fact: Security Operations Center (SOC)

fact: Security Information and Event Management (SIEM) systems

fact: 24x7 SOC operation

fact: continuous network monitoring

fact: real-time threat response

reasoning: The paragraph describes what the cybersecurity program does—operating a SOC and deploying SIEM systems for continuous monitoring. These are specific security operations practices that demonstrate cybersecurity domain expertise beyond generic risk management language. The use of SOC and SIEM terminology (specific to cybersecurity) passes the ERM test, as a non-security ERM professional would not naturally use these terms.


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph describes what the cybersecurity program does (identify, monitor, mitigate risks; continuous monitoring; quarterly expert updates) rather than who is responsible or how management is organized, making it primarily about the risk management process. The specificity is Generic Boilerplate because while the IT Steering Committee is named, it is not a distinguishing identifier (every company has steering committees), all practices mentioned are generic cybersecurity activities any company could claim (continuous monitoring, vulnerability assessment, attack vector analysis), no hard numbers or verifiable facts are present, and no named leadership roles or externally verifiable credentials appear.

provider: minimax

stage: benchmark


content_category: None/Other

reasoning: This paragraph explicitly states the company has no business operations, no cybersecurity risk management program, and no formal cybersecurity risk assessment processes—providing no substantive cybersecurity disclosure. The negative assertion about incidents and risk level are not Incident Disclosure or Strategy Integration under the rules (negative self-assertions about absence are not externally verifiable incident descriptions). The paragraph contains zero specific facts about any cybersecurity program, governance structure, or risk management activity. All assertions are generic SPAC boilerplate with no domain terminology, firm-specific details, or verifiable claims.


content_category: Board Governance

reasoning: This paragraph describes the board's oversight structure for cybersecurity—specifically how management (Director of Internal Audit, CFO) informs the Board, the cadence of briefings (minimum once per year), and the Board's role in strategic decisions and annual reviews. It answers 'How does the board oversee cybersecurity?' making Board Governance the appropriate category. The specificity is Generic Boilerplate because all roles mentioned (Director of Internal Audit, CFO, Director of Information Technology) are standard executive titles present at any public company, the governance mechanisms described (regular briefings, ongoing dialogue, annual review) are generic structures that any company could claim, and no domain-specific cybersecurity expertise is demonstrated beyond using the word 'cybersecurity' itself.


reasoning: The paragraph describes the company's cybersecurity risk assessment methodology (periodic assessments, components of assessments), which directly answers what the cybersecurity program does → RMP. However, all terminology used (risk assessment, internal/external risks, likelihood and potential damage, policies, procedures, safeguards) is generic ERM language that applies to any risk domain. Swapping 'cybersecurity' for 'financial' or 'operational' yields identical phrasing — no cybersecurity domain expertise is demonstrated. No firm-specific facts, no named frameworks, no specific tools or practices → Level 1.


reasoning: This paragraph is a cross-reference directing readers to Item 1A for cybersecurity risk information. It contains no substantive disclosure about any of the six substantive categories—no governance description, no management organization, no program activities, no incident details, no materiality assessment. The only content is a generic risk acknowledgment and a pointer to another section.


reasoning: The paragraph describes board-level cybersecurity oversight, specifically the delegation of oversight to the Audit Review Committee (ARC) and the ARC's review responsibilities. This is a governance-chain paragraph directly answering how the board oversees cybersecurity. For specificity, the paragraph contains only generic governance language (oversight, review, controls, procedures) that any public company could use—'internal controls over financial reporting' is a standard audit term that fails the ERM test. The 'ARC' acronym is company-specific in naming but the committee's described functions (reviewing cybersecurity risks, controls, plans, and incident response) are standard audit committee responsibilities found at virtually all public companies. No domain expertise, firm-specific distinguishing facts, or verifiable claims are present.


