fact: Named management-level committee: Cyber ERM (Enterprise Risk Management) Committee

fact: Committee comprises cross-functional representation across the Company

reasoning: The paragraph's primary purpose is establishing a management-level committee (Cyber ERM Committee), describing its composition (cross-functional) and responsibilities (rapid response, incident reporting to Board/Audit Committee). Per Rule 1, management-level committees → MR when about structure/membership. While the reporting chain to the Board touches BG, the central subject is the committee's organizational role. The named 'Cyber ERM Committee' is a firm-specific identifier that distinguishes this company's governance structure, elevating specificity to Level 3.

thinking:
Let me analyze this paragraph.

Category: This describes a committee (Cyber ERM Committee) - its composition, responsibilities, and reporting lines. The committee is management-level (not a board committee). It's about structure/membership and reporting to the Board/Audit Committee. The primary question answered is about how the oversight/governance chain works - the committee reports to the Audit Committee and Board. But the committee itself is management-level.

The paragraph describes: (1) a named committee - Cyber ERM Committee, (2) cross-functional composition, (3) responsibilities: rapid response/incident program, (4) reporting to Audit Committee and Board.

I'm trying to categorize this - the committee's structure and membership point toward management-level classification, but the reporting relationship to the Audit Committee and Board suggests governance oversight. The paragraph actually straddles both: it's describing the committee's establishment and composition while also explaining how it feeds into the board's materiality assessment process. The rapid response and incident management responsibilities are operational activities, but the governance chain is what ties it to board-level oversight. G). Let me apply the person-removal test for MR vs RMP.

Remove person-specific content (committee name, composition): "implementing a rapid response and incident program in the event of an identified cybersecurity threat" and "reporting all incidents to the Audit Committee and Board of Directors... to assess materiality... and determine Exchange Act reporting obligations."

The incident response program description remains but it's thin. The reporting chain to Board also remains but that's governance. The committee structure IS the main content. I think this is MR - it's about establishing and describing a management-level committee's role.

Wait, but Rule 1 says governance-chain paragraphs default to BG. This paragraph describes how information flows from management committee → Audit Committee → Board. That's a governance chain. But the primary subject is the Cyber ERM Committee itself.

I'll go with MR - the central subject is this management-level committee, its composition and responsibilities. The named "Cyber ERM Committee" is firm-specific, while the incident response plan and reporting obligations are generic elements that appear across companies.


content_category: Third-Party Risk

category_confidence: high

specificity_confidence: high

reasoning: The paragraph's central topic is contractual cybersecurity requirements imposed ON the Custodian (a third-party vendor), including requirements the Custodian must flow down to its own critical vendors and incident notification obligations — squarely Third-Party Risk. The language throughout is generic ERM-level ('reasonable and appropriate measures,' 'processes to assess, identify and manage risks') with no domain-specific terminology passing the ERM test, no named frameworks, and no verifiable claims, keeping specificity at Level 1.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Analyzing this paragraph from MetLife Policyholder Trust's 10-K filing.

This is about contractual requirements imposed ON the Custodian (a vendor/third party) regarding cybersecurity measures and incident reporting. The central topic is third-party oversight via contract.

Category: Third-Party Risk - contractual security requirements imposed on the Custodian vendor.

Specificity: Let me check for facts. The language is fairly generic - "reasonable and appropriate" measures, "processes to assess, identify and manage risks" - standard ERM language. "Custodian" is a specific role but generic in trust context.

The mention of MetLife, Inc. as a named entity and the Custodian as a specific contractual party add some firm-specificity, but most of the language around data security incidents, cybersecurity measures, and critical vendor requirements remains fairly generic without specific frameworks or tools referenced.

Looking at the contractual structure itself—the requirement that the Custodian notify MetLife and impose requirements on its own vendors—this describes a particular organizational arrangement, but it's still expressed in standard boilerplate language that doesn't distinguish this from typical ERM provisions.

I'm settling on Level 1 for this as generic boilerplate, since the language throughout relies on standard contractual and risk management terminology without domain-specific terms that would elevate it beyond that baseline.


content_category: Risk Management Process

fact: access control listed as an IT security process

specificity_confidence: low

reasoning: The paragraph describes the company's cybersecurity policies, standards, and processes for assessing and managing cyber risks, making it RMP. Most language is generic boilerplate ('processes to assess, identify and manage cybersecurity risks'), but 'access control' as a named IT security process passes the ERM test as a domain-specific practice, pushing to Level 2.

thinking:
Classify this paragraph.

Category: This describes what the cybersecurity program does - processes to assess, identify, manage risks, policies covering various topics, regular reviews. This is RMP.

The cross-reference at the end is minor.

Specificity: Let me scan for facts.
- "incident response, access control, disaster recovery and testing" - these are process descriptions. Access control passes ERM test? Access control is a security domain term. Incident response is listed as commonly confused (L1). Disaster recovery is L1.
- "access control" - this is a security-specific concept that passes the ERM test

- "at least annually" - generic cadence
- "AI and operational resilience laws" - not really domain terms for cybersecurity

Now I'm reconsidering whether "access control" truly qualifies as domain-specific. It's fundamental to IT security, but general ERM professionals might also reference access controls in physical security contexts. In the IT context though, it's pretty specialized terminology that wouldn't naturally appear in non-security risk management discussions.

Looking at the full paragraph again - "incident response, access control, disaster recovery and testing" - incident response and disaster recovery are explicitly L1 boilerplate, but access control in an IT process context is more specialized. The framing as "IT processes" does show some domain awareness. I'm leaning toward L2 because of the access control terminology, even though it sits alongside L1 concepts.


content_category: Incident Disclosure

fact: Cybersecurity intrusion detected on February 16, 2022

fact: Network disruption impacting certain systems

category_confidence: medium

reasoning: The paragraph is anchored by a real cybersecurity incident (February 2022 intrusion) with detection, response, and a materiality conclusion, making Incident Disclosure the dominant frame despite extensive speculative boilerplate that follows. The specific date 'February 16, 2022' tied to a real event is externally verifiable, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

It describes a real cybersecurity incident (February 16, 2022 intrusion), then transitions into speculative risk language and a cross-reference.

Category: The paragraph starts with an actual incident description (ID), then has a materiality assessment ("did not materially and adversely affect our results of operations" → SI), then speculative risk language, then cross-reference.

The incident description and the materiality conclusion are both present. The incident frame is dominant early, but much of the paragraph is speculative boilerplate. The materiality statement "the February 2022 cybersecurity intrusion did not materially and adversely affect our results of operations" is a backward-looking SI assessment per Rule 5.

Wait, I need to reconsider the balance here. The actual incident details only occupy the first few sentences, while the bulk of the paragraph consists of the materiality conclusion and speculative language about potential risks. The speculative portions with phrases like "could have" and "potential to" don't qualify as SI under Rule 5—those are forward-looking statements without the materiality anchor. So the real SI content is just that one sentence about the incident not materially affecting operations, making the paragraph predominantly ID with a brief SI component, not the other way around.

Looking at the specificity markers: the February 16, 2022 date tied to an actual cybersecurity intrusion is externally verifiable at Level 4, even though other details like "third-party experts" lack firm specificity. That concrete date anchors this as ID.


fact: Intrusion caused a network disruption and impacted certain systems

fact: Did not materially and adversely affect results of operations (materiality conclusion about the incident)

reasoning: The paragraph is anchored by a real cybersecurity incident (February 16, 2022 intrusion) with detection, response steps, and a materiality assessment, making the incident frame dominant over the extensive speculative risk language that follows (Rule 4 → ID). The specific date of the incident (February 16, 2022) is an externally verifiable fact, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

Content: Describes a real cybersecurity incident (Feb 16, 2022 intrusion), then transitions to hypothetical impacts and risk factors. The incident description is the opening and anchoring content, but the majority of text is about potential impacts (speculative). However, there's also a materiality assessment: "the February 2022 cybersecurity intrusion did not materially and adversely affect our results of operations."

Category: Mixed ID and SI. The paragraph starts with incident details (date, detection, response), includes a materiality assessment (SI), then extensive speculation.

The incident itself is the concrete, distinguishing element here, while the speculation about potential impacts is more generic risk language. The materiality statement—that the intrusion didn't materially affect operations—is clearly an SI assessment. So despite the mixed nature, the incident details and the materiality conclusion together form the substance, making this primarily an ID disclosure with an SI component.

Looking at the specificity markers: the February 16, 2022 date is verifiable and concrete, "cybersecurity intrusion" and "network disruption" are domain-specific terms, and the incident itself qualifies as quantitatively verifiable. That puts this at Level 4.


content_category: None/Other

reasoning: This paragraph describes Travis Smith's career history and responsibilities in manufacturing, engineering, and HSE — none of which involve cybersecurity. Despite appearing in Item 1C, the paragraph contains zero substantive cybersecurity disclosure (no cybersecurity responsibilities, oversight, or program content), making it N/O per Rule 6. N/O paragraphs always receive Generic Boilerplate regardless of verifiable biographical details present.

thinking:
Let me analyze this paragraph about Travis Smith from Eastman Chemical Co.

Category: This is about a management role - describing qualifications, career history, and responsibilities. But wait - is this actually about cybersecurity? Let me re-read... This describes an EVP responsible for manufacturing, engineering, and HSE. There's no mention of cybersecurity at all. It's in Item 1C but the content itself has no cybersecurity substance.

Actually, it's in Item 1C which is the cybersecurity disclosure section, so presumably this person has some role in cybersecurity oversight.

