reasoning: The paragraph states backward-looking materiality conclusions ('have not experienced any material cybersecurity incidents' and 'expenses incurred from any security incidents have been immaterial'), which are SI assessments per Rule 5. The remainder is generic speculation and cross-referencing risk factors. No domain terms pass the ERM test, no firm-specific facts, and the negative incident assertion is not externally verifiable, leaving specificity at Level 1.

thinking:
Let me analyze this paragraph.

Content: States no material incidents, expenses immaterial, references risk factors, discusses potential future impacts and resource expenditure.

Category: The paragraph states a conclusion about whether cybersecurity has affected business outcomes ("have not experienced any material cybersecurity incidents, and the expenses incurred from any security incidents have been immaterial") - this is a backward-looking materiality assessment → SI. It also has forward-looking speculation but the materiality assessment is present.

Wait - "Have not experienced any material cybersecurity incidents" → SI per Rule 5. Also "expenses incurred from any security incidents have been immaterial" is another backward-looking assessment.

The forward-looking part about potentially expending greater resources is speculative and hedged. Looking at specificity, the claim about not experiencing material incidents is a negative self-assertion that's not externally verifiable, with no domain-specific terms or firm-specific facts—just generic boilerplate language. That puts it at Level 1 specificity.


content_category: Third-Party Risk

fact: 21 CFR 11 (Part 11) compliance for electronic records and signatures

type: framework

fact: antivirus and antimalware software

category_confidence: high

specificity_confidence: high

reasoning: The paragraph's central topic is how the company manages cybersecurity through its CRO relationship—it has no own policy, so vendor oversight IS the cybersecurity program, making Third-Party Risk the primary category. Specificity reaches Level 2 via the 21 CFR 11 regulatory framework reference and antivirus/antimalware domain terms, but no named firms or verifiable quantities push it higher.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: The company doesn't have its own cybersecurity policy but contracts with CROs. Describes the CRO's compliance (21 CFR 11), their security measures, and the company's oversight of the CRO.

Category: This is about how third-party cyber risks are managed - vendor oversight is the central topic. The company's entire cybersecurity posture is outsourced to CROs, and the paragraph describes requirements imposed on and review of vendors. → Third-Party Risk

Specific facts:
- "21 CFR 11 (Part 11) compliant" - this is a named regulatory standard, domain term/framework

- "antivirus and antimalware software" - domain-specific security controls
- "incident response, backup and recovery" - standard ERM practices
- "CRO" (Contract Research Organization) - a generic industry term, not firm-specific

Nothing here is firm-specific or proprietary—no named individuals, committees, or executive titles. The 21 CFR 11 compliance claim could theoretically be verified, but the paragraph doesn't provide enough detail to assess verifiability.

This lands at Level 2 because of the domain-adapted language around 21 CFR 11 and security controls, even though the rest is generic.


content_category: Strategy Integration

reasoning: The paragraph states a backward-looking materiality conclusion ('have not identified any cybersecurity incidents or threats that have materially affected us') and a forward-looking SEC 106(b)(2) assessment ('reasonably likely to materially affect us'), both triggering the SI materiality rule. No domain terms, firm-specific facts, or verifiable claims are present—the negative assertion about no material incidents is not externally verifiable, and the remainder is generic language plus a cross-reference to Item 1A.

thinking: Materiality assessment paragraph.


reasoning: The paragraph states backward-looking conclusions about no material security breach, no material expenses, and no penalties — these are materiality assessments about business/financial impact, mapping to SI under Rule 5. Specificity is Level 1: 'last three years' is a soft timeframe, negative self-assertions are not externally verifiable, and no domain terms, firm-specific facts, or quantified claims are present.

thinking:
Classify this paragraph.

This is a negative assertion about not having experienced material incidents and no expenses/penalties. Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI (negative assertion, backward-looking materiality assessment).

Specificity: "During the last three years" is a soft timeframe. The negative assertions are not externally verifiable. No domain terms, no firm-specific facts, no verifiable claims. Level 1.


content_category: Risk Management Process

category_confidence: medium

reasoning: The paragraph covers multiple topics but the bulk of the text describes what the cybersecurity program does—risk assessment, monitoring, testing, security tools, third-party collaboration, and due diligence processes—making RMP the primary category. Despite the SI-qualifying materiality statement ('have not materially affected...business strategy, results of operations, or financial condition') and board oversight mention, RMP content dominates by volume. Specificity remains Level 1 because all language ('assess risks,' 'monitor information systems,' 'security tools,' 'identify, escalate, investigate, resolve, and recover') is generic process description that passes the ERM test—swap 'cybersecurity' for any other risk domain and the language still works. No named frameworks, specific tools, domain terminology, or firm-specific facts are present.

thinking:
Let me analyze this paragraph carefully.

This is a dense paragraph covering multiple topics. Let me break it down:

1. Management assesses risks, monitors systems, tests systems - RMP
2. Security tools for incident lifecycle - RMP
3. Board assesses risks based on probability and impact - BG
4. Third-party collaboration for assessments - RMP/TP
5. Third-party risk management process - TP
6. "have not materially affected" statement - SI
7. Cross-reference to risk factors - N/O

The bulk of the text focuses on risk management processes and what the cybersecurity program actually does—the risk assessments, monitoring, tools, and third-party collaboration all point to RMP as the primary category. Even though there's a materiality statement about threats not affecting the company, that's secondary to the main content about program activities.

Looking at the specificity now, the language is pretty generic throughout—"security tools," "identify, escalate, investigate, resolve," "third-party cybersecurity risk management," "due diligence on external entities." There are no named frameworks, specific tool names, or domain-specific terminology that would really stand out. The materiality assertion itself is just a self-reported negative claim without verification. Even phrases like "cybersecurity prevention and response systems" and "identification, verification, and validation of cybersecurity risks" are standard risk management language, not particularly distinctive.

This is clearly Level 1—Generic Boilerplate. Everything here could apply to any risk domain with minimal changes.


reasoning: The paragraph is split between describing consultants assisting the company's program (RMP) and future requirements to impose on third-party service providers (TP); the vendor certification requirements comprise the majority of text, making TP the dominant topic per Rule 3. All language ('risk assessment processes,' 'cybersecurity policies and procedures,' 'monitor and test safeguards,' 'appropriate security measures') is generic ERM-level vocabulary with no domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Talks about engaging third-party consultants for risk assessment, designing/implementing cybersecurity policies, monitoring/testing safeguards. Then discusses future intentions for requiring third-party certifications.

Category: First part is about third parties hired to serve the company (assessors) → RMP per Rule 3. Second part is about requirements imposed ON vendors → TP. The first part describes consultants helping with their own program. The second part is future intent for vendor requirements. Mixed - but the first sentence frames it as "risk assessment processes" with third parties assisting. The second half is future intent ("In the future, we intend to require...") for vendor oversight.

This is split between current RMP activities—where they're using third-party assessors for their own risk management—and future TP intentions around vendor certifications. The first half is clearly RMP under Rule 3, while the second half about requiring vendor certifications points toward TP, though it's aspirational rather than current practice. Given that the RMP portion describes what they're actively doing now while the TP portion is still in planning stages, I'm leaning toward RMP as the primary category here.

Actually, looking at the text distribution, the vendor requirement sentence is substantially longer and seems to be the main focus of the paragraph. That tips it toward TP despite being future-oriented. The language throughout is also quite generic—"risk assessment processes," "cybersecurity policies," "monitor and test our safeguards"—with no specific frameworks, named roles, or verifiable details that would ground this in concrete practice.


content_category: None/Other

reasoning: As an exploration-stage company explicitly stating it has not adopted any formal cybersecurity risk management programs or processes, this falls under Rule 6's no-operations/no-program threshold for N/O. The paragraph contains only forward-looking commitments and contextual statements about data storage, with no substantive cybersecurity measures described. N/O paragraphs always receive Generic Boilerplate.

thinking:
Exploration stage company with no formal cybersecurity program. This is a classic N/O or SI case.

The paragraph says they haven't adopted formal programs, acknowledges importance, and notes they don't store customer data.

Category: This is essentially saying "we don't have a program yet." There's no substantive cybersecurity disclosure. But wait - "We have not yet adopted formal cybersecurity risk management programs" - is this a materiality assessment? No, it's stating they don't have a program. The commitment to implement is forward-looking. "We do not store in our systems any customer or similar data" is contextual.

This feels like N/O - no substantive cybersecurity disclosure exists.

The explicit statement that they lack a program aligns with Rule 6 for SPACs and no-operations companies, which means this is N/O with Generic Boilerplate.


content_category: Board Governance

fact: SMIS and Cybersecurity Committee provides reports to the Board

fact: Cybersecurity committee as a named non-generic committee

fact: SMIS's team handles cybersecurity incidents

fact: cyber incident response plan

reasoning: The paragraph describes how the Board of Directors receives cybersecurity reports and how incident information escalates through the governance chain (SMIS team → Cybersecurity Committee → Board/Audit Committee), making it Board Governance. Specificity is Firm-Specific due to the named 'SMIS and Cybersecurity Committee' and 'SMIS's team,' which are non-generic organizational entities unique to this company.

thinking:
Classify this paragraph.

Category: This describes how the Board receives reports from committees about cybersecurity, and how incident information flows up to the Board. This is about board oversight structure and information flow → Board Governance.

