
Let me analyze this paragraph.

It states a conclusion about whether cybersecurity has materially affected business outcomes → SI (Rule 5). The first sentence is a backward-looking materiality assessment plus forward-looking "reasonably likely to materially affect." The second sentence is a cross-reference to Item 1A.

Specificity: "As of December 31, 2024" is a reporting period anchor, not a cybersecurity fact. The materiality assessment is a negative self-assertion - not externally verifiable. No domain terms, no firm-specific facts. This is Generic Boilerplate.

The language about not identifying risks that have materially affected or are reasonably likely to materially affect is another materiality assertion without specificity - no domain expertise, no firm-specific details, no verifiable claims. This is Level 1 boilerplate.