The paragraph itself is purely about manufacturing, engineering, and HSE responsibilities with no cybersecurity content whatsoever. Even though it's positioned in Item 1C, there's no substantive cybersecurity disclosure here - just a biographical overview of a manufacturing executive. The company may have included this bio as part of their cybersecurity governance structure, but the text itself contains zero cybersecurity substance, so I'll classify this as a Management Role. I'm looking at the specific details here—Travis Smith is named with his exact title, age 51, and a series of verifiable dates spanning from 1992 through January 2025. These concrete facts push this toward Level 4 specificity. But I'm circling back to the core issue: there's genuinely no cybersecurity language in this paragraph at all. It's purely biographical and career history. If I'm categorizing this as None/Other, then specificity should be Generic Boilerplate, not Level 4. So I need to settle the category first before I can assign the right specificity level.

The real tension is that companies include executive bios in Item 1C precisely because these people manage cybersecurity risk, even if the paragraph itself never mentions cybersecurity. But the instructions are clear—no substantive cybersecurity disclosure means None/Other. This person's role is manufacturing, HSE, and engineering, with zero explicit cybersecurity content. I think I have to go with None/Other, even though it feels like I'm missing the context of why the company placed it there. I keep wavering on whether this executive's biographical details qualify as cybersecurity management disclosure. The paragraph focuses on manufacturing and operational responsibilities with no explicit cybersecurity mention, which pushes me toward None/Other. I'm settling on N/O with Generic Boilerplate classification.


reasoning: This is a cross-reference paragraph pointing to Item 1A Risk Factors for materiality discussion, with no substantive cybersecurity content. Pure cross-reference → N/O, Generic Boilerplate.


reasoning: This is a forward-looking disclaimer with a cross-reference to Item 1A Risk Factors, containing no substantive cybersecurity disclosure. 'Could have a material adverse effect' is generic speculation present in virtually every 10-K, not a materiality assessment. No specific facts elevate specificity above Level 1.

thinking: Brief forward-looking disclaimer with cross-reference.


reasoning: This is an introductory paragraph framing the company's cybersecurity program, referencing 'risk management principles' and safeguarding information systems, which points toward RMP as the topic being introduced. However, no specific practices, domain terms, or firm-specific facts are present — 'confidentiality, integrity, and availability' is standard boilerplate any business professional could write, keeping it at Level 1.

thinking: Introductory paragraph with no specific cybersecurity content.


reasoning: The paragraph centrally addresses how the company manages third-party/vendor cybersecurity risk — reviewing practices, imposing contractual obligations, conducting assessments — making TP the clear category. All language is generic process description (reviewing, assessing, contractually imposing) that any ERM professional could write; no domain terms, firm-specific facts, or verifiable claims are present.

thinking: Third-party risk management paragraph.


fact: ransomware actors may have exfiltrated personal information

fact: notifications provided to individuals and regulators in accordance with applicable laws

reasoning: The paragraph describes findings from an actual incident investigation—ransomware exfiltration of personal data and subsequent regulatory notifications—making it Incident Disclosure. 'Ransomware' is a specific threat type passing the ERM test for Level 2, but there are no named firms, specific dates, or verifiable quantities to push higher.

thinking: Incident disclosure - describes what happened (ransomware exfiltration, notifications provided).


content_category: Strategy Integration

reasoning: The paragraph opens with a direct materiality assessment ('have not materially affected... not reasonably likely to materially affect... business strategy, results of operations, or financial condition'), which is the SEC Item 106(b)(2) formula → SI. The remainder is generic speculation about evolving threats and a cross-reference to Risk Factors. No domain terms, firm-specific facts, or verifiable claims are present.

thinking: SI materiality assessment in first sentence, plus cross-reference.


content_category: Board Governance

reasoning: The paragraph describes how cybersecurity information flows to the board—Audit Committee reports to the full Board, and management briefs the Board—squarely answering the board oversight question. No domain terms, firm-specific facts, or verifiable claims are present; 'Audit Committee' and 'full Board' are generic governance structures every public company has.

thinking:
Classify this paragraph.

Content: Audit Committee reports to Board about cybersecurity activities; Board receives briefings from management on cybersecurity.

Category: Board Governance - describes how information flows to the board about cybersecurity oversight.

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


fact: ransomware incident

fact: phishing emails

fact: fourth quarter of fiscal year 2019

fact: retained third party consultants and forensic experts

fact: assistance of law enforcement in investigating the attack

reasoning: The paragraph describes a real ransomware incident in Q4 2019 with timeline, impact on operations and revenue, and remediation steps — classic Incident Disclosure. The specific date (Q4 fiscal year 2019) tied to a real event and the cross-reference to Note 18 in financial statements make this verifiable, elevating to Level 4.

thinking: Incident disclosure about a real ransomware event in Q4 2019, with financial impact details.


fact: defense-in-depth and layered strategy

fact: endpoint detection and response

fact: network anomaly detection

fact: multi-factor authentication

fact: threat intelligence services

fact: phishing simulation exercises

reasoning: The paragraph describes what the cybersecurity program does—tools deployed, training conducted, third-party services used—squarely answering the RMP question. Multiple domain-specific terms (EDR, network anomaly detection, MFA, defense-in-depth, threat intelligence, phishing simulations) pass the ERM test, but no firm-specific roles or verifiable claims elevate beyond Level 2.

thinking:
Let me analyze this paragraph.

Content category: This describes what the cybersecurity program does - risk assessment, framework, security tools, training. This is RMP.

Specific facts:
- "defense-in-depth" - domain term (architectural concept)
- "endpoint detection and response" - domain term (EDR)
- "network anomaly detection" - domain term
- "multi-factor authentication" - domain term (MFA)
- "threat intelligence services" - domain term
- "phishing simulation exercises" - domain term
- "layered strategy" - related to defense in depth

No named roles, no verifiable claims.

This appears to be a domain-adapted level 2 classification, meaning the content uses specialized cybersecurity terminology and concepts but doesn't reference specific individuals or make claims that require external verification.


reasoning: The paragraph is centrally about how the company identifies and oversees cybersecurity risks from third parties (vendors, service providers, third-party systems), making Third-Party Risk the primary category. The language is entirely generic — 'risk-based approach,' 'identifying and overseeing' — with no domain-specific terms, firm-specific facts, or verifiable claims, leaving it at Level 1.

thinking:
Classify this paragraph.

Content: About managing third-party cybersecurity risks - vendors, service providers, third-party systems. This is centrally about third-party risk management.

Category: Third-Party Risk - it's centrally about how third-party cyber risks are managed.

Specificity: "risk-based approach" is generic ERM language. No domain terms that pass the ERM test. No firm-specific facts.

There are no verifiable claims here, so this lands at Level 1.


reasoning: The paragraph centrally addresses how the company manages cybersecurity risks from third-party vendors—due diligence, risk assessments, and contractual obligations—making Third-Party Risk the clear category. All language is generic vendor risk management (risk assessments, contractual obligations, due diligence) that any ERM professional could write; no domain-specific terms, firm-specific facts, or verifiable claims are present.

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

Specificity: The paragraph describes vendor security due diligence, risk assessments on vendors, contractual cybersecurity obligations. All of this is generic process description - no domain terms that pass the ERM test, no firm-specific facts, no verifiable claims. "Risk assessments on vendors" and "contractual obligations" are standard ERM language.

Wait - "application providers, contract research organizations and contract manufacturing organizations" - these are types of vendors but not cybersecurity domain terms. The whole paragraph is generic vendor risk management language.

So this is Level 1 - it's just boilerplate third-party risk management without any specificity or concrete details.


reasoning: The paragraph's central topic is managing cybersecurity risks from third-party service providers — risk assessments, requesting security policy information, and monitoring vendor incidents — making it squarely Third-Party Risk. All language is generic process description (risk assessments, security policies, monitoring) that any ERM professional could write, with no domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

The paragraph is centrally about how the company manages third-party cybersecurity risks - vendor assessments, requesting security info from providers, monitoring incidents involving third parties. This is squarely Third-Party Risk.

Specificity: Let me scan for facts.
- "third-party risk assessments" - generic process description, L1
- "request that material third-party service providers provide us information about their security policies and procedures" - generic
- "monitor cybersecurity incidents involving our third-party providers" - generic

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

All the language here is boilerplate without any concrete details or company-specific information, so this lands at Level 1.


reasoning: The paragraph answers how the board oversees cybersecurity: Audit Committee oversight, quarterly updates, and escalation to a Cybersecurity Sub-Committee for material incidents — classic Board Governance. The named 'Cybersecurity Sub-Committee of the Board of Directors' is a non-generic committee that elevates specificity to Firm-Specific; the quarterly cadence and Audit Committee are generic and do not qualify.

thinking:
Classifying this paragraph.

Category: Board Governance - describes how the board/committees oversee cybersecurity.

Specific facts:
- Audit Committee oversight - generic, every company has this
- "at least once per quarter" - generic cadence
- "Cybersecurity Sub-Committee of the Board of Directors" - this is a named non-generic committee → firm-specific

Specificity: Firm-Specific (Level 3) due to the Cybersecurity Sub-Committee.


content_category: Management Role

fact: CISO role with primary responsibility for information security program

type: quantified

reasoning: The paragraph describes the CISO's responsibilities and qualifications; applying the person-removal test leaves no substantive program description, confirming MR. Specificity reaches Level 4 due to two specific experience durations (30 years IT, 17 years infosec) that are externally checkable against a resume.

thinking:
Classify this paragraph.