Specific facts:
- "SMIS and Cybersecurity Committee" → named_committee (firm-specific)
- "cyber incident response plan" → domain_term (but generic)
- "Audit committee" → generic, not firm-specific
- "Cybersecurity committee" → named_committee (firm-specific, non-generic)
- "SMIS's team" → named_team (firm-specific)

- The presence of named committees and teams like SMIS and the Cybersecurity Committee pushes this to firm-specific classification.


reasoning: The paragraph describes how the Board delegates cybersecurity oversight to the Audit Committee, directly answering how the board oversees cybersecurity → Board Governance. All entities mentioned (Board, Audit Committee) are generic governance structures present at every public company, with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: Board delegates to Audit Committee for cybersecurity oversight. This is about how the board oversees cybersecurity → Board Governance.

Specificity: "Audit Committee" is generic (every company has one). "Board" is generic. No domain terms, no firm-specific facts, no verifiable claims. This is generic oversight language.

Level 1.


reasoning: The paragraph's primary purpose is a backward-looking materiality assessment ('does not believe that it has experienced any material cybersecurity incidents, nor any material costs') which maps to SI under Rule 5. The remaining content is generic speculation ('cannot provide assurance') and a cross-reference to Item 1A, neither of which override the assessment. For specificity, 'past two years' is a soft timeframe, the negative assertion about no material incidents is not externally verifiable, and no domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Let me analyze this paragraph.

The paragraph states: no material cybersecurity incidents in past two years, no material costs, cannot guarantee future safety, cross-reference to Item 1A.

Category: This is primarily a materiality assessment - "does not believe that it has experienced any material cybersecurity incidents" and "nor any material costs related to immaterial cyber incidents." This is a backward-looking assessment per Rule 5 → Strategy Integration.

The "cannot provide assurance" is generic speculation (every 10-K says this) → NOT SI. The cross-reference to Item 1A → N/O. But the primary content is the materiality assessment.

The language here is entirely generic—"no material cybersecurity incidents" and "past two years" lack any firm-specific details, domain adaptation, or external verification. It's boilerplate language that could appear in any company's filing, so this falls into Level 1 - Generic Boilerplate.


content_category: Management Role

fact: Senior management (CEO and CFO) explicitly lack direct cybersecurity expertise or certifications

specificity_confidence: medium

reasoning: The paragraph primarily answers how management is organized to handle cybersecurity — CEO and CFO are responsible, they lack certifications, and they compensate by consulting a third-party IT expert. While reporting to the Audit Committee and Board is mentioned, the dominant content is management's responsibilities and qualifications (or lack thereof), making this MR per Rule 1. The explicit admission that management lacks cybersecurity certifications is a firm-specific distinguishing fact (most companies would not disclose this), elevating specificity to Level 3.

thinking:
Let me analyze this paragraph.

Category: This describes management's role (CEO, CFO) in assessing/managing cybersecurity risk and reporting to the Audit Committee/Board. It's about who is responsible and their qualifications. The governance chain (management → Audit Committee → Board) is present, but the primary focus is on management's responsibilities and qualifications (or lack thereof). Per Rule 1, this becomes MR when management's organizational role is the primary content. The paragraph focuses on CEO/CFO responsibilities and their qualifications - this is MR.

Wait - it also describes the reporting chain to Audit Committee and Board. But the bulk is about management's role and qualifications. I'd say MR.

Now looking at specificity - most of what's mentioned is generic (CEO, CFO, Audit Committee roles that every company has), but there's one concrete admission here: management doesn't have direct cybersecurity certifications. That's the firm-specific detail that stands out. Level 3.


reasoning: The paragraph opens with a materiality assessment ('have not...materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition'), which is the SEC Item 106(b)(2) backward- and forward-looking assessment → SI per Rule 5. The trailing clause about Board oversight is secondary. Specificity is Level 1: the materiality statement is a negative self-assertion (not verifiable), 'Board' is generic, and no domain terms pass the ERM test.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. "We have not identified risks from known cybersecurity threats...that have materially affected or are reasonably likely to materially affect us" - This is a materiality assessment → SI per Rule 5.
2. "Board considers cybersecurity risks as part of its risk oversight function of cybersecurity and other information technology risks" - This is about board oversight → BG.

The first part is a clear SI materiality statement (both backward and forward-looking). The second part is BG. Which dominates? The materiality assessment is the first and larger clause. But they seem roughly equal. The materiality statement is the more substantive claim.

Actually, looking more carefully, this seems like a poorly formatted paragraph that combines an SI statement with a BG transition. The SI statement is the main substantive content. The BG part is quite generic, so I'll go with SI as the primary category since the materiality assessment is the central claim. The materiality statement "have not materially affected or are reasonably likely to materially affect" is a negative self-assertion - per the rules, this is NOT externally verifiable, and there are no domain terms that pass the ERM test or firm-specific facts beyond generic "Board," which makes this Generic Boilerplate - Level 1.


reasoning: The paragraph's central claim is a backward-looking materiality assessment — 'has not experienced any unauthorized access resulting from cybersecurity incidents with a materially adverse effect on our business, operations, or financial condition' — which is a negative assertion about business impact, mapping to SI per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present; the negative self-assertion is not externally verifiable, and the cross-reference to Item 1A is filler.

thinking:
Let me analyze this paragraph.

Content: States they maintain strong cybersecurity posture, haven't experienced material incidents, and cross-references Risk Factors.

Category: The key statement is "has not experienced any unauthorized access resulting from cybersecurity incidents with a materially adverse effect on our business, operations, or financial condition" - this is a materiality assessment (negative assertion). Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI.

Specificity: The negative assertion about no material incidents is a self-reported claim about absence - NOT externally verifiable. The cross-reference to Item 1A is N/O content. No domain terms, no firm-specific facts, no verifiable claims.

So this lands at Level 1 - it's a generic materiality statement without any specific incident details or verifiable information.


reasoning: This is a governance-chain paragraph describing the Board's oversight responsibility and identifying CFO/CEO as management responsible for cybersecurity — per Rule 1, this defaults to Board Governance. CEO and CFO are generic roles present at every company (not firm-specific), no domain terminology passes the ERM test, and the date reference 'subsequent to June 30, 2024' is a reporting-period anchor rather than a verifiable cybersecurity fact, leaving this at Level 1.

thinking:
This paragraph appears truncated but let me classify what's present.

It describes board oversight and management roles (CFO, CEO) responsible for cybersecurity. The primary question answered is about oversight structure - board oversight plus who in management is responsible.

This is a governance-chain paragraph. Per Rule 1, it defaults to BG when describing oversight structure. But it also names specific management roles. The board oversight is brief, and the management roles (CFO, CEO) are mentioned with their responsibilities. It's a mix but the oversight structure framing makes it BG.

Actually, re-reading: "Board of Directors is responsible for oversight" + "CFO and CEO are the members of management responsible for managing and assessing" - this is a governance chain paragraph describing oversight structure → BG.

The roles mentioned are standard across companies, and the date reference to June 30, 2024 is just a reporting period marker without any firm-specific details or domain-specific terminology. This reads as generic boilerplate language.


fact: risk-based due diligence of service providers' information security programs

fact: contractual requirements for security controls on third parties with access to IT systems

reasoning: The entire paragraph is about how Cheniere manages third-party service provider cybersecurity risk — due diligence, contractual security requirements, data use restrictions, and incident notification obligations — making TP the clear category. The paragraph uses domain terms like 'information security programs' and 'risk-based due diligence' in a security context, and describes specific contractual mechanisms (restricting data use, requiring incident notification), but lacks firm-specific facts (no named roles, committees, or verifiable claims), keeping it at Level 2.

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


reasoning: The paragraph's central claim is a backward-looking materiality assessment ('have not encountered cybersecurity challenges that have materially impaired our operations or financial standing'), which is SI per Rule 5. The remaining content is hypothetical future impact language ('if we were to experience') and a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims are present — 'December 31, 2024' is a reporting period anchor, and the negative incident assertion is not externally verifiable.

thinking:
Let me analyze this paragraph.

Content: States no material incidents during the year, forward-looking monitoring statement, hypothetical future incident language, and a cross-reference.

Category: The key statement is "have not encountered cybersecurity challenges that have materially impaired our operations or financial standing" - this is a backward-looking materiality assessment → SI per Rule 5. The rest is speculation ("could have") and cross-reference which are N/O, but the materiality assessment is the substantive claim.

Specificity: "have not encountered cybersecurity challenges that have materially impaired our operations or financial standing" - this is a negative self-assertion, not externally verifiable.

The reporting date itself doesn't constitute a cybersecurity fact, and there are no domain-specific terms or company-particular details here → Level 1.


reasoning: The paragraph opens with both a backward-looking and forward-looking materiality assessment ('have not previously materially affected us' and 'not reasonably likely to materially affect'), making it Strategy Integration under Rule 5. The remainder is generic risk speculation and a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims elevate specificity above Level 1.

thinking: Strategy Integration - materiality assessment present.


fact: SOC reports of providers

fact: complementary controls (specific to SOC report assurance framework)

reasoning: The central topic is how the company oversees third-party provider cybersecurity—security assessments before engagement, ongoing monitoring, and SOC report reviews—making TP the primary category. The trailing materiality sentence touches SI but is minor relative to the TP content. 'SOC reports' and 'complementary controls' demonstrate domain knowledge beyond generic ERM language, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Let me analyze this paragraph.

Content: Third-party risk management processes, SOC reports, monitoring, and a materiality statement.

Category: The central topic is third-party risk management. The last sentence is a materiality assessment (SI), but the bulk is about TP. TP wins by text volume.

Wait, let me re-read. The paragraph is primarily about third-party oversight processes. The last sentence about materiality is a minor addition. Central topic = TP.