Category: This is about the CISO's role, responsibilities, and qualifications. Person-removal test: remove CISO, 30 years, 17 years, qualifications → almost nothing remains. → MR

Specificity:
- "CISO" → named_role (firm-specific)
- "30 years of information technology experience" → quantified, verifiable
- "17 years focused specifically on information security and risk management" → quantified, verifiable

Level 4.


fact: firewalls

fact: intrusion prevention systems

fact: endpoint detection and response systems

fact: vulnerability assessments

fact: cybersecurity threat intelligence

reasoning: The paragraph describes technical safeguards and security operations the program deploys, squarely answering 'what does the cybersecurity program do?' → RMP. Multiple domain-specific terms (firewalls, IPS, EDR, vulnerability assessments, threat intelligence) pass the ERM test, elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Category: Describes what the cybersecurity program does - technical safeguards, tools, monitoring. This is RMP.

Specific facts: firewalls, intrusion prevention, endpoint detection and response (EDR), access controls, vulnerability assessments, threat intelligence - these are domain terms that pass the ERM test.

No firm-specific facts, no verifiable claims.

Level 2.


fact: IS Steering Committee oversees vendor management program

fact: Chief Information Officer chairs the IS Steering Committee

reasoning: The paragraph centrally addresses third-party vendor risk management — identifying, measuring, monitoring, and controlling outsourcing risks — making it Third-Party Risk. Specificity reaches Level 3 via the named IS Steering Committee and CIO role chairing it, both firm-specific organizational details.

thinking:
Let me analyze this paragraph.

Content: This is about third-party vendor management. It discusses the vendor management program, risks of third-party relationships, the IS Steering Committee oversight, and the program's purpose.

Category: Third-Party Risk - the central topic is managing third-party/vendor cyber risks.

Specific facts:
- "IS Steering Committee" - named committee
- "Chief Information Officer" - named role (CIO is VP+ level)
- The committee is "chaired by the Chief Information Officer" - firm-specific organizational detail

Specificity: The IS Steering Committee and CIO are firm-specific facts → Level 3.


fact: CISO role briefs the Audit Committee

fact: Cybersecurity Executive Committee

fact: Audit Committee composed of two members of the Board who are also members of the Cybersecurity Executive Committee

reasoning: The paragraph describes how the board-level Audit Committee receives cybersecurity briefings from the CISO and its compositional overlap with the Cybersecurity Executive Committee, making it primarily about board oversight. The specific claim of 'two members' on both committees is a verifiable headcount, elevating to Level 4.

thinking:
Classify this paragraph.

The paragraph describes how the CISO briefs the Audit Committee on cybersecurity matters, and notes the committee composition overlap with the Cybersecurity Executive Committee. This is about board-level oversight (Audit Committee receiving briefings) → Board Governance.

Specific facts:
- CISO (named_role, firm-specific)
- Cybersecurity Executive Committee (named_committee, firm-specific)
- Audit Committee composed of two members of the Board who are also on the Cybersecurity Executive Committee (quantified - "two members" is a specific number)

- "Annually" briefing cadence is generic, but the "two members" detail is a specific headcount that could be verified, making this Level 4.


fact: Information Technology Automated Solutions (ITAS) — named internal department responsible for vendor audits

reasoning: The paragraph is centrally about managing cybersecurity risks from third-party service providers — security risk assessments before engagement, MSA security requirements, audit rights, and ongoing certification validation — making Third-Party Risk the clear category. The named internal department 'Information Technology Automated Solutions (ITAS)' is a firm-specific organizational detail that elevates specificity to Level 3.

thinking:
Classify this paragraph.

Content: About managing third-party service provider cybersecurity risks - security risk assessments, MSA security requirements, audit rights, ongoing audits by ITAS.

Category: Third-Party Risk - this is centrally about how they manage vendor/supplier cybersecurity risks.

Specific facts:
- "security risk assessment" - generic process
- "master services agreements" - generic
- "audit rights" - generic
- "Information Technology Automated Solutions (ITAS)" - named team/department, firm-specific
- "contract owners within ITAS" - firm-specific organizational detail

Specificity: ITAS is a named internal team/department - firm-specific (Level 3).


fact: Disclosed a security breach on February 13, 2023

fact: Third-party vendor providing secure file transfer software platform was breached

fact: Personal information of certain patients of healthcare facilities were exposed

reasoning: The paragraph describes a real cybersecurity incident with a specific disclosure date (February 13, 2023) and details about what happened (third-party file transfer vendor breach exposing patient data), making it Incident Disclosure. The specific date is externally verifiable, elevating specificity to Quantified-Verifiable.

thinking: Incident disclosure with a specific date and real event described.


fact: Chief Information Security Officer (CISO)

fact: Cybersecurity Risk Management Team

reasoning: The paragraph describes who implements cybersecurity processes—CISO oversight, a named department, and a named team—making it about management organization. Person-removal test leaves almost no substantive content, confirming MR. Firm-specific named roles and teams (CISO, Trust/Security/Reliability department, Cybersecurity Risk Management Team) elevate to Level 3, but no verifiable claims (no specific credentials, years of experience, or headcount) keep it below Level 4.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes management roles (CISO, Trust/Security/Reliability department, Cybersecurity Risk Management Team) and their organizational structure. Person-removal test: remove CISO, team names, department - what remains? "Our cybersecurity risk assessment and management processes are implemented and maintained by certain Company management... has significant collective experience in relevant computer science and engineering disciplines and cybersecurity matters." Very little substantive program description remains. → MR

Specificity:
- CISO → named_role (firm-specific)

- "Trust, Security and Reliability department" → named_team (firm-specific, distinguishing department name)
- "Cybersecurity Risk Management Team" → named_team (firm-specific)

Level 3.


fact: Chief Capability Officer (CCO)

fact: Chief Information Officer (CIO)

reasoning: The paragraph primarily describes board-level oversight via the Audit Committee receiving cybersecurity reports and engaging with management, making it Board Governance. Three named C-suite roles (CCO, CIO, CISO) elevate specificity to Firm-Specific.

thinking:
Let me analyze this paragraph.

Category: This describes how the Audit Committee receives reports and engages with management on cybersecurity. The primary question answered is "How does the board oversee cybersecurity?" — Board Governance. The Audit Committee is a board-level committee receiving reports from management.

Specific facts:
- "quarterly cybersecurity reports" — generic cadence
- "Audit Committee" — generic, every company has one
- "Chief Capability Officer (CCO)" — this is a named role, VP-level or above, firm-specific

- "Chief Information Officer (CIO)" and "Chief Information Security Officer (CISO)" — both named roles at VP-level or above, making them firm-specific
- "incident response and recovery protocols," "associate trainings and awareness," and "third-party audits and assessments" — all Level 1 generic practices

The CCO title is particularly distinctive since "Chief Capability Officer" isn't a standard executive role you see everywhere, and combined with the CIO and CISO, these named positions push this into firm-specific territory.

Specificity: Level 3 (Firm-Specific) due to the presence of named executive roles — CCO, CIO, and CISO.


reasoning: The paragraph answers how the board oversees cybersecurity: receiving quarterly reports, management updates, and incident escalation above a threshold — classic Board Governance. No domain terms pass the ERM test ('security posture,' 'cybersecurity events' are general business language), no firm-specific facts (quarterly cadence is generic, 'pre-determined minimum threshold' is vague), and no verifiable claims, leaving this at Level 1.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity - quarterly reports, board receives updates from management. This is Board Governance.

Specific facts:
- "quarterly cybersecurity report" - generic cadence, not firm-specific
- "pre-determined minimum threshold" - this is a firm-specific process detail but fairly generic language
- Board of directors - generic

No domain terms that pass the ERM test. "cybersecurity risk," "security posture," "cybersecurity events," "cybersecurity incidents" - these are basic terms any ERM professional would use.

Actually, "security posture" - would a non-security ERM professional use this? It's pretty common in general business language now.

The "pre-determined minimum threshold" for incident escalation is just a process description rather than specialized terminology, so this reads as standard board oversight language—I'd classify it as Level 1 Generic Boilerplate.


reasoning: The paragraph centrally addresses how the Adviser oversees cybersecurity risks from third parties including vendors, service providers, and external users, making TP the primary category. The language is entirely generic ('comprehensive, risk-based approach,' 'key vendors, service providers') with no domain terms passing the ERM test, no firm-specific facts, and no verifiable claims, keeping specificity at Level 1.

thinking:
Classify this paragraph.

Content: About how the Adviser manages third-party cybersecurity risks - vendors, service providers, external users. This is centrally about third-party risk management.

Category: Third-Party Risk (TP) - the central topic is managing cyber risks from third parties.

Specificity: "comprehensive, risk-based approach" - generic. "key vendors, service providers and other external users" - generic. No domain terms that pass the ERM test. No firm-specific facts beyond "Our Adviser" which is somewhat firm-specific (indicates externally advised structure). Actually "Our Adviser" is a generic reference to the company's adviser - not a named role at VP+ level. It's just describing the organizational structure.

The language here is standard boilerplate with no specialized terminology or distinguishing details - just a generic description of how the company manages external cybersecurity risks through its adviser structure. This lands at Level 1.


fact: security questionnaires required of vendors

fact: vulnerability scans conducted related to vendors' services

reasoning: The paragraph is centrally about how the company manages cybersecurity risks from third-party vendors—assessment levels, contractual obligations, and security requirements imposed on providers—making it Third-Party Risk. Domain terms like 'security questionnaires' and 'vulnerability scans' pass the ERM test (security-specific assessment methods), elevating to Level 2, but no firm-specific or verifiable facts are present.

thinking:
Classify this paragraph.

Content: Describes how they manage third-party/vendor cybersecurity risks - vendor management processes, assessments, contractual obligations, security questionnaires, vulnerability scans.

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

Specificity: Let me scan for facts.
- "security questionnaires" - this is a domain term (specific vendor assessment practice)
- "vulnerability scans" - domain term
- "contract research organizations" and "contract manufacturing organizations" - these are firm-specific types of vendors typical of pharma/biotech companies, but they're general business terms, not cybersecurity domain terms

- The paragraph describes requirements imposed on vendors, which confirms the third-party risk focus. The domain-specific terms like security questionnaires and vulnerability scans both qualify as specialized security practices, putting this at Level 2 specificity. There are no named roles, committees, or verifiable facts that would push it higher.

Specificity: Domain-Adapted (Level 2).


fact: Vice President and Chief Information Officer (CIO)

fact: Cybersecurity Team within IT department

fact: CISO has 27 years of cybersecurity experience

fact: 17 years in the oil and gas industry

fact: One of less than 400 CISOs globally graduated from FBI's CISO Academy in Quantico, Virginia

reasoning: The paragraph describes management organizational structure—reporting lines (CISO → CIO), team composition, qualifications, and credentials—making it MR via the person-removal test (removing people leaves almost nothing). Specificity reaches Level 4 with multiple verifiable claims: 27 years experience, 17 years in oil and gas, and graduation from the FBI's CISO Academy (a named, verifiable program with a specific claimed cohort size of <400).

thinking:
Classifying this paragraph.

Category: This is about management roles - CISO, CIO, their qualifications, reporting lines, team structure. Person-removal test: remove names, titles, qualifications → very little remains. → MR

Specificity: Let me list facts:
- VP and CIO (named_role, firm-specific)
- CISO (named_role, firm-specific)
- 27 years of cybersecurity experience (quantified, verifiable)
- 17 years in oil and gas industry (quantified, verifiable)
- FBI's CISO Academy in Quantico, Virginia (named_firm/other_specific, verifiable)

- Less than 400 CISOs globally have graduated from the academy (quantified, verifiable)
- Cybersecurity Executive Committee and Cybersecurity Team (named_committee and named_team, firm-specific)

Level 4.


fact: security incident and event manager (SIEM) interface

fact: behavioral analytics

fact: firewalls

fact: anti-malware

fact: penetration testing (external and internal)

fact: authentication attempts monitoring

reasoning: The paragraph describes the company's cybersecurity program activities—incident identification processes, security monitoring tools, and testing procedures—squarely answering 'what does the program do?' → RMP. Multiple domain-specific terms (SIEM, behavioral analytics, firewalls, anti-malware, penetration testing) pass the ERM test, but no firm-specific or verifiable facts elevate beyond Level 2.

thinking:
Classify this paragraph.

Category: Describes what the cybersecurity program does - processes, tools, testing. RMP.

Specificity: Let me scan for facts.
- "security incident and event manager interface" = SIEM (domain term)
- "behavioral analytics" = domain term
- "firewalls" = domain term
- "anti-malware" = domain term
- "penetration testing" = domain term
- "authentication attempts" = domain term

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


fact: Vice President of IT & Digitization

reasoning: The paragraph identifies who is responsible for cybersecurity (VP of IT & Digitization and the IT Team) and describes their qualifications and responsibilities—person-removal leaves only generic risk language, confirming MR. The VP-level title with a specific portfolio ('IT & Digitization') is a firm-specific fact elevating to Level 3.

thinking:
Classify this paragraph.

Category: This describes management's organizational structure - VP of IT & Digitization, IT Team, their responsibilities. Person-removal test: remove the VP title and team composition, what remains? "identifying, assessing, monitoring, managing and communicating cybersecurity risks" and "experience developing and implementing enterprise-wide cybersecurity strategies..." - this is generic description of what the team does, but the primary framing is about WHO is responsible (the VP, the IT Team) and their qualifications. This is MR.

Specificity:
- "Vice President of IT & Digitization" - VP-level title with IT portfolio → firm-specific

- "IT Team" is a generic label, though it has a defined composition, while the remaining language about cybersecurity risk management and strategy development is standard across organizations. The VP title is what pushes this to Level 3 - Firm-Specific.


fact: attack vectors

specificity_confidence: medium

reasoning: The paragraph opens with a backward-looking materiality assessment ('have not experienced any material cybersecurity events to date') and then states threats 'could materially affect' business strategy/results, making SI the primary category per Rule 5. The term 'attack vectors' is cybersecurity-specific vocabulary that passes the ERM test, lifting specificity to Level 2, though the rest is generic speculation and a cross-reference.

thinking:
Let me analyze this paragraph.

"Although we have not experienced any material cybersecurity events to date" — this is a negative assertion about absence of incidents. Per Rule 5, "Have not experienced any material cybersecurity incidents" → SI (negative assertion).

Then "new advanced cybersecurity threats and attack vectors could materially affect" — "could" is speculative, not an assessment.

Then a cross-reference to Item 1A.

The paragraph opens with a backward-looking materiality assessment (no material events to date) → SI. The speculative part and cross-reference are secondary.

Specificity: "Have not experienced any material cybersecurity events to date" is a negative self-assertion, not externally verifiable.

Now I'm checking whether there are any domain terms that would elevate this beyond generic boilerplate. "Attack vectors" is actually cybersecurity-specific vocabulary that passes the ERM test, so I'd classify this as Level 2 with that domain term included.


fact: CISO role referenced as briefing the board and committee

reasoning: The paragraph describes how cybersecurity information flows from the CISO and management to the Audit and Risk Committee and Board of Directors, including briefing frequency — this is board oversight structure, hence Board Governance. The CISO is a firm-specific named role elevating to Level 3; the cadences (quarterly, semi-annual, annual) are generic and the Audit and Risk Committee is a standard board-level committee, so neither adds specificity beyond Level 3.

thinking:
Classify this paragraph.

Category: This describes how information flows from CISO/management to the Audit and Risk Committee and Board. It's about board oversight structure and information flow → Board Governance.

Specific facts:
- CISO (named role, firm-specific)
- Audit and Risk Committee (this is a named committee but it's a board-level committee similar to "Audit Committee" - however "Audit and Risk Committee" is slightly more specific than generic "Audit Committee")
- Quarterly briefings, semi-annual briefings, annual briefings - generic cadences, not firm-specific
- External assessments - domain term? No, generic.

- Cybersecurity training programs - generic

The Audit and Risk Committee is a standard board-level governance structure, not firm-specific, but the CISO role is the distinguishing firm-specific element here. This lands at Level 3 (Firm-Specific) because of the named executive role.


fact: February 2022 targeted cyber-attack

fact: Limited operations for approximately three weeks

fact: Chief Information Security Officer (CISO) added to IS leadership

fact: CSRM program (named internal program)

fact: cybersecurity incident response plan

reasoning: The paragraph primarily describes what happened in an actual cyber-attack — its timing, scope (global systems shutdown), operational impact (~3 weeks of limited operations), and remediation — making it Incident Disclosure despite some SI and RMP elements. Specificity is Level 4 due to the specific date (February 2022), quantified duration (~three weeks), and the CISO addition, all of which are externally verifiable claims tied to a publicly reported incident.

thinking:
Let me analyze this paragraph.

Content: Describes an actual cyber-attack in February 2022, its impact (shutting down systems, limited operations for ~3 weeks), remediation steps, and organizational changes (adding CISO).

Category: This describes an actual incident - timeline, scope, impact, response. It also has some SI elements ("do not expect to have a further material adverse impact") and some RMP elements (investments in CSRM program). But the dominant frame is the incident narrative. → Incident Disclosure.

Specific facts:
- "February 2022" - specific date → verifiable

- "approximately three weeks" - soft number but specific enough
- "Chief Information Security Officer (CISO)" - named role → firm-specific
- "CSRM program" - named internal program
- "cybersecurity incident response plan" - domain term
- The incident itself is a real, publicly known event → verifiable

Level 4: "February 2022" specific date tied to real event, "approximately three weeks" duration, CISO role added, named program "CSRM program."


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

type: framework

fact: International Organization for Standardization (ISO) framework

fact: Confidentiality, security and availability (CIA triad)

reasoning: While the paragraph opens with board oversight context, the majority of text describes the cybersecurity program's ERM integration, framework adoption (NIST, ISO), and approach to preserving confidentiality/security/availability—answering 'what does the program do?' → RMP. Named frameworks (NIST, ISO) and the CIA triad pass the ERM test as domain terminology, but no firm-specific facts or verifiable claims are present, so specificity stays at Level 2.

thinking:
Analyzing this paragraph from Day One Biopharmaceuticals (DAWN) 10-K filing.

Category: The paragraph starts with board oversight (BG) but then shifts to describing the cybersecurity program's integration with ERM, frameworks, and approach. The primary question answered is "What does the cybersecurity program do?" - describing framework adoption, ERM integration, and the comprehensive approach. The board mention is brief context. This is RMP.

Wait, let me re-read. First sentence: Board recognizes importance. Second: Board is actively involved in oversight of risk management, cybersecurity as component of ERM.

Third and fourth sentences detail the program's foundation in NIST and ISO frameworks, along with its cross-functional approach emphasizing confidentiality, security, and availability. The board appears mainly as context for what's really a program description. This is RMP.

I'm identifying domain terms here: NIST and ISO are named standards frameworks, and the CIA triad concept appears explicitly. These are domain-specific references that satisfy the ERM test. No firm-specific facts like named executives or committees beyond the generic Board, and no verifiable claims to check.