Specific facts:
- "SOC reports" - domain term (SOC 2/SOC reports pass ERM test)

- "complementary controls" is a specific SOC report terminology, showing domain expertise
- The materiality statement at the end touches on SI criteria but isn't the main focus

This lands at Level 2 — domain-specific language without firm-specific facts or verifiable claims.


fact: threat intelligence feeds

fact: vulnerability management

reasoning: The paragraph describes what the cybersecurity program does — incident response planning, monitoring, vulnerability management, and training — squarely answering the RMP question. Domain terms 'threat intelligence feeds' and 'vulnerability management' pass the ERM test (non-security professionals wouldn't naturally use these), elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Describes cyber crisis response plan, incident response team activities (monitoring threat intelligence feeds, vulnerability management, incident response), training/simulations/drills.

Category: RMP - describes what the cybersecurity program does.

Specific facts:
- "cyber crisis response plan" - could be firm-specific named program? It's somewhat generic but has a specific name
- "threat intelligence feeds" - domain term (passes ERM test)
- "vulnerability management" - domain term (passes ERM test)
- "incident response team" - this is generic
- "simulations and drills" - generic

-
The domain-specific language here is limited to threat intelligence feeds and vulnerability management. There aren't any firm-specific facts that meet the threshold, and "cyber crisis response plan" is too generic despite having a name. No named executives, committees, or verifiable details push this beyond domain-adapted specificity.


reasoning: The paragraph addresses both third parties hired to assist the company's cybersecurity program and requirements imposed on those providers (certification of security capabilities, compliance with laws, breach reporting obligations); the vendor-requirement language is the most detailed portion, making TP the central topic per Rule 3. No domain-specific terminology passes the ERM test—'risk assessment,' 'security measures,' 'monitor and test safeguards' are generic enterprise risk language—and no firm-specific or verifiable facts are present, yielding Level 1.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party service providers in two ways: (1) third parties hired to help with risk assessment/cybersecurity (consultants helping design, implement, monitor, test), and (2) requirements imposed on third-party service providers (certification, security measures, breach reporting).

Category: This is a mix of RMP (third parties helping the company) and TP (requirements imposed on vendors). The first two sentences describe consultants hired to serve the company → RMP per Rule 3. The last sentence describes requirements imposed ON third-party service providers → TP. The last sentence is substantial and specifically about vendor oversight requirements.

Looking at the balance here, the vendor requirements section is quite detailed—they need to certify their abilities, maintain security measures, comply with laws, and report breaches. That's the dominant focus, so I'm leaning toward categorizing this as Third-Party Risk overall, since the requirements imposed on vendors form the core of what the paragraph is really addressing.

As for specificity, I'm not seeing any domain-specific terminology that would meet the ERM threshold. "Risk assessment," "security measures," and "monitor and test safeguards" are all fairly generic concepts. There are no firm-specific facts or verifiable claims here either, so this lands at Level 1.


fact: CISO role oversees information security program

fact: Over 30 years of experience in cybersecurity

type: quantified

fact: Served as Security Officer in the United States Navy

fact: CISO at Amgen

fact: CISO at Warner Bros

fact: Cybersecurity roles at KPMG

fact: Cybersecurity roles at Forrester

reasoning: The paragraph describes the CISO's responsibilities, qualifications, and career history — classic MR content about who is responsible and what qualifies them. Specificity is Level 4 due to 'over 30 years of experience' (verifiable lower bound) and multiple named prior employers (Amgen, Warner Bros, KPMG, Forrester, US Navy) that are independently verifiable career claims.

thinking:
MR - about the CISO's role, responsibilities, and qualifications.

Specific facts: CISO (named_role), 30 years experience (quantified), United States Navy (named_firm), Amgen (named_firm), Warner Bros (named_firm), KPMG (named_firm), Forrester (named_firm).

"over 30 years" is a lower bound → verifiable.


reasoning: The paragraph states a backward-looking materiality conclusion ('did not identify any cybersecurity threats that have materially affected or are reasonably likely to materially affect') which is the SEC Item 106(b)(2) assessment, making it Strategy Integration. No domain terms, firm-specific facts, or verifiable claims are present — the negative self-assertion about no material incidents is not externally verifiable, the 'In 2024' is a reporting period anchor, and the remainder is generic risk disclaimer and cross-reference.

thinking: Strategy Integration - materiality assessment statement.


fact: Mr. Dennis named as cybersecurity-relevant individual

fact: Director of Information Technology title

fact: Founder of a data privacy consulting company

fact: Served since June 2019

fact: Over 20 years of experience in data management

fact: System alerts of potential malicious cyber activity

fact: Real-time dashboards that monitor and assess systems

fact: Communications with service providers regarding new attack vectors and vulnerabilities

reasoning: The paragraph introduces Mr. Dennis and his qualifications but the bulk of content describes cybersecurity program processes (system alerts, dashboards, reporting cadences, service provider communications), so per the person-removal test substantive program description remains → RMP. Specificity reaches Level 4 via 'over 20 years of experience' (verifiable lower bound) and 'since June 2019' (specific verifiable date), with firm-specific facts (named individual, founding a consulting company) and domain terms (attack vectors, malicious cyber activity, real-time dashboards).

thinking:
Let me analyze this paragraph.

Category: This describes Mr. Dennis's role, qualifications, and what processes he uses. The person-removal test: remove Mr. Dennis, his title, his qualifications, his team. What remains? Processes for monitoring, detection, mitigation - system alerts, real-time dashboards, status reports, communications with service providers. That's substantive program description. But the paragraph is structured around Mr. Dennis as the subject. Let me weigh: the paragraph starts with his role and qualifications (MR), then describes processes (RMP). The processes are described in detail - system alerts, dashboards, reporting cadences, service provider communications.

The processes themselves are substantive enough that removing Mr. Dennis still leaves meaningful program content, so RMP seems stronger. But looking more carefully, a lot of real estate goes to Mr. Dennis specifically - his title, his founding a consulting company, his 20 years of experience, his team, his reporting line to the Audit Committee. When I re-read the full paragraph, it's roughly split between Mr. Dennis details in the first two sentences and process descriptions in the last three. The processes are presented with Mr. Dennis as the grammatical subject, but the actual content is about what the program does. Rule 2 suggests that when a named officer is the subject but the content describes program functions, it leans RMP - though Mr. Dennis is a Director, not a VP or above, so that distinction matters here. I need to keep reading to see if there's more context about how to classify this. The specificity assessment comes down to verifiable details—"over 20 years of experience" gives me a concrete lower bound, and "since June 2019" is a specific date I could cross-check against employment records, both pointing to Level 4. Mr. Dennis as a named individual in a cybersecurity role pushes that to Level 3, while the generic reporting cadences don't add firm-specific weight.


reasoning: The paragraph states a conclusion that cybersecurity incidents have not materially affected the company's business strategy, results of operations, or financial condition — this is a backward-looking materiality assessment triggering SI under Rule 5. The second sentence is a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims are present, so specificity remains Level 1.

thinking: Materiality assessment + cross-reference.


fact: CGNC (named board-level committee with cybersecurity oversight role)

reasoning: The paragraph describes the governance chain from a named committee (CGNC) down through senior management and business units, focusing on oversight structure and reporting flows (including SEC incident report determination), which defaults to Board Governance under Rule 1. The CGNC is a named, non-generic committee specific to this company's governance structure, elevating specificity to Firm-Specific.

thinking:
Classify this paragraph.

Content: Describes oversight structure - CGNC committee oversight, senior management responsibility for day-to-day operations, business unit reporting requirements, and SEC filing determination. This is about how management is organized to handle cybersecurity - reporting lines, responsibilities.

But wait - it mentions CGNC (a committee) oversight and then describes management responsibilities and reporting flows. The governance chain (Board → Committee → Management) context here is about oversight structure flowing down. The CGNC seems like a board-level committee. The paragraph describes how information flows up from business units to senior management to SEC determination.

This feels like BG - it's describing the oversight structure and information flow.

The core issue is whether this leans toward management responsibilities or the governance oversight chain. The paragraph emphasizes the reporting structure and escalation path to SEC determination, which points to BG classification. CGNC is a named committee suggesting board-level governance, while the management responsibilities are secondary to the overall oversight framework being described. I'll classify this as BG.

Now I'm determining the specificity level for CGNC. It appears to be a firm-specific committee abbreviation—likely standing for something like "Corporate Governance and Nominating Committee"—and its particular role in cybersecurity oversight makes it Level 3 firm-specific rather than a generic committee reference.


fact: service provider oversight committee

reasoning: The entire paragraph is centrally about oversight of third-party service providers—selection, due diligence, contracting, monitoring—making Third-Party Risk the clear category. The named 'service provider oversight committee' is a firm-specific organizational detail that elevates specificity to Level 3, though the rest of the paragraph uses generic process language (due diligence, questionnaires, onsite visits) that any ERM professional would write.

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

Specific facts:
- "service provider oversight committee" - named committee (firm-specific)
- "questionnaires, meetings and onsite visits" - security assessment methods

The committee is a named non-generic committee → firm-specific. The assessment methods (questionnaires, meetings, onsite visits) are general process descriptions, not really domain terms.

Category: Third-Party Risk - the entire paragraph is about managing third-party service providers.

Specificity: The "service provider oversight committee" is a named committee → Level 3.


content_category: Incident Disclosure

fact: January 2021 - date when company became aware of improper access

fact: Information technology systems hosted by a third-party cloud provider were improperly accessed

fact: Source code and credentials used to access IT systems were compromised

fact: Received a ransom/extortion threat to publicly release materials unless payment was made

reasoning: The paragraph describes a real cybersecurity incident — the January 2021 unauthorized access to cloud-hosted systems, source code compromise, and extortion demand — making it Incident Disclosure. The trailing materiality language is subordinate to the incident narrative (Rule 4). The specific date 'January 2021' is an externally verifiable fact (this was a widely reported Ubiquiti breach), elevating specificity to Level 4.

thinking:
Incident disclosure with specifics about the January 2021 breach, plus a materiality assessment at the end.