This lands at Domain-Adapted specificity.


reasoning: The paragraph opens with a backward-looking materiality assessment ('no cybersecurity incidents have had…a material adverse effect on our business, financial condition or results of operations'), which is the defining marker of Strategy Integration under Rule 5. It also discusses cyber risk insurance and potential future costs, reinforcing the SI frame. No domain terms pass the ERM test ('cyber risk insurance' is standard business language), the negative materiality assertion is not externally verifiable, and no firm-specific or quantified facts are present, leaving specificity at Level 1.

thinking:
Classify this paragraph.

The paragraph states "no cybersecurity incidents have had...a material adverse effect" - this is a backward-looking materiality assessment → SI per Rule 5. Then discusses insurance and potential future impacts.

The materiality assessment is the lead and central claim. The insurance mention also supports SI. The "could have a material adverse effect" is speculation but the overall frame is SI.

Specific facts: "cyber risk insurance" - this is a firm-specific claim about having insurance... actually, many companies mention this. Let me think about specificity.

- "cyber risk insurance" - is this domain terminology? It's a common business term.

The insurance language doesn't really qualify as domain-specific in the cybersecurity sense, and the negative assertion about incidents lacking material impact isn't verifiable under the rules. This reads as standard boilerplate materiality language without domain terminology that would satisfy the ERM test, firm-specific facts, or verifiable claims. "Cyber risk insurance" itself isn't a cybersecurity domain term—it's general business language an ERM professional would recognize. Overall, this is Level 1 with generic boilerplate specificity.


fact: Chief Information Security Officer (CISO) maintains the enterprise information security program

fact: Executive Vice President and Chief Information Officer (CIO) oversees the program

reasoning: The paragraph names the CISO and EVP/CIO as maintaining and overseeing the security program. Applying the person-removal test, removing these roles leaves only generic 'assess, identify and manage material risks through our enterprise information security program,' which collapses to near-nothing substantive — making this MR. The CISO and EVP/CIO titles are firm-specific facts elevating specificity to Level 3.

thinking:
Classify this paragraph.

Content: Describes enterprise information security program maintained by CISO, overseen by EVP/CIO. The paragraph answers "How is management organized to handle cybersecurity?" - it's about roles and oversight structure at management level.

But wait - it also mentions "assess, identify and manage material risks from cybersecurity threats through our enterprise information security program." Let me apply the person-removal test: remove CISO and CIO references. What remains? "We primarily assess, identify and manage material risks from cybersecurity threats through our enterprise information security program." That's generic process language. The paragraph is really about WHO maintains and oversees the program - MR.

Actually, applying the person-removal test confirms it: strip out the CISO and EVP/CIO roles and you're left with generic risk management language that lacks substance. The specificity comes entirely from those firm-specific roles, making this a Level 3 classification.


reasoning: The paragraph centrally addresses how the company manages third-party vendor cybersecurity risk—evaluating internal controls, reviewing vendors with access to customer information/network, and imposing contractual confidentiality obligations. This is vendor oversight as the central topic → TP. The language is entirely generic ('carefully evaluated,' 'appropriate controls and mechanisms,' 'safeguard confidential information') with no domain-specific terms, firm-specific facts, or verifiable claims.

thinking: Third-party vendor oversight is the central topic.


reasoning: The paragraph contains a backward-looking materiality assessment ('we do not believe we have...experienced a cybersecurity incident that materially affected our business, our business strategy, our results of operations or financial condition'), which per Rule 5 drives the category to Strategy Integration. The remainder is generic risk description and a cross-reference to Item 1A. No domain terms pass the ERM test (information theft, extortion, reputational risk are all general business concepts), the negative materiality assertion is not externally verifiable, and no firm-specific facts are present, leaving specificity at Level 1.

thinking:
Let me analyze this paragraph.

The paragraph discusses cybersecurity risks faced by Moelis & Co, describes the threat landscape, includes a materiality assessment ("we do not believe we have...experienced a cybersecurity incident that materially affected our business"), and cross-references Item 1A.

Category: The key statement is the materiality assessment - "we do not believe we have...experienced a cybersecurity incident that materially affected our business, our business strategy, our results of operations or financial condition." Per Rule 5, this is a backward-looking materiality conclusion → Strategy Integration.

But most of the paragraph is generic risk description.

The materiality assessment is the most substantive disclosure here. Actually, let me reconsider - the paragraph is mostly about risks and threats, but contains the SI materiality statement. Per Rule 5, stating a conclusion about whether cybersecurity has affected business outcomes → SI.

For specificity, the materiality statement "we do not believe we have...experienced a cybersecurity incident that materially affected..." is a negative self-assertion that's not externally verifiable. There are no domain-specific terms that pass the ERM test, no firm-specific facts beyond generic language. This is Level 1 - Generic Boilerplate.

The threats listed - information theft, destruction, extortion - are all generic, and "work-from-home workforce" isn't domain-specific either. No domain terms passing the ERM test here either. Level 1.


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


reasoning: This paragraph is a cross-reference to Item 1A Risk Factors with no substantive cybersecurity disclosure, making it N/O. No specific facts of any kind are present.


fact: Director of Information Security (Director-level title with security qualifier)

fact: over 30 years of experience in IT and information security

fact: CISSP certification

fact: OD Technology Department

fact: Risk Committee

fact: prevention, detection, mitigation and remediation monitoring

fact: incident response and recovery plans

reasoning: Applying the person-removal test, substantial program content remains: multidisciplinary teams deployed, programs to protect systems, real-time monitoring of prevention/detection/mitigation/remediation, incident response plans — making this RMP over MR despite the Director's qualifications. Specificity reaches Level 4 via the verifiable CISSP certification and the lower-bound 'over 30 years' claim.

thinking:
Let me analyze this paragraph.

Category: The paragraph starts with the Director of Information Security's qualifications, then describes program activities (protecting systems, incident response), team deployment, and monitoring activities. Using the person-removal test: remove the Director of Information Security's qualifications and role - there's still substantial content about programs, teams, monitoring, prevention/detection/mitigation/remediation. So RMP. But wait - there's significant content about the Director's qualifications (30 years, CISSP) and role, reporting to Risk Committee. Let me re-read...

The paragraph has the Director as grammatical subject but describes what the program does (implemented programs, multidisciplinary teams deployed, monitors prevention/detection/mitigation/remediation).

Per Rule 2, the bulk of the content focuses on program activities rather than the individual's qualifications, so this leans toward RMP. The Director's background is present but secondary to what the program actually does.

For specificity, "Director of Information Security" is a firm-specific title at the director level, and the credentials like 30+ years in IT/infosec and CISSP certification are all verifiable details that add precision.


reasoning: The paragraph describes the company's risk assessment methodology (identification, likelihood/damage evaluation, sufficiency review), answering 'what does the cybersecurity program do?' → RMP. All language is standard ERM terminology ('periodic risk assessments,' 'reasonably foreseeable internal and external risks,' 'likelihood and potential damage') that any enterprise risk professional would use — no cybersecurity domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Describes risk assessment process - periodic risk assessments, identification of threats, likelihood/damage assessment, sufficiency of existing controls. This is about what the cybersecurity program does → RMP.

Specificity: Let me scan for facts.
- "periodic risk assessments" - generic
- "identification of reasonably foreseeable internal and external risks" - generic risk management language
- "likelihood and potential damage" - generic
- "sufficiency of existing policies, procedures, systems, and safeguards" - generic

This is all standard risk management language that any ERM professional would use. No domain-specific terms, no firm-specific facts, no verifiable claims.

Level 1.


reasoning: The paragraph's central topic is how the company manages cybersecurity risks from third-party vendors—listing its vendor management process, risk assessments, security questionnaires, and contractual obligations imposed on providers—making Third-Party Risk the clear category. Despite the length, the language stays at a generic process-description level ('risk assessments,' 'security questionnaires,' 'review of vendor security programs') that any ERM professional could write without cybersecurity domain expertise; no specific frameworks (e.g., SOC 2), tools, or firm-unique details are mentioned.

thinking:
Vendor/third-party risk management is the central topic here.

Facts: vendor management process details, security questionnaires, risk assessments, review of vendor security programs, contractual obligations. The paragraph describes requirements imposed on vendors and how the company manages third-party cyber risk.

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

Specificity: "security questionnaires", "risk assessments", "review of vendor security programs", "review of available security assessments, reports, and audits" - these are process descriptions. Do they pass the ERM test? "Security questionnaires" is somewhat domain-specific.

The language here is fairly standard vendor management terminology that most ERM professionals would recognize. Terms like security questionnaires and vendor risk assessments are broadly used across industries, and the paragraph describes these processes in general terms without demonstrating specialized cybersecurity expertise. I'd classify this as Level 1 - it covers what the company does but doesn't reveal deep domain knowledge.

No mention of specific security frameworks or standards like NIST or SOC 2 either, which would indicate more sophisticated security thinking. This confirms it's Level 1.


reasoning: The paragraph describes how the Board and Audit Committee receive cybersecurity reports from management, including incident updates — squarely answering how the board oversees cybersecurity. No domain-specific terminology, firm-specific facts, or verifiable claims are present; 'Audit Committee' is generic and the reporting language is standard boilerplate.

thinking:
Classify this paragraph.

Category: Board/Audit Committee receiving reports from management about cybersecurity risks and incidents. This is about how information flows to the board → Board Governance.

Specific facts: "Audit Committee" is generic (every company has one), not firm-specific. No domain terms that pass ERM test. No firm-specific or verifiable facts. This is generic oversight language.

Specificity: Level 1 - Generic Boilerplate.


reasoning: The paragraph describes the company's information security program as integrated and cross-functional, which answers 'what does the cybersecurity program do?' making it RMP, though it's more aspirational framing than substantive process description. No domain-specific terms pass the ERM test — 'information security program,' 'cross-functional approach,' and 'fully integrated' are all generic language any business professional could write.

thinking:
Classify this paragraph.

Content: Talks about having a "comprehensive and trustworthy information security program" that is "fully integrated into our operations" with a "cross-functional approach." This is about the cybersecurity program generally - RMP.

Specificity: No domain terms that pass the ERM test. "Information security program," "cross-functional approach," "integrated into operations" - all generic. No firm-specific facts, no verifiable claims.

Level 1.


fact: security assessments of providers before engagement

fact: Chief Information Security Officer (CISO)

fact: security specialists

reasoning: The paragraph's central topic is how the company oversees and manages cybersecurity risks from third-party service providers, including pre-engagement assessments and ongoing compliance monitoring, making it Third-Party Risk. The mention of the CISO as a named VP-level role elevates specificity to Firm-Specific.

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

Facts: CISO mentioned (firm-specific), security assessments, compliance monitoring.

Category: Third-Party Risk - central topic is managing third-party cyber risks.

Specificity: CISO is a firm-specific named role → Level 3.


fact: Senior Manager of Enterprise IT Security Risk and Compliance team leads cybersecurity program

fact: Reports to Managing Director of Enterprise IT

fact: Over 30 years of IT experience

fact: Over 20 years specializing in cybersecurity

reasoning: The paragraph centers on who leads the cybersecurity program, their reporting line, qualifications, and which executives receive updates — all management organizational content (MR). The person-removal test leaves only generic program language. Specificity reaches Level 4 via verifiable lower-bound experience claims ('over 30 years of IT experience,' 'over 20 years specializing in cybersecurity').

thinking:
Let me analyze this paragraph.

Category: This describes management roles - the Senior Manager leading the cybersecurity program, reporting lines, qualifications, and who receives updates. The person-removal test: remove the Senior Manager's title, experience, reporting line - what remains? "how cyber risks are identified and assessed and how the company prepares for, detects, responds, and recovers from cyber threats" and "Quarterly cybersecurity program updates and as-needed reporting on cybersecurity incidents are provided to" executives. The program description is generic. The primary focus is on the management organizational structure and the person's role/qualifications. → MR

Specificity:

Now I'm breaking down the specific elements. The Senior Manager title is firm-specific with a security qualifier, though it's below VP level. The Managing Director of Enterprise IT is also firm-specific. The experience metrics are quantified and verifiable - over 30 years in IT and over 20 years in cybersecurity specifically. The quarterly reporting cadence is generic, and the executive recipients (CEO, COO, CFO) are standard. Counsel → generic roles

Wait - "Senior Manager" is below VP level. The rules say firm-specific includes "cybersecurity leadership roles at VP level or above" and "Director-level titles WITH a security qualifier." Senior Manager is below Director level. However, this is a specific titled role unique to this company - "Senior Manager of Enterprise IT Security Risk and Compliance team" - that's quite distinctive. Actually, let me re-read the rules more carefully.

The rules list specific title levels. "Senior Manager" doesn't qualify under the named_role firm-specific criteria. But "Managing Director of Enterprise IT" - "Managing Director" could be considered VP-level equivalent. Actually the rules say "VP/SVP/EVP of IT, VP/SVP/EVP of Information Technology" - Managing Director isn't listed but is often equivalent to VP or above.

"Managing Director of Enterprise IT" likely qualifies as firm-specific given it's a VP-equivalent title with IT scope. Regardless, the quantified experience claims like "over 30 years" and "over 20 years" are verifiable lower bounds that push this to Level 4.


fact: Board's Cybersecurity Special Committee

fact: information security team with assistance from legal team

reasoning: The paragraph primarily describes the company's incident response and breach management process (four-step lifecycle, severity-based prioritization), which survives the person-removal test as a substantive program description → RMP. The 'Cybersecurity Special Committee' is a named non-generic board committee that distinguishes this company, elevating specificity to Firm-Specific.

thinking:
Classify this paragraph.

Category: Describes incident response process steps and how they manage incidents. The person-removal test: remove "information security team", "legal team", "Board's Cybersecurity Special Committee" - substantive process description remains. → RMP.

Specific facts:
- Four-step incident response process (generic IR lifecycle, not domain-specific enough)
- "information security team" - not VP+ level
- "legal team" - generic
- "Board's Cybersecurity Special Committee" - named non-generic committee → firm-specific

- "incident response and breach management processes" - generic terminology
- The four phases align with standard NIST IR framework concepts but aren't explicitly referenced that way
- "Detecting and analyzing", "containing, eliminating and recovering" are standard IR phases
- The Board's Cybersecurity Special Committee is the firm-specific element that pushes this toward Level 3
- "Information security team" is a generic team name


reasoning: This paragraph is a general statement about reliance on technology and associated security risks, without describing any specific cybersecurity program, governance structure, or measures — it serves as an introductory framing paragraph. No domain terminology, firm-specific facts, or verifiable claims are present.

thinking: Simple classification task.


reasoning: The paragraph describes how the board oversees cybersecurity risk and delegates to the audit committee, directly answering the board governance question. All language is generic ERM terminology (risk oversight, risk management practices, prevention/detection/mitigation) with no domain-specific terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity risks, delegation to audit committee. This is Board Governance.

Specificity: Let me scan for facts.
- "audit committee" - generic, every company has one → not firm-specific
- "general partner's board of directors" - generic governance structure
- No domain terms that pass the ERM test - "cybersecurity incidents", "risk oversight", "risk management practices" are all generic ERM language
- No named roles, no verifiable facts

This is Level 1 - Generic Boilerplate.


fact: cybersecurity risk assessment prior to onboarding vendors

fact: digital controls to monitor third-party access reviewed at least annually

fact: Onex Corp. named as parent conducting vendor oversight

reasoning: The entire paragraph describes how third-party vendor cybersecurity risks are assessed, monitored, and contractually managed, making TP the clear category. Naming Onex Corp. as the specific entity conducting vendor oversight elevates this to Firm-Specific, though the vendor management practices themselves are fairly standard.

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


reasoning: The paragraph primarily describes who (CEO, CFO) is responsible for incident response oversight and their decision-making authority, with board notification as a secondary element — applying the person-removal test, the remaining process description is thin. No domain terms pass the ERM test ('incident response procedures,' 'evaluate, mitigate, and remediate' are generic risk management language), and CEO/CFO/Board of Managers are generic governance roles present at every entity, yielding Level 1.

thinking:
Analyzing this paragraph about Greystone Housing Impact Investors LP.

Category: This describes incident response procedures and who oversees them (CEO, CFO), notification flows, and board notification. The primary question answered is "How is management organized to handle cybersecurity?" — it describes roles (CEO, CFO) and their responsibilities in incident response, plus reporting lines to the Board of Managers. But it also describes incident response procedures (RMP). Let me apply the person-removal test: remove CEO, CFO, Board of Managers references — what remains? "incident response procedures...

The remaining content focuses on notification requirements and resource allocation during incidents. So the paragraph really centers on management's role in incident response — specifically the CEO and CFO's responsibilities for overseeing procedures, determining resource needs, and ensuring the Board gets notified of material incidents. The governance structure (Board → CEO/CFO → incident response) is integral to what's being described, making this fundamentally about management's oversight role rather than just procedural steps. The partnership structure and incident response language are all generic boilerplate without any firm-specific details or domain expertise — this is clearly Level 1.


fact: Chief Operating Officer oversees cybersecurity policies and processes

reasoning: The paragraph identifies the COO as the management-level owner of cybersecurity, making it about management's organizational role (MR). The COO is a VP-or-above title whose portfolio here includes cybersecurity, making it a firm-specific fact, but no verifiable claims push it to Level 4.

thinking:
Classify this paragraph.

Content: COO oversees cybersecurity policies and processes, with a reference to another section.

Category: This is about who oversees cybersecurity at the management level - the COO's role. It's MR.

Specific facts: "Chief Operating Officer" - this is a C-suite role with cybersecurity responsibility. But COO is not a cybersecurity-specific title. Wait - the rules say "generic governance roles that exist at every company (Board, Audit Committee, CEO, CFO, General Counsel)" are NOT firm-specific. COO isn't listed there explicitly, but it's similarly generic.

The tension here is that COO is a generic C-suite title like CEO or CFO, but the rules specifically flag cybersecurity leadership roles at VP level and above as firm-specific - and COO definitely qualifies as that level. Since COO isn't inherently a cybersecurity role and isn't on the firm-specific list like CISO or CIO would be, I'm leaning toward this being generic governance rather than firm-specific.

Actually, wait - the rule does say "any VP-or-above title whose portfolio includes IT, cybersecurity, or information security," and this COO explicitly oversees cybersecurity. That matches the criteria, so this should count as firm-specific after all.


fact: Service Organization Controls (SOC) reports used to develop self-attestation questionnaires

reasoning: The paragraph's central topic is how third-party vendors are vetted, contractually obligated, and monitored for cybersecurity—squarely Third-Party Risk. SOC reports are a domain-specific framework reference that passes the ERM test (a generic risk manager wouldn't naturally reference SOC attestations), elevating to Level 2. The Vendor Management team and information security resources are generic enough to not qualify as firm-specific.

thinking:
Classify this paragraph.

Content: About how third-party vendors are managed for cybersecurity. Due diligence, questionnaires, SOC reports, contractual requirements, ongoing monitoring. Central topic is third-party risk management.