The paragraph describes a real incident (January 2021 unauthorized access) - that's ID. The last sentence has a materiality assessment but the dominant frame is the incident itself.

Specific facts: "January 2021" is a specific date, "third-party cloud provider" is generic, "source code" compromised, ransom demand. The date is verifiable.


fact: penetration testing

fact: ISAT (named internal team)

reasoning: Per Rule 3, third parties hired to serve the company (assessors, pen testers) → RMP. The named internal team 'ISAT' is a firm-specific fact elevating specificity to Level 3, with 'penetration testing' as a supporting domain term.

thinking:
Classify this paragraph.

The paragraph describes engaging third-party consultants to assist with cybersecurity programs - risk assessments and penetration testing. These are third parties hired to serve the company (assessors, pen testers) → RMP per Rule 3.

Specific facts:
- "penetration testing" → domain_term (L2)
- "ISAT" → named_team (L3, firm-specific team name)

Specificity: Firm-Specific (L3)


reasoning: The paragraph states a materiality assessment conclusion ('do not believe... have had, or are reasonably likely to have, a material adverse effect') which is the SEC Item 106(b)(2) language, making it Strategy Integration per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present — the date is a reporting-period anchor, the negative materiality assertion is not externally verifiable, and the remaining content is generic hedging and a cross-reference to Item 1A.

thinking:
Let me analyze this paragraph.

Content: This is a materiality assessment statement - "we do not believe that any risks from cybersecurity threats... have had, or are reasonably likely to have, a material adverse effect." This is the classic SEC Item 106(b)(2) language. Then hedging language and a cross-reference to Item 1A.

Category: Strategy Integration per Rule 5 - backward-looking and forward-looking materiality assessment.

Specificity: "As of February 27, 2025" is a reporting date, not a cybersecurity fact. "We do not believe... have had... a material adverse effect" - this is a negative self-assertion, not externally verifiable.

The cross-reference to Item 1A adds nothing substantive, and the phrase about past cybersecurity incidents is just another negative assertion without verifiable content. There's no domain-specific language, firm-specific facts, or concrete claims here—it's all standard boilerplate materiality language. This clearly falls into Level 1.


reasoning: The paragraph states the company acknowledges the need for cybersecurity measures to protect information systems and data confidentiality/integrity/accessibility, which is a minimal description of program purpose (→ RMP). However, it contains no domain-specific terminology that passes the ERM test — 'confidentiality, integrity, and accessibility of our data' and 'cybersecurity measures' are generic enough for any business professional to write — yielding Level 1.

thinking:
Classify this paragraph.

This is generic language about cybersecurity importance. No specific processes, roles, or facts.

Category: Risk Management Process - but it's really just stating they acknowledge the need for cybersecurity measures. It's so generic it could be N/O, but it does reference "cybersecurity measures to secure our information systems" and "confidentiality, integrity, and accessibility of our data."

Actually, this is describing what the program aims to do at the highest level - it's a preamble. It says they acknowledge the need for cybersecurity measures. This is essentially an introductory statement. It doesn't answer any of the six questions substantively.

The mention of "confidentiality, integrity, and accessibility" does invoke the CIA triad, which is domain-specific terminology, but it's used so superficially here that it barely qualifies as a substantive disclosure. The paragraph really just amounts to acknowledging the need for cybersecurity without providing any meaningful detail about actual practices or controls. I'm reconsidering whether this even qualifies as RMP or should be N/O instead—it just acknowledges the need for cybersecurity without describing any actual process or measure, which might trigger Rule 6's threshold for "no substantive disclosure." For a SPAC or company with no real operations, that would push it to N/O. Now I'm looking at DSwiss Inc to see if there's a similar pattern.


fact: IT Committee regularly meets to identify improvements, assess security layers, and evaluate new technologies

reasoning: The paragraph describes program activities (identifying improvements, assessing security layers, evaluating technologies, engaging experts to analyze infrastructure) — applying the person-removal test, substantive program description remains, so RMP. The named 'IT Committee' is a firm-specific management-level committee elevating specificity to Level 3, though the rest is generic process language.

thinking:
Classify this paragraph.

Content: IT Committee meets regularly to identify improvements, assess security layers, evaluate new technologies. They also engage cybersecurity experts to analyze policies/procedures/infrastructure.

Category: This describes what the cybersecurity program does - risk assessment, evaluation of technologies, engaging experts. The IT Committee is mentioned but in context of program activities. Per Rule 2, remove person-specific content - substantive program description remains. → RMP.

Specific facts:
- "IT Committee" - named committee? It's a management-level committee. This is firm-specific.
- "cybersecurity experts" - unnamed, not specific.

- The rest is generic process description.

"IT Committee" is a named, non-generic committee, so it qualifies as firm-specific. This pushes the overall classification to Level 3 (Firm-Specific).


reasoning: The paragraph opens with a backward-looking materiality conclusion ('have not identified any cybersecurity incidents or threats that have materially affected us') and a forward-looking SEC 106(b)(2) statement ('reasonably likely to materially affect us'), both triggering SI under Rule 5. The remainder is generic speculation ('could have a material adverse effect') and a cross-reference to Risk Factors, neither of which elevates specificity. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: Materiality assessment paragraph.


reasoning: This paragraph is a cross-reference pointing to Item 1A for materiality discussion, making it N/O per Rule 5 (cross-references are not assessments). No substantive cybersecurity content is disclosed here, keeping specificity at Level 1.

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


fact: cybersecurity audits of third parties

reasoning: The paragraph centrally addresses how third-party cybersecurity risks are managed—vendor contractual requirements, supply chain oversight, and cybersecurity audits—making TP the clear category. Specificity is borderline; 'cybersecurity audits' passes the ERM test as a domain-specific practice, but the rest is fairly generic process description.

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


reasoning: The paragraph primarily answers how third-party cyber risks are managed: it describes engaging service providers and then imposing security certification and breach-reporting requirements on them, making vendor oversight the central topic per Rule 3. Specificity is Level 1 because all language ('risk assessment processes,' 'cybersecurity policies and procedures,' 'appropriate security measures,' 'promptly report any suspected breach') is generic enough for any ERM professional to write, with no domain terms, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

Content: Discusses third-party service providers in two capacities: (1) consultants helping design/implement cybersecurity program, and (2) requirements imposed on third-party providers regarding security measures.

Category: The paragraph has two parts - third parties helping with risk assessment (RMP per Rule 3) and requirements imposed on vendors (TP per Rule 3). The central topic seems split. The first half is about third parties serving the company (assessors → RMP). The second half imposes requirements ON vendors (→ TP). Looking at text balance, it's roughly even. The second sentence is about third parties assisting (RMP), and the third sentence is about requirements on vendors (TP).

Now I'm reconsidering the classification. The paragraph covers both how they engage consultants for risk assessment and the requirements they impose on those same vendors. Since the requirements imposed on vendors are a significant and central part of the discussion, this leans toward Third-Party Risk management rather than just Risk Management Program. ants hired to help with the company's risk assessment and security program. The certification and security requirements they must meet are substantial enough that Third-Party Risk Management is the better fit—this paragraph is fundamentally about how the company manages and controls its third-party service providers, not just what those providers do for the program.

Now I'm looking at the specificity of the language used. The paragraph mentions "consultants, or other third parties," "risk assessment processes," "cybersecurity policies and procedures," and "monitor and test our safeguards"—all fairly general terms. The contractual requirement about certifying the ability to implement security measures is more concrete, though still somewhat vague.


reasoning: The paragraph primarily answers how management is organized to handle cybersecurity — CEO oversees day-to-day operations with IT personnel, executive management updates the Board. While it touches BG (Board receiving reports) and SI (no material incidents to date), the CEO's responsibilities and reporting structure dominate the text. Specificity is Level 1: CEO is a generic role present at every company, 'incident response plan' is on the commonly-confused list, and the negative materiality assertion is not externally verifiable. No domain terms pass the ERM test.

thinking:
Let me analyze this paragraph.

Content: CEO oversees cybersecurity with IT personnel, executive management updates Board on incidents, Board receives periodic reports, CEO has incident response plan, no material incidents to date.

Category: This touches both MR and BG. The paragraph starts with CEO's role, then discusses how info flows to the Board, then back to CEO's incident response plan, then a materiality statement. The primary question answered is about management's role and how they organize cybersecurity oversight. But there's also Board reporting. Let me weigh: CEO responsibilities (MR), Board updates (BG), incident response plan (RMP), materiality statement (SI).

The CEO and management structure is the central focus throughout—they're overseeing cybersecurity, updating the Board, and maintaining the incident response plan. Even though Board reporting is mentioned, the paragraph primarily describes management's organizational role and responsibilities, so this leans toward MR.

Looking at the specificity here, I'm seeing mostly generic language: "CEO" is a standard role every company has, "incident response plan" is boilerplate, and the prevention/mitigation/detection/remediation framework is standard industry terminology. The closing statement about not encountering material incidents is a negative self-assertion without verifiable backing. There's no domain-specific language, no firm-specific facts, and nothing that would pass the ERM test. This is Level 1—generic boilerplate.


reasoning: This paragraph is introductory framing explaining why cybersecurity matters to the company. It does not answer any of the six substantive questions — no program activities, governance structure, management roles, or materiality assessment are described. The 'could materially adversely affect' language is speculative per Rule 5 (not an actual assessment), and no cybersecurity measures or processes are disclosed (Rule 6). N/O paragraphs always receive Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Discusses cybersecurity as critical to business, mentions threat types, notes supply chain risk, and states that incidents "could materially adversely affect" business. This is general framing about why cybersecurity matters.

Category: The "could materially adversely affect" language is speculative (Rule 5 - "Could have a material adverse effect" → NOT SI). No actual assessment of whether cybersecurity HAS affected or IS REASONABLY LIKELY to affect. This is general introductory framing. It mentions threats but doesn't describe program activities. It's mostly contextual framing - could be N/O or RMP. But it does mention specific threat types (ransomware, denial-of-service) and frames why cybersecurity matters.

The paragraph lacks any description of actual processes, governance structures, or management activities—it's purely introductory context. While it references specific threats like ransomware and supply chain risks, the speculative "could materially adversely affect" language disqualifies it from Strategy Integration per Rule 5. This reads as a preamble rather than substantive disclosure about the company's cybersecurity program. This is just introductory framing without any actual cybersecurity measures or processes described—just threat context and business justification. That makes it N/O, which means it gets tagged as Generic Boilerplate.


fact: CISO role

fact: CDO (Chief Digital Officer) role

fact: CDO has more than 20 years of executive IT leadership experience

fact: CDO joined MPC in 2021

fact: Previously employed by GE and its subsidiary companies

fact: Over 20 years at GE

fact: Named Senior Vice President and CIO of Services for GE in 2017

fact: Named VP and CIO of GE Healthcare

fact: GE Healthcare

fact: Holds a Bachelor's degree in Business Administration, Management and Information Systems

reasoning: The paragraph details the CDO's qualifications, career history, and reporting relationship with the CISO — squarely Management Role per the person-removal test (nothing substantive remains without the person-specific content). Multiple verifiable facts drive Level 4: 'more than 20 years' experience, joined MPC in 2021, prior employment at GE with named titles (SVP & CIO of Services in 2017, VP & CIO of GE Healthcare), and a named degree.

thinking:
Classify this paragraph.

This is about the CDO's qualifications, experience, career history, and reporting relationship with the CISO. This is clearly Management Role.

Specific facts:
- CISO (named role, firm-specific)
- CDO (named role, firm-specific)
- "more than 20 years of executive IT leadership experience" - quantified, verifiable lower bound
- "joined MPC in 2021" - specific date, verifiable
- GE and subsidiary companies - named firm, verifiable

- Over two decades at GE across multiple senior IT leadership positions with specific dates and named firms, plus a relevant degree in business and information systems. This is definitely Level 4.


fact: Clarium Managed Services, LLC conducted a Cybersecurity Assessment

fact: Assessment conducted in 2022

fact: Score of 4.8 on a scale of 0 to 5

fact: Cybersecurity Risk Posture assessment

reasoning: The paragraph contains a materiality conclusion ('have not materially affected… business strategy, results of operations or financial condition') which is a clear SI assessment per Rule 5, and the Clarium assessment score serves as evidence supporting that conclusion. Specificity is Level 4 due to the named third-party firm (Clarium Managed Services, LLC), a specific year (2022), and a quantified assessment score (4.8/5), all externally verifiable.

thinking:
Let me analyze this paragraph.

Content: Mentions a specific third-party assessment by Clarium in 2022, a score of 4.8/5, no material incidents in last three years, materiality assessment statement, and cross-reference to Item 1A.

Category: This has multiple elements. The Clarium assessment is about risk management process (third-party assessor hired to serve the company → RMP per Rule 3). The "has not experienced any material cybersecurity incidents" and "not materially affected" statements are SI per Rule 5. The cross-reference is N/O.

The materiality assessment statements are prominent.

The paragraph structure is working against a clear categorization—the Clarium assessment opens strong with two sentences, followed by the no-material-incidents claim, then the materiality conclusion, then a cross-reference. The materiality assessment is the concluding point and appears to anchor the Clarium score, which tips this toward SI, though it's genuinely close.

Looking at the specificity markers: Clarium Managed Services is a named, verifiable firm with a specific 2022 assessment date and a quantified score of 4.8 out of 5. The "last three fiscal years" framing is softer and harder to verify. The named firm and precise score push this to Level 4.


fact: ransomware attack

fact: ransomware attack occurred on April 28, 2023

fact: network returned to full operation on May 1, 2023

reasoning: The paragraph describes an actual cybersecurity incident — a ransomware attack — with timeline, scope, and remediation outcome, making it Incident Disclosure. Specificity is Quantified-Verifiable due to two specific, externally verifiable dates (April 28, 2023 attack and May 1, 2023 recovery).

thinking: Incident disclosure with specific dates and named attack type.


reasoning: The first sentence states a backward-looking materiality conclusion ('No unauthorized access...occurred...that has had a material adverse effect on our business, operations, or consolidated financial condition'), which is an SI assessment per Rule 5. The remaining sentences are generic speculation ('could have') and a cross-reference. No domain terms passing the ERM test, no firm-specific facts, and the negative assertion is not externally verifiable, so specificity remains Level 1.

thinking:
Let me analyze this paragraph.

The paragraph has three parts:
1. A negative assertion about no material unauthorized access from cybersecurity incidents
2. Hypothetical "could have" language about potential material adverse effects
3. A cross-reference to Item 1A Risk Factors

The first sentence is a backward-looking materiality assessment: "No unauthorized access... occurred... that has had a material adverse effect" → This is SI per Rule 5.

The second sentence is speculative "could have a material adverse effect" → NOT SI per Rule 5.

The third sentence is a cross-reference → N/O.

The dominant content is the materiality assessment in the first sentence → Strategy Integration.

The negative assertion lacks external verification and contains no domain-specific terminology or firm-specific facts—it's generic boilerplate at Level 1.


reasoning: The paragraph is centrally about overseeing cybersecurity risks from third-party service providers—onboarding assessments, ongoing monitoring, contract renewal reviews—making Third-Party Risk the clear category. Despite its length, the language stays at a level any ERM professional could write: 'risk-based approach,' 'cybersecurity assessments,' 'design and operational effectiveness of controls,' and 'information security posture' are all standard vendor risk management vocabulary that don't demonstrate specialized cybersecurity domain knowledge.

thinking:
Classify this paragraph about BankUnited's third-party risk management.

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

Specificity: Let me scan for facts.
- "information security division" - a named team? It's a generic division name, not particularly firm-specific
- "third-party risk management unit" - similarly generic
- "risk-based approach" - generic
- "cybersecurity assessments of third-party service providers at the time of onboarding, as part of regular ongoing monitoring, at the time of contract renewal, and upon detection of any increase in risk profile" - this describes process but uses fairly generic language

- "design and operational effectiveness of information technology and security related controls" - audit/controls language that could apply to any framework
- "information security posture" - this is a domain term

Looking at whether this meets the ERM Level 2 threshold, the language here is mostly generic enough that any ERM professional could write it. The assessments and controls language are standard vendor oversight terminology, though "information security posture" does lean slightly more technical. Overall, this reads as fairly boilerplate third-party risk management without much firm-specific detail.

The organizational units mentioned—"information security division" and "third-party risk management unit"—are generic department names, not named roles or firm-specific structures that would elevate this. The processes themselves (onboarding, ongoing monitoring, contract reviews) are standard vendor management practices.

I'm settling on Level 1 here. The language is process-focused but doesn't demonstrate expertise beyond what a general ERM professional would produce.


fact: BNY Mellon named as the entity with a third-party governance framework

reasoning: The paragraph is centrally about how BNY Mellon manages cybersecurity risks posed by third-party service providers—vendor oversight, risk evaluation, and contractual obligations—making Third-Party Risk the clear category. BNY Mellon is a named firm, elevating specificity to Level 3, but the actual processes described (risk evaluation, contractual obligations, additional controls) are generic and lack domain-specific terminology.

thinking:
Classify this paragraph.

This is about BNY Mellon's third-party governance framework for managing cybersecurity risks from third-party service providers. The central topic is third-party risk management.

Category: Third-Party Risk - it's centrally about how third-party cyber risks are managed (vendor oversight, contractual requirements).

Specific facts:
- "BNY Mellon" is named but it's the trustee, not really a named third-party firm in the verification sense... actually BNY Mellon is named as the entity managing the program. This is a named firm.

- The language around "third-party governance framework" and "mandatory contractual obligations" is quite generic, and the paragraph doesn't use domain-specific cybersecurity terminology that would elevate it beyond standard vendor oversight language. BNY Mellon being explicitly named pushes this to firm-specific level though.

Specificity: Firm-Specific due to BNY Mellon being named.


reasoning: The paragraph states a conclusion that no material cybersecurity incident occurred during the fiscal year (negative assertion → SI per Rule 5), then cross-references Item 1A for further risk discussion. Specificity is Level 1: the negative self-assertion ('did not experience a material cybersecurity incident') is explicitly not externally verifiable, the date is a reporting period marker, and the cross-reference adds no domain or firm-specific content.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. "We did not experience a material cybersecurity incident during the fiscal year ended December 27, 2024" - This is a negative assertion about no material incidents. Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI.
2. The rest is a cross-reference to Item 1A risk factors.

The primary content is the materiality assessment (no material incidents) plus a cross-reference. The materiality statement is an SI assessment per Rule 5. The cross-reference portion points elsewhere.

Since the paragraph STATES A CONCLUSION about whether cybersecurity has affected business outcomes (negative assertion = SI per Rule 5), this is Strategy Integration.