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

Specific facts:
- SOC reports (domain term / framework)
- Self-attestation questionnaires (process but generic)
- Vendor Management team (named_team - firm-specific? It's a generic team name but specific to this company's structure)

- "dedicated information security resources" and "vendor management office" are also mentioned but similarly generic

The key specificity marker here is SOC reports—that's a concrete domain term referencing a recognized security audit standard, which pushes this to Level 2. The team names are borderline since they're generic titles even if they're firm-specific in structure. Overall, I'd classify this as Level 2 based on the SOC framework reference.


fact: Incident detected in early April 2023

reasoning: The paragraph describes a real cybersecurity incident — its detection, timeline, investigation, and response actions — making it clearly Incident Disclosure. 'Early April 2023' is a specific, externally verifiable timeframe tied to a real event (AvidXchange's publicly reported breach), elevating specificity to Quantified-Verifiable.

thinking:
Incident disclosure - describes a real event with timing, detection, and response actions.

Specific facts: "early April 2023" is a specific date, "leading cybersecurity experts" is generic (unnamed), "law enforcement" is generic. Detection method: "routine security monitoring protocols" - not really domain-specific beyond generic.

"early April 2023" - this is a specific date tied to a real incident, verifiable.

Wait - "early April 2023" - is this specific enough? It's not an exact date but it's a timeframe tied to a real event. It's verifiable in the sense that AvidXchange did disclose an incident around that time.

The "early April 2023" timeframe counts as specific since the incident was publicly disclosed and can be confirmed, which pushes this to Level 4, though the detection method remains generic.


reasoning: The paragraph describes the Board's oversight role over risk management, its delegation to committees, and management's responsibility for assessing risk — answering how the board oversees cybersecurity, placing it in Board Governance. No domain-specific terminology, firm-specific facts, or verifiable claims appear; the language is entirely generic enterprise risk oversight that any ERM professional could write.

thinking:
Classify this paragraph.

This is about board oversight of risk management generally - not cybersecurity-specific. It describes the Board's role in risk oversight, CEO and senior management's responsibility, and standing committees.

Category: This is about board oversight structure → Board Governance. Though it's general enterprise risk, it's in Item 1C (cybersecurity section).

Specificity: Let me check for specific facts. "CEO" is generic. "Board's standing committees" - generic. No domain terms, no firm-specific facts, no verifiable claims. This is generic boilerplate about enterprise risk oversight.

So this lands at Level 1 - Generic Boilerplate.


reasoning: The paragraph describes what the cybersecurity program does — incident response planning, severity evaluation, and law enforcement engagement — making it RMP. The vocabulary is entirely generic process language (incident response plan, prioritization guidelines, communication channels, severity scale); none of these terms pass the ERM test, as a non-security risk professional could describe any operational incident plan in identical terms.

thinking:
Classify this paragraph.

Content: Describes incident response plan details - prioritization guidelines, data collection, evidence handling, communication channels, law enforcement engagement, severity-based evaluation.

Category: Risk Management Process - describes what the cybersecurity program does (incident response planning, security operations).

Specificity: Let me check for specific facts.
- "incident response plan" - this is generic (L1)
- "prioritization guidelines, data collection and evidence handling, communication channels" - these describe components but are fairly generic
- "law enforcement engagement" - generic
- "evaluate security incidents on a scale of severity" - generic process description

The terms used here are general process descriptions.

"Incident response plan" is explicitly L1, and while "evidence handling" in a security context shows some domain awareness, the overall vocabulary—prioritization, data collection, communication channels, law enforcement engagement—reads like standard operational concepts that any ERM professional could describe. The components listed are fairly generic rather than domain-specific.


fact: CISO leads the corporate information security organization

fact: security engineering, cyber threat detection and response

fact: Certificate in Cybersecurity Oversight from the Carnegie Mellon University Software Engineering Institute

reasoning: The paragraph primarily describes the CISO's role, qualifications, and the corporate information security organization's responsibilities — applying the person-removal test, the remaining program description is secondary to the organizational/leadership focus, making this MR. The Carnegie Mellon University Software Engineering Institute certificate in Cybersecurity Oversight is an externally verifiable credential tied to a named institution, elevating specificity to Level 4.

thinking:
Let me analyze this paragraph.

Category: The paragraph describes the CISO's role, qualifications, and the corporate information security organization's responsibilities. The person-removal test: removing CISO, their experience, Carnegie Mellon certificate — there's still content about what the organization does (security strategy, policy, engineering, operations, threat detection, enterprise security structure, employee culture). But the primary focus is on who leads the organization and their qualifications, plus the organization's role. This is primarily MR - it's about the management organization and leadership.

Specific facts:
- CISO (named role, firm-specific)
- "certificate in Cybersecurity Oversight from the Carnegie Mellon University Software Engineering Institute" — this is verifiable (named institution, specific certificate)

- The corporate information security organization and its functions are firm-specific, while the underlying domains like security engineering and cyber threat detection are standard industry terms. The Carnegie Mellon certificate is externally verifiable and specific, whereas "many years" lacks concrete verification, making the credential the more substantive claim.


fact: malware and computer virus attacks (specific threat types)

reasoning: The paragraph's core purpose is a backward-looking materiality assessment ('have not materially affected our business strategy, results of operations, or financial condition'), which is SI per Rule 5. Specificity reaches Level 2 via the mention of specific threat types (malware, computer virus attacks), which pass the ERM test as cybersecurity-domain vocabulary; the negative materiality assertion is not externally verifiable so does not reach Level 4.

thinking:
Classify this paragraph.

The paragraph discusses cybersecurity risks generally, mentions past threats (malware, computer virus attacks), and concludes with a materiality assessment. The key sentence is "such risks and threats have not materially affected our business strategy, results of operations, or financial condition to date" — this is a backward-looking materiality assessment → SI per Rule 5.

Specificity: The mention of "malware and computer virus attacks" — these are domain terms but fairly generic. Let me apply the ERM test: would a non-security ERM professional use "malware and computer virus attacks"? Actually, these are pretty commonly understood terms. But they are specific threat types.

"Malware" and "computer virus" are borderline on the ERM test — they're cybersecurity-specific but widely recognized enough that I'd classify them as domain-adapted rather than highly specialized. The materiality statement itself is a backward-looking SI assessment, though it's a negative self-assertion that isn't externally verifiable.

So: SI, Domain-Adapted.


fact: CISO role

fact: CPO (Chief Privacy Officer) role

fact: CIO role

fact: VP of Global IT Security role

fact: Certified Information Systems Auditor (CISA) certification

fact: Certified Information Systems Security Professional (CISSP) certification

fact: Fellow of Information Privacy (FIP) certification

fact: Certified Information Privacy Professional (CIPP) certification

fact: Incident Response team comprising cross-functional professionals globally

fact: Incident Response team meets weekly

reasoning: The paragraph primarily answers who leads cybersecurity and what qualifies them (CISO, CPO, CIO, VP of Global IT Security, their experience and certifications), making it Management Role. Specificity reaches Level 4 because it names independently verifiable certifications: CISA, CISSP, FIP, and CIPP, all confirmable through their respective issuing bodies.

thinking:
Let me analyze this paragraph.

Category: This is about management roles - CISO, CPO, CIO, VP of Global IT Security, their qualifications, certifications, and team structure. Person-removal test: remove names/titles/qualifications → little remains except the Incident Response team meeting weekly. The primary focus is on WHO leads cybersecurity and WHAT qualifies them. → Management Role.

Specific facts:
- CISO (named role, firm-specific)
- CPO (named role, firm-specific)
- CIO (named role, firm-specific)
- VP of Global IT Security (named role, firm-specific)

- CISA certification (verifiable)
- CISSP certification (verifiable)
- Fellow of Information Privacy (verifiable)
- CIPP certification (verifiable)
- Incident Response team (named team)
- Weekly meetings of Incident Response team

Specificity: The certifications CISA, CISSP, FIP, CIPP are all externally verifiable → Level 4.


reasoning: The paragraph describes how the Audit Committee and Board receive cybersecurity updates and engage with management on cybersecurity matters — squarely answering the board oversight question (BG). No domain-specific security terms, no firm-specific facts (Audit Committee is generic), and no verifiable claims — 'at least annually' is a generic cadence, and 'business continuity planning' fails the ERM test.

thinking:
Classify this paragraph.

This is about how the board oversees cybersecurity - Audit Committee engagement, Board meeting discussions, reporting to the Board. This is Board Governance.

Specific facts: "Audit Committee" - generic, every company has one. "at least annually" - generic cadence. "business continuity planning" - L1 term. No domain terms, no firm-specific facts, no verifiable claims.

This is Generic Boilerplate.


reasoning: This is a backward-looking and forward-looking materiality assessment stating that cybersecurity risks have not materially affected and are not reasonably likely to materially affect business strategy, results, or financial condition — squarely SI per Rule 5. No domain terms, firm-specific facts, or verifiable claims are present, so specificity remains Level 1.

thinking: Materiality assessment paragraph.


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

thinking: Cross-reference to risk factors, no substantive cybersecurity disclosure.


reasoning: The paragraph's central topic is assessing third-party service providers' security measures and breach reporting obligations, making Third-Party Risk the primary category. The language is entirely generic — 'appropriate security measures,' 'applicable laws,' 'suspected breach' — all terms any ERM professional would use, with no domain-specific terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: About assessing third-party service providers' security measures, compliance with laws, and breach reporting requirements. This is centrally about vendor/supplier cybersecurity oversight → Third-Party Risk.

Specificity: No domain terms that pass ERM test, no firm-specific facts, no verifiable claims. "security measures", "applicable laws", "suspected breach" — all generic ERM language.