But looking at specificity, the negative assertion itself isn't externally verifiable—it's just a self-reported claim with no domain-specific details, firm-specific facts, or verifiable evidence. The only concrete element is the reporting period date. This reads as generic boilerplate rather than substantive disclosure.


fact: Energy Transfer's Chief Information Officer oversees IT, cybersecurity, infrastructure and IT governance

fact: CIO has more than 35 years of experience leading business technology functions

fact: Energy Transfer IT team has over 50 years of combined experience in IT

fact: 20 years dedicated to cybersecurity

fact: GICSP certification

fact: CISSP certification

fact: CEH certification

fact: USAC's IT department leads internal cybersecurity program

fact: IT leadership team has average of over 25 years of experience in IT operations

fact: Over 10 years of experience in IT security

reasoning: The paragraph is primarily about management roles, qualifications, team composition, and credentials — answering how management is organized to handle cybersecurity — making it MR. Multiple verifiable claims drive Level 4: named certifications (GICSP, CISSP, CEH) are independently verifiable via certification bodies, and specific experience thresholds (35+ years, 50+ combined years, 20 years cybersecurity) are quantified lower bounds.

thinking:
Let me analyze this paragraph.

Content: Describes Energy Transfer's CIO role, IT team experience/certifications, and USAC's IT department leadership. This is about management roles, qualifications, and team composition.

Category: Management Role - primarily about who manages cybersecurity, their qualifications, experience, and credentials.

Specific facts:
- Energy Transfer's Chief Information Officer (named role, firm-specific)
- 35 years of experience (quantified, verifiable)
- Energy Transfer IT team (named team)
- 50 years combined experience (quantified)
- 20 years dedicated to cybersecurity (quantified)

- GICSP, CISSP, and CEH certifications (verifiable credentials)
- USAC's IT department with 25 years average IT operations experience and 10 years in IT security (quantified, firm-specific)

Specificity: Level 4 - multiple verifiable claims across certifications, experience metrics, and firm-specific roles.


fact: Threat actors exfiltrated images of video meetings and computer screens

fact: Threat actors released exfiltrated information publicly after ransom demand was refused

fact: Vendor and customer information was also released publicly

reasoning: This paragraph describes a real cybersecurity incident — unauthorized access, data exfiltration, and a ransom demand — making it Incident Disclosure. The specific details about the nature of exfiltrated data (video meeting images, screen captures), the public release of data, and the ransom demand are firm-specific facts about this particular incident, but there are no named third parties, specific dates, or quantified claims that would reach Level 4.

thinking: Incident disclosure - describes what happened in an actual cybersecurity incident.


fact: October 15, 2025 — specific date incident was discovered

fact: Federal Bureau of Investigation (FBI) notified

fact: cyber incident response plan activated

fact: deployment of encryption and monitoring software by threat actor

fact: external cybersecurity experts retained

reasoning: The paragraph describes a real cybersecurity incident — unauthorized access, timeline, response actions, and investigation findings — making it clearly Incident Disclosure. The specific date (October 15, 2025) and named entity (FBI) are externally verifiable facts, elevating specificity to Quantified-Verifiable.

thinking: Incident disclosure with specific details.


reasoning: The paragraph is a forward-looking disclaimer acknowledging past incidents without specifics and cross-referencing Item 1A Risk Factors, fitting None/Other. No domain terms, firm-specific facts, or verifiable claims are present.

thinking:
Classify this paragraph.

Content: mentions past incidents vaguely, references Item 1A, forward-looking disclaimer language. No specific incident details. The cross-reference to Item 1A and speculative language ("may continue to occur") points to N/O or SI.

"cybersecurity attacks and incidents have occurred in the past" - this is a vague acknowledgment, not a specific incident disclosure. No timeline, scope, or details.

"Have not experienced any material cybersecurity incidents" would be SI, but this says incidents HAVE occurred - but without any materiality assessment. It's more of a risk disclaimer.

The cross-reference to Item 1A Risk Factors signals this is None/Other per Rule 5, and the overall structure is just a disclaimer with a cross-reference rather than substantive disclosure. There's no specific language, no firm-specific details, and no verifiable claims—it's generic boilerplate.


fact: vulnerability assessments

fact: Chief Information Security Officer (CISO)

reasoning: The paragraph describes how the Audit Committee and Board oversee cybersecurity risks, including briefing content and escalation processes, squarely answering the board oversight question → Board Governance. The mention of the CISO elevates to Firm-Specific; 'vulnerability assessments' is a domain term but the CISO sets the floor at Level 3.

thinking:
Classify this paragraph.

Category: This is about how the board/Audit Committee oversees cybersecurity. Board Governance.

Specific facts:
- Audit Committee (generic, every company has one - not firm-specific)
- "vulnerability assessments" - domain term
- CISO - firm-specific (named role)
- "quarterly presentations" - generic cadence
- "at least once each year" - generic cadence

Specificity: CISO is firm-specific → Level 3.


fact: CISO reports quarterly to the Risk and Compliance Committee

fact: Risk and Compliance Committee (non-generic board committee)

fact: Chief Legal Officer periodically presents to the Board on cybersecurity

reasoning: The paragraph describes the governance chain from CISO to Risk and Compliance Committee to Board, focusing on oversight structure and information flow — classic Board Governance. Firm-specific due to the named CISO role and the non-generic Risk and Compliance Committee.

thinking:
Governance chain paragraph: CISO → Risk and Compliance Committee → Board. Purpose is describing oversight structure and information flow.

Category: Board Governance (oversight structure, how info flows to board)

Facts:
- CISO (named role, firm-specific)
- Risk and Compliance Committee (named committee, firm-specific)
- Chief Legal Officer (generic role, not firm-specific)
- quarterly reports (generic cadence)

Specificity: Firm-Specific (Level 3) due to CISO and Risk and Compliance Committee


fact: IT Committee includes senior executives and other members of management

fact: Executive Vice President and Chief Accounting Officer (CAO)

fact: Co-Chief Operating Officer (COO)

reasoning: Despite the heading 'Management's Role Managing Risk,' the bulk of the paragraph describes how information flows to the Board—briefing frequency, briefing topics, ongoing dialogue, and Board participation in strategic decisions—making Board Governance the primary question answered. Firm-specific due to named VP+ roles (SVP of IT, EVP/CAO, Co-COO) and a named management-level committee (IT Committee), but no externally verifiable claims.

thinking:
Let me analyze this paragraph.

Category: This describes both management roles and board oversight. The heading says "Management's Role Managing Risk" but the content is heavily about how information flows to the Board, briefing frequency, and Board oversight. The IT Committee is a management-level committee, but the bulk of the paragraph describes Board briefings and Board participation in strategic decisions. This is primarily about how the board oversees cybersecurity - BG.

Wait, let me re-read. The IT Committee is mentioned first (MR), then SVP IT, EVP/CAO, and Co-COO informing the Board (BG - information flow to board).

The Board briefings are clearly the focus here, so this is Board Governance. I'm noting the specific roles mentioned - IT Committee, Senior Vice President of Information Technology, Executive Vice President and Chief Accounting Officer, and Co-Chief Operating Officer - which makes this Level 3 for firm-specificity. The annual briefing cadence is pretty soft and not really measurable, and the topics themselves are fairly generic, so that doesn't add much specificity.


reasoning: This is a cross-reference to Item 1A risk factors with no substantive cybersecurity disclosure, making it N/O. No specific facts are present beyond the generic risk factor title.


reasoning: The paragraph describes the board's delegation of cybersecurity oversight to the audit committee, directly answering how the board oversees cybersecurity — classic Board Governance. All elements are generic (board, audit committee, risk oversight function) with no domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: Board governance - describes board oversight structure, delegation to audit committee.

Specificity: No domain terms beyond generic "cybersecurity risk management program." No firm-specific facts (Audit Committee is generic, board is generic). No verifiable facts.

Level 1.


fact: NSA Cybersecurity Collaboration Center

fact: CISA Critical Partnership

fact: FBI InfraGard

fact: U.S. Coast Guard Area Maritime Security Committees and Cybersecurity Subcommittees

fact: Cyber-Hawaii

fact: Maritime Transportation System Information Sharing and Analysis Center (MTS-ISAC)

fact: Information Sharing and Analysis Center (ISAC)

reasoning: This is a list of named external cybersecurity partnerships and collaborations, which represents program activities (information sharing, threat intelligence). The named organizations (NSA Cybersecurity Collaboration Center, FBI InfraGard, MTS-ISAC, CISA Critical Partnership) are specific, externally verifiable memberships/partnerships that could be confirmed independently.

thinking: This paragraph is a list of external partnerships/organizations related to cybersecurity.


reasoning: The first sentence delivers a backward-looking materiality assessment ('have not...materially affected') and a forward-looking one ('reasonably likely to materially affect'), which per Rule 5 makes this SI. The remaining sentences are speculative risk language and a cross-reference to Item 1A. No domain terms, firm-specific facts, or verifiable claims are present—the negative materiality assertion is a self-reported claim about absence, not externally verifiable.

thinking:
Let me analyze this paragraph.

Sentence 1: "We have not identified risks from known cybersecurity threats...that have materially affected or are reasonably likely to materially affect us" → This is a backward-looking materiality assessment AND a forward-looking SEC Item 106(b)(2) assessment → SI per Rule 5.

Sentence 2: "We face certain ongoing risks from cybersecurity threats that, if realized, are reasonably likely to materially affect us" → This is speculative/conditional ("if realized") - closer to "could have a material adverse effect" speculation.

Sentence 3: Cross-reference to Item 1A → N/O per Rule 5.

The first sentence makes a clear materiality conclusion, so that's SI. The second sentence is more speculative in tone but still addresses materiality. The third is just a cross-reference. Looking at the overall content, this falls under Strategy Integration since the materiality assessment in the first sentence is what drives the substance. As for specificity, there are no domain-specific terms, no company-specific facts, and the negative assertion about not identifying risks isn't verifiable under the rules—this is generic boilerplate language.


fact: Chief Security Officer role at Deutsche Bank

fact: CISO/CSO role

fact: More than 20 years in information security

fact: Served as global CISO/CSO for three different large European financial institutions

fact: Partner position in a global strategy and consulting firm leading security work

fact: Deutsche Bank (named parent entity)

reasoning: The paragraph focuses on the CSO's qualifications, career history, and support structure — all hallmarks of Management Role (person-removal test leaves near-nothing). 'More than 20 years' is a verifiable lower bound and 'three different large European financial institutions' is a specific count, pushing specificity to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes Deutsche Bank's Chief Security Officer's qualifications and experience, plus the support structure. This is about a management role - qualifications, career history, team composition.

Category: Management Role - it's about who the person is, their qualifications, career history, and team structure.

Specific facts:
- "Chief Security Officer" - named role (firm-specific, VP+ level)
- "more than 20 years" in information security - quantified, verifiable lower bound

- Held CISO/CSO positions across three major European financial institutions and worked as a partner at a global strategy consulting firm - this reinforces the depth of experience and senior-level background, confirming the Level 4 specificity rating.


fact: Vendor Management Policy (named internal program)

fact: enhanced risk assessments for higher-risk vendors

fact: ongoing monitoring of vendors

fact: contractual controls to restrict information access levels

reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party vendors, including requirements imposed on them, making it Third-Party Risk. The named 'Vendor Management Policy' is a firm-specific program identifier that distinguishes this company's posture, elevating to Level 3.

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


reasoning: The paragraph's central substantive claim is a materiality assessment — 'we do not believe we have been materially affected by cybersecurity incidents or threats in the past, or that past incidents are reasonably likely to materially affect us' — which is a backward-looking and forward-looking conclusion about business impact, squarely triggering the SI materiality rule. No domain-specific terminology (incident classification and risk-based approach are generic ERM language), no firm-specific facts, and no verifiable claims are present, keeping specificity at Level 1.

thinking:
Let me analyze this paragraph.

The paragraph discusses: experiencing cybersecurity incidents generally, classification and tracking of incidents, a materiality assessment ("do not believe we have been materially affected"), risk-based approach mention, limitations of controls, and a cross-reference to Item 1A.

Key question: What is the primary content?

The core statement is the materiality assessment: "we do not believe we have been materially affected by cybersecurity incidents or threats in the past, or that past incidents are reasonably likely to materially affect us." This is a backward-looking and forward-looking materiality conclusion → SI per Rule 5.

The materiality assertion itself is a negative self-judgment that can't be externally verified, and the rest of the language—incident classification, risk-based approach, the cross-reference—is all generic boilerplate without firm-specific facts or verifiable claims. This is Level 1 generic disclosure.


fact: regular scanning of both internal and externally facing systems (vulnerability scanning)

fact: annual third-party penetration testing

fact: security technologies to contain and remediate malware risks

fact: active monitoring of logs and events for network perimeter and internal systems

reasoning: The paragraph describes specific cybersecurity program activities (scanning, penetration testing, malware containment, log monitoring, vendor due diligence), answering what the program does → RMP. Third-party vendor due diligence is one item among many, not the central topic. Domain terms like penetration testing, malware, network perimeter, and log monitoring pass the ERM test, but no firm-specific or verifiable facts elevate beyond Level 2.

thinking:
Classify this paragraph.

Content: describes security activities - vulnerability scanning, penetration testing, malware containment, log monitoring, vendor due diligence. This is about what the cybersecurity program does → RMP. Third-party mention is one component, not central → RMP.

Specific facts:
- "regular scanning of both internal and externally facing systems" → domain term (vulnerability scanning)
- "annual third-party penetration testing" → domain term (penetration testing)
- "security technologies intended to identify and assist in containing and remediating malware risks" → domain term (malware)

- "Active monitoring of logs and events for our network perimeter and internal systems" → domain term (log monitoring, network perimeter)

These are all domain terms that pass the ERM test with no firm-specific facts or verifiable claims. The overall specificity level is Domain-Adapted (Level 2).


reasoning: This paragraph is a cross-reference pointing to Item 1A for materiality discussion rather than making its own materiality assessment — per Rule 5, cross-references like 'risks that may materially affect us, see [elsewhere]' are N/O. No substantive cybersecurity content is disclosed here, just a pointer to another section.

thinking: Cross-reference to Item 1A with materiality language but no actual assessment here.


fact: Information Security Steering Committee (ISSC)

fact: Executives from Legal, Accounting, Internal Audit and Risk Management, Cybersecurity and Facilities departments

fact: Services agreement with Liberty for establishing the committee

reasoning: The paragraph describes a management-level committee (ISSC) — its name, departmental composition, and oversight scope — making it primarily about how management is organized (MR per Rule 1). The named committee and specific department roster are firm-specific facts that distinguish this company, driving Level 3 specificity.

thinking:
Let me analyze this paragraph.

Content: Describes a management-level committee (ISSC) with its composition and responsibilities.

Category: This is about a management-level committee - the Information Security Steering Committee. It describes membership (cross-functional executives from specific departments) and oversight responsibilities. Per Rule 1, management-level committees → MR if about structure/membership. This is about structure/membership → MR.

Specific facts:
- "Information Security Steering Committee ("ISSC")" — named committee (firm-specific)

- The committee draws from Legal, Accounting, Internal Audit and Risk Management, Cybersecurity and Facilities — these are the actual departments involved, making this firm-specific
- There's also a services agreement with Liberty mentioned as an organizational detail

The domain language around information security and data protection uses standard ERM terminology, so that doesn't push this toward firm-specific. But the named committee combined with the explicit department composition puts this clearly at Level 3 (Firm-Specific).


reasoning: The paragraph describes cybersecurity insurance coverage, which addresses how cybersecurity affects business/financial posture — a Strategy Integration topic. While it lists several coverage areas (liability, privacy, business interruption, etc.), these are standard insurance policy components that any ERM professional would recognize and do not demonstrate cybersecurity domain expertise. No firm-specific or verifiable facts are present.

thinking: Cybersecurity insurance coverage description.


reasoning: This is a cross-reference to Item 1A Risk Factors with no substantive cybersecurity disclosure, making it None/Other. No specific facts are present.


fact: confidentiality, integrity and availability (CIA triad)

fact: penetration tests

fact: threat landscape

fact: backup and recovery systems and disaster recovery of critical systems

reasoning: The paragraph describes what the cybersecurity program does: security controls, risk-based architecture, risk register, penetration testing, and backup/recovery — all program activities making it RMP. Domain terms like CIA triad and penetration testing pass the ERM test, but there are no firm-specific facts (no named roles, named tools, or verifiable claims), keeping it at Level 2.

thinking:
Let me classify this paragraph.

Category: This describes what the cybersecurity program does - security controls, risk-based approach, risk register, penetration testing, backup/recovery. This is RMP.

Specific facts:
- "penetration testing" - domain term
- "risk register" - this is somewhat domain-specific but could be ERM... actually risk registers are used broadly in ERM
- "confidentiality, integrity and availability" (CIA triad) - domain term
- "threat landscape" - domain term
- "cloud environments" - borderline
- "annual penetration tests at each of our businesses" - the "annual" and "at each of our businesses" adds some specificity

- "backup and recovery systems and disaster recovery" - general IT/business continuity terms

Now I'm testing which elements are truly domain-specific. The CIA triad and penetration tests are clearly cybersecurity concepts, while the risk register is too general for ERM classification. Most of the other terms like networks and cloud environments are standard IT vocabulary, and the firm-specific detail about conducting tests annually across all businesses doesn't really distinguish this as unique.

The mention of independent third parties conducting these tests lacks any identifying information, so there's no way to verify it. Overall, this disclosure lands at Level 2 - it uses domain-adapted language around cybersecurity fundamentals but doesn't go deeper than that.


reasoning: This is a pure cross-reference directing readers to Item 1A Risk Factors, with no substantive cybersecurity disclosure. No specific facts of any kind are present.

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


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

fact: Wireless and data networks remained operational during the incident

fact: All significant systems restored as of March 31, 2023

reasoning: The paragraph describes the operational status and restoration timeline of a real cybersecurity incident, making it Incident Disclosure. The specific date 'March 31, 2023' for system restoration and named services (DISH TV, SLING TV, Retail Wireless) are externally verifiable facts, elevating to Level 4.

thinking: Incident disclosure - describes status of systems during and after a real incident.


fact: threat modeling

fact: vulnerability testing

reasoning: The paragraph describes what the cybersecurity program does—assessments, testing, exercises, and third-party reviews feeding results to the Board—squarely answering the RMP question. Third parties are mentioned as serving the company's internal program (Rule 3 → RMP). Domain terms like 'threat modeling,' 'vulnerability testing,' and 'information security maturity assessments' pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
RMP - describes what the cybersecurity program does (assessments, testing, exercises). Third parties mentioned but as part of internal program (Rule 3 → RMP).

Specific facts: threat modeling, vulnerability testing, tabletop exercises - but tabletop exercises without cybersecurity qualifier stay L1 per rules. Wait, they're in cybersecurity context. Let me re-read: "tabletop exercises" is listed as L1 "without cybersecurity qualifier" but here it's clearly in cybersecurity context. Hmm, the rule says "tabletop exercises (without cybersecurity qualifier)" - these are in a cybersecurity section, so arguably qualified.