Level 1.


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


reasoning: The paragraph answers 'what does the cybersecurity program do?' by describing processes to assess, identify, and manage risks, and noting the Investment Adviser's cybersecurity program covers the company — placing it in RMP. All language is generic ERM boilerplate ('processes to assess, identify, and manage material risks') with no domain terminology, named roles, or verifiable facts.

thinking:
Classifying this paragraph.

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

Category: This is about what the cybersecurity program does / how risks are managed. It's a high-level description of risk management processes. RMP.

Specificity: "processes to assess, identify, and manage material risks from cybersecurity threats" - generic ERM language (L1). "Investment Adviser" - this is somewhat firm-specific context (externally managed BDC).

The term "cybersecurity program" lacks domain-specific terminology or named leadership roles, and the reference to "Investment Adviser" is just a standard structural descriptor for BDCs rather than a concrete entity. This lands at Level 1.


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

thinking: Cross-reference to risk factors section.


fact: Completed merger with SomaLogic Operating Co, Inc.

fact: Merger completed in early 2024

fact: SomaLogic maintains ongoing ISO 27001 compliance certification

reasoning: Paragraph describes cybersecurity program integration activities following a merger (reviewing policies, procedures, tools), making it RMP. Specificity reaches Level 4 because SomaLogic's ongoing ISO 27001 compliance certification is an externally verifiable claim via certification bodies, and SomaLogic Operating Co, Inc. is a named firm.

thinking:
Let me analyze this paragraph.

Content: Describes merger with SomaLogic, review of cybersecurity policies/procedures/tools for integration, notes SomaLogic's ISO 27001 compliance certification.

Category: This is about what the cybersecurity program does in the context of a merger integration - reviewing policies, procedures, tools. It's describing program activities. RMP.

Specific facts:
- "SomaLogic Operating Co, Inc." - named firm
- "ISO 27001 compliance certification" - this is "ongoing ISO 27001 compliance certification" which suggests they maintain it → Quantified-Verifiable

- The merger occurred in early 2024, a specific event that triggered this integration work
- SomaLogic's ongoing ISO 27001 certification is verifiable through the certification body itself → Level 4


fact: Enterprise Risk Management Committee (management committee) oversees the program

fact: Committee membership includes CEO, CFO, COO, Chief Credit Officer, Chief Administrative Officer, CIO, and Chief Risk Officer

fact: Chief Information Officer (CIO) is a committee member

fact: Chief Risk Officer is a committee member

fact: Information Security Policy and Program (named internal program)

fact: Information Systems Audit performed by third-party firms

fact: Risk Oversight Committee reviews audit results

fact: penetration test (internal and external)

reasoning: The paragraph describes the ERM Committee's membership but primarily details program activities — IS audits, penetration testing, risk assessments, and oversight of the Information Security Policy and Program — so RMP wins the person-removal test. Specificity reaches Level 3 due to firm-specific details: named Enterprise Risk Management Committee with a distinctive seven-role membership, named Information Security Policy and Program, named Risk Oversight Committee, and CIO/CRO roles.

thinking:
Let me analyze this paragraph.

Content: Describes the Enterprise Risk Management Committee's composition and role in overseeing the Information Security Policy and Program, testing through audits, penetration testing, and risk assessments.

Category: This is a mixed paragraph. It describes a management committee (ERM Committee) with its membership, but then goes on to describe what the program does (testing, audits, penetration testing, risk assessments). Let me apply the person-removal test: if I remove the committee membership list, there's substantial content about IS audits, penetration testing, risk assessments. So RMP.

Wait - the ERM Committee is a management-level committee.

Per Rule 1, management-level committees → MR if about structure/membership, RMP if about activities. This paragraph covers both membership AND activities. The bulk of the text is about activities (testing, audits, penetration tests, risk assessments). → RMP.

The committee includes specific roles like CEO, CFO, COO, Chief Credit Officer, Chief Administrative Officer, CIO, and Chief Risk Officer. While most are standard C-suite positions, the Chief Credit Officer and Chief Administrative Officer suggest firm-specific composition. But since the paragraph emphasizes the activities—the Information Security Policy and Program, Information Systems Audit, and penetration testing—this is fundamentally about what the program does rather than just who's on the committee.

Looking at the specificity markers: the Enterprise Risk Management Committee with this particular membership composition is firm-specific, the Information Security Policy and Program is a named program, and the Risk Oversight Committee and Audit Committee are also named governance structures. The penetration testing is a domain term. Overall, this points to Level 3 specificity.


fact: Named board member Paresh Patel has information technology expertise

reasoning: The paragraph describes how the board receives cybersecurity reports and identifies a board member's IT expertise — both squarely about board oversight. Naming Paresh Patel as a specific board member with IT expertise is a firm-specific fact, elevating to Level 3.

thinking:
Classify this paragraph.

Category: Board oversight of cybersecurity - board receives reports, board member expertise. → Board Governance.

Specific facts:
- Named individual "Paresh Patel" → named person in cybersecurity context → firm-specific
- "information technology expertise" of a board member → firm-specific fact about board composition

No verifiable quantified claims (no specific numbers, certifications, etc.).

Specificity: Firm-Specific (Level 3)


reasoning: This is a cross-reference to Item 1A Risk Factors with no substantive cybersecurity disclosure — it points elsewhere and uses generic speculative language ('may materially affect'). No domain terms, firm-specific facts, or verifiable claims are present.


reasoning: This paragraph is introductory framing about being a potential cyberattack target and needing to address risks — it contains no substantive cybersecurity disclosure (no program details, no governance structure, no materiality conclusion). It uses entirely generic business language ('may be exposed,' 'ability to address these risks') with no domain terminology, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

This is generic language about being a potential target and needing to address cyber risks. No specific program, no specific facts, no materiality assessment conclusion. Pure introductory/contextual language.

Category: None/Other - this is generic introductory framing with no substantive disclosure.

Wait - does it answer any of the six questions? It's speculative/contextual ("may be a potential target", "may be exposed"). No concrete measures, no assessment conclusion. This is introductory framing.

Specificity: Generic Boilerplate (Level 1) - no domain terms, no firm-specific facts.


reasoning: The paragraph briefly mentions investing in cybersecurity, network resiliency, and adapting internal controls/processes to protect systems, which loosely describes program activities (RMP), though the second sentence is a pure cross-reference to Item 1A. Specificity is Level 1 because all language ('internal controls and processes,' 'protect our systems and infrastructure') is generic ERM language with no domain terms, firm-specific facts, or verifiable claims.

thinking:
Classify this paragraph.

Content: Investment in cybersecurity, network resiliency, internal controls/processes to protect systems. Plus a cross-reference to Item 1A.

Category: The first sentence is generic about investing in cybersecurity and adapting controls. The second sentence is a cross-reference. No specific program activities, no board governance, no management roles. The first sentence touches on RMP but is very generic. The cross-reference is N/O. Mixed - the first sentence is a generic statement about investing/adapting controls. It's borderline RMP/SI/N/O.

The investment language could fall under SI, while the controls mention is generic RMP. The cross-reference points toward N/O. There's minimal substantive content here—just vague statements about investing and adapting controls with no real detail. It's borderline RMP at best, but so thin it's almost a closing statement.

Looking at Rule 6, there is some actual cybersecurity measure described, even if generically. The phrase about investing in cybersecurity and adapting internal controls does constitute a disclosure, so I'll categorize it as RMP rather than N/O. On specificity, none of the terms—"cybersecurity," "resiliency," "internal controls," "protect systems"—pass the ERM test. This is clearly Level 1.


reasoning: The paragraph opens with a backward-looking materiality assessment ('we do not believe that our business strategy, results of operations or financial condition have been materially adversely affected by any cybersecurity incidents'), which is the defining marker for Strategy Integration under Rule 5. Specificity is Level 1 because the negative materiality assertion is not externally verifiable, and the remaining content uses only generic risk/investment language with no domain terms, firm-specific facts, or verifiable claims.

thinking:
Let me analyze this paragraph.

The paragraph starts with a materiality assessment ("we do not believe that our business strategy, results of operations or financial condition have been materially adversely affected"), which is a backward-looking SI statement per Rule 5. The rest discusses general cyber risk landscape and generic program language.

Category: Strategy Integration - the opening clause is a clear materiality assessment.

Specificity: The paragraph contains generic language. No domain terms that pass the ERM test, no firm-specific facts, no verifiable claims. "We do not believe that our business strategy, results of operations or financial condition have been materially adversely affected" is a negative self-assertion - not externally verifiable.

This is clearly Level 1 boilerplate with no substantive domain-specific language or company-specific details.


reasoning: The paragraph describes third-party service providers hired to assess and support the company's security program, which per Rule 3 makes this RMP (third parties serving the company, not vendor oversight). The language is entirely generic—'assess our information security program,' 'monitoring and supporting our control environment,' 'breach notification and response processes'—all terms a non-security ERM professional could naturally use, yielding Level 1.

thinking:
Classify this paragraph.

Content: Third-party service providers assessing their security program, monitoring, supporting control environment and breach response. These are third parties hired to serve the company (assessors) → RMP per Rule 3.

Specificity: No domain terms that pass ERM test beyond generic language. "Information security program," "cyberthreat landscape," "control environment," "breach notification and response processes" - these are fairly generic. "Breach notification" is somewhat domain-adjacent but an ERM professional could use it. Let me check more carefully.

The terminology here is generic enough that a non-security ERM professional could reasonably use it, so I'm classifying this as Level 1 - generic boilerplate.