Tabletop exercises appear in business continuity and ERM contexts too, so they'd stay L1, but the other terms here—threat modeling, vulnerability testing, and information security maturity assessments—are distinctly security-focused and wouldn't naturally appear in a general ERM professional's vocabulary. These are domain-specific terms that signal Level 2. There are no firm-specific facts or verifiable claims to push this higher.


fact: February 23, 2023 — DISH Network experienced a network outage

fact: February 28, 2023 — further disclosed data extraction

fact: DISH Network named as affected entity

fact: incident response and business continuity plans activated

fact: notified appropriate law enforcement authorities

reasoning: The paragraph describes a real cybersecurity incident at DISH Network with specific dates (Feb 23 and Feb 28, 2023), timeline of response actions, and disclosure of data extraction — clearly Incident Disclosure. Two specific dates tied to a real, publicly reported event make this Quantified-Verifiable.

thinking: Incident disclosure with specific dates and named entities.


fact: CISO role

fact: 25 years of prior experience in information systems, cybersecurity, risk management, and infrastructure management

fact: Certified Internal Controls Auditor (CICA)

fact: Payment Card Industry Professional (PCIP)

fact: Certified Information Systems Security Professional (CISSP)

fact: Certified Information Systems Auditor (CISA)

fact: Certified in Risk and Information Systems Control (CRISC)

reasoning: The paragraph focuses entirely on the CISO's responsibilities, experience, and qualifications—applying the person-removal test leaves no substantive program description, confirming MR. Specificity is Level 4 due to multiple externally verifiable claims: 25 years of experience (specific quantity) and five named certifications (CISSP, CISA, CRISC, CICA, PCIP) each verifiable through their respective certification bodies.

thinking:
Classify this paragraph.

Category: This is about the CISO's responsibilities, qualifications, and certifications. Person-removal test: remove all person-specific content and nearly nothing remains. → MR.

Specificity: Contains multiple verifiable facts:
- 25 years of experience (quantified)
- CISSP, CISA, CRISC, CICA, PCIP certifications (verifiable)
- Master's and bachelor's degrees in Computer Information Systems and Business Administration

Level 4.


fact: threat intelligence service providers

fact: penetration testing firms

fact: managed cybersecurity service providers

reasoning: Per Rule 3, third parties hired to serve the company (assessors, pen testers, consultants) are part of the internal program → RMP. Domain terms like 'threat intelligence,' 'penetration testing,' and 'managed cybersecurity service providers' pass the ERM test, elevating specificity to Level 2, with no firm-specific or verifiable facts present.

thinking:
Classify this paragraph.

Content: describes using various service providers for cybersecurity - threat intelligence, consultants, pen testing, software providers, managed services, legal counsel. These are third parties hired to serve the company's program.

Category: Per Rule 3, "Third parties hired to serve the company (assessors, pen testers) → RMP." This is about external providers as components of the internal program. RMP.

Specificity: Domain terms present - "threat intelligence," "penetration testing," "managed cybersecurity service providers." These pass the ERM test. No firm-specific facts or verifiable claims.

This falls into Level 2 specificity.


reasoning: The paragraph centrally addresses how third-party/supplier cyber risks are managed — potential indirect impacts and contractual/procedural controls imposed on vendors — making TP the primary category. The language is entirely generic ('processes and procedures,' 'security and privacy addendums,' 'address potential deficiencies') with no domain-specific terminology, firm-specific facts, or verifiable claims.

thinking: Third-party risk management paragraph.


fact: Cybersecurity event occurred in June 2023

fact: Unauthorized third party gained access to email accounts of two employees

fact: Affected customers notified in early September 2023

fact: Approximately $25,000 in expenses related to the incident

reasoning: Though the paragraph begins with RMP/TP boilerplate about third-party oversight and incident response programs, the dominant content describes an actual cybersecurity incident — unauthorized email access in June 2023, customer notification in September 2023, and remediation — making Incident Disclosure the best fit per Rule 4 (incident frame dominant). Specificity reaches Level 4 via multiple verifiable facts: specific dates (June 2023, September 2023), a hard count (two employees), and a dollar figure (~$25,000).

thinking:
Let me analyze this paragraph carefully.

Content: This paragraph covers multiple topics - third-party relationship oversight, incident response program, and then describes an actual cybersecurity incident (unauthorized access to email accounts in June 2023, notification in September 2023, ~$25,000 in expenses).

Category: The paragraph contains a real incident disclosure with specific details (June 2023, two employee email accounts, September 2023 notification, $25,000 cost). While it starts with some RMP/TP content, the incident details are substantial and specific. The incident description with timeline, scope, and financial impact is the most distinctive content. Mixed between ID and SI per Rule 4 - the timeline/scope/response is ID, and the $25,000 cost is financial impact (SI).

The incident narrative is clearly the dominant frame here - the financial detail and remediation steps all feed into the story of what happened. Looking at the specifics: June 2023 for when the breach occurred, two employees affected, early September 2023 when they notified people, and approximately $25,000 in response costs. These concrete details make this an Incident Disclosure.


fact: cyber liability insurance policy

specificity_confidence: low

reasoning: The paragraph states the company maintains a cyber liability insurance policy, which is a concrete business/financial measure relating cybersecurity to the company's strategy, fitting Strategy Integration. The mention of a specific insurance policy type is a firm-specific fact (this company holds this coverage), though the paragraph is very brief and includes a cross-reference. No domain terms, verifiable quantities, or named entities elevate it beyond Level 3.

thinking: Cybersecurity insurance mention + cross-reference.


fact: ransomware mentioned as experienced threat type

fact: malware and computer virus attacks mentioned

fact: June 2018 specific incident date

fact: $10 million in forged/fraudulent electronic payment disbursements

fact: unauthorized third-party access to email system

reasoning: The paragraph describes actual incidents including a specific June 2018 event, but its primary purpose is the materiality assessment — stating risks 'have not materially affected us, including our business strategy, results of operations or financial condition' and are not 'reasonably likely' to do so, which is a clear SI materiality conclusion per Rule 5. Specificity reaches Level 4 via the verifiable $10 million amount and the specific June 2018 incident date tied to a real, publicly known event.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Third-party service providers hosting sensitive data
2. Actual cybersecurity incidents (ransomware, malware, unauthorized access)
3. A specific June 2018 incident ($10M fraudulent payments)
4. A materiality assessment stating risks have not materially affected them
5. A cross-reference to Risk Factors

What question does this primarily answer? It's a mix of incident disclosure and strategy integration. The June 2018 incident is described (ID), and there's a materiality assessment (SI). Let me weigh which dominates.

The paragraph opens with third-party risk context, catalogs various incidents, highlights the June 2018 example with specific dollar amounts, then concludes with a materiality statement that these haven't materially impacted the company. That materiality assertion appears to be the main point, with the incidents serving as supporting evidence for why the risk is immaterial. But there's real incident disclosure too.

I think this is primarily Strategy Integration because the materiality assessment is the conclusion/purpose of the paragraph, and the incidents are supporting context. But it's close. The specific incident detail (June 2018, $10M, forged payments) is substantial ID content.

Let me reconsider - the paragraph title is "Material Cybersecurity Risk, Threats & Incidents" and it describes actual incidents including a specific one. But the materiality conclusion is the key takeaway. I'll go with SI since the backward-looking materiality assessment + forward-looking "not reasonably likely" statement is the primary purpose per Rule 5.

Actually, re-reading Rule 4: "What happened (timeline, scope, response) → ID. Business/financial impact → SI. Mixed with incident frame dominant → ID. Mixed with financial frame dominant → SI."

The paragraph describes what happened AND provides a materiality assessment. The incident is described but the paragraph's purpose seems to be about materiality, so SI it is. Looking at the specificity here - there's a concrete date tied to a real event, a quantified dollar amount, and detailed descriptions of what actually occurred. Both the June 2018 incident and the $10 million figure are externally verifiable, which puts this at Level 4 specificity.


reasoning: The paragraph describes the company's cybersecurity program activities—controls, technologies, assessments, and engaging third-party specialists for reviews—making it RMP (third parties serve the company per Rule 3). All language is generic ERM-level ('assess, identify, and manage material cybersecurity risks,' 'formal reviews and assessments,' 'actionable recommendations') with no domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Describes cybersecurity risk management processes - controls, technologies, assessments, and engaging third-party specialists for reviews.

Category: RMP - describes what the cybersecurity program does (assessments, controls, technologies, third-party reviews as part of internal program).

Third parties are hired to serve the company (assessors) → RMP per Rule 3.

Specificity: Let me scan for facts.
- "controls, technologies, and other processes to assess, identify, and manage material cybersecurity risks" → generic ERM language, L1
- "engage independent third-party specialists to review our cybersecurity environment" → generic, L1

- "formal reviews and assessments" → generic
- "actionable recommendations for improvement" → generic

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


reasoning: The paragraph describes how a committee presents cybersecurity oversight results to the Board of Directors, including briefing frequency and escalation protocols — squarely answering 'how does the board oversee cybersecurity?' No domain-specific terminology (everything here could describe any enterprise risk), no firm-specific details (the 'Committee' is unnamed/generic in this excerpt), and no verifiable claims, leaving this at Level 1.

thinking:
Classify this paragraph.

This is about how the Committee presents results to the Board, how the Board oversees risk management, and how information flows to the board. This is Board Governance.

Specific facts: "Committee" - generic reference, not named specifically. "Board of Directors" - generic. "regularly scheduled meetings" - generic cadence. No domain terms that pass ERM test. No firm-specific facts. No verifiable claims.

Wait - "material cybersecurity threats or incidents" - this is generic language. "periodic performance and effectiveness review" - generic.

This is pretty boilerplate governance language.

So this classifies as Level 1 - it's all standard governance language without any specific details or firm-specific information.