content_category: Incident Disclosure

fact: Form 8-K filed on February 29, 2024 (specific date of required SEC disclosure)

fact: MOVEit Cybersecurity Incident (named, identifiable real-world incident)

fact: PBI (named third-party entity involved in incident)

fact: Approximately 2.5 million to 2.7 million policyholders' or other customers' personal information exposed (hard number range)

fact: Personal information included social security numbers (specific data type)

reasoning: The paragraph primarily describes an actual cybersecurity incident—the MOVEit breach—including the investigation, scope (2.5-2.7 million individuals), data types exposed, and impact assessment, making it Incident Disclosure. The specificity reaches Level 4 because the paragraph contains externally verifiable claims: a specific SEC filing date (February 29, 2024), a named incident (MOVEit), a named third party (PBI), and a quantified victim count range—all facts that could be independently confirmed.


content_category: Management Role

fact: IT Risk and Compliance Team

fact: VP Security

reasoning: The paragraph describes organizational structure and reporting relationships (IT Risk and Compliance Team reporting to VP Security), which directly answers how management is organized to handle cybersecurity, making this Management Role. The VP Security (a VP-level role with security qualifier) and named IT Risk and Compliance Team are firm-specific facts that distinguish this company's cybersecurity leadership structure.


fact: Information Security Officer

fact: Chief Information Officer

fact: mandatory training requirements

reasoning: The paragraph describes management-level roles (ISO and CIO) and their training responsibilities, which maps to how management is organized to handle cybersecurity. However, the content uses only generic terminology (mandatory training, processes, procedures, technical requirements) that any company could state — no domain-specific security concepts (ERM test passes: any ERM professional could write this about any compliance training), no named committees or programs, and no verifiable claims. The specific role titles alone do not elevate specificity since they exist at virtually every financial institution.


reasoning: This paragraph is a general risk-factor introduction describing the company's reliance on secure information processing and stating that cybersecurity threats are increasing. It contains no substantive description of actual cybersecurity governance, management structure, risk management processes, or specific incidents — only speculative language about potential future threats. The third-party mention is incidental context, not a description of how the company manages third-party cyber risks. The specificity is Level 1 because the paragraph contains no domain-specific practices, firm-specific organizational facts, or externally verifiable claims.


reasoning: The paragraph describes general business systems (accounting software, CRM, POS, etc.) and notes confidential information collection, but does not describe any actual cybersecurity measures, controls, or processes — it is a business operations overview rather than a cybersecurity disclosure. No domain-specific security practices, tools, or methodologies are mentioned, and no facts distinguishing this company's cybersecurity posture appear.


content_category: Third-Party Risk

category_confidence: medium

reasoning: The paragraph focuses on third-party vendor/customer oversight, clearly meeting Rule 3's TP criteria. However, it contains only generic security assessment language with no domain-specific terminology, firm-specific identifiers, or verifiable claims — making it pure boilerplate at Level 1.


fact: insider threat controls

fact: tools to alert on suspicious or unusual insider activity

fact: data loss prevention controls

reasoning: The paragraph describes what the cybersecurity program does—specifically insider threat controls, alerting tools, and data loss prevention measures—making RMP the appropriate category. The specificity is Domain-Adapted because the paragraph demonstrates cybersecurity domain expertise through specific security practices ('insider threat controls,' 'tools to alert on suspicious activity,' 'prevent data loss') that a general ERM professional would not naturally use without cybersecurity context. No firm-specific facts (named roles, specific committees) or externally verifiable claims (certifications, named third parties, specific dates/numbers) are present.


reasoning: The paragraph is primarily a forward-looking disclaimer acknowledging cybersecurity risks and cross-referencing Risk Factors, rather than describing a substantive cybersecurity process, role, or incident. While it mentions monitoring and disaster recovery in passing, these are incidental to the main purpose of risk acknowledgment and liability limitation. No firm-specific facts (e.g., named roles, specific team composition, named programs), domain-expertise terminology beyond generic threat types, or externally verifiable claims are present.


fact: June 2024 - specific incident date

fact: CDK - named third-party provider involved in incident

reasoning: The paragraph's primary purpose is describing a real cybersecurity incident (CDK breach in June 2024), including timing, nature, and impact, making it Incident Disclosure. Specificity reaches Level 4 because 'June 2024' and 'CDK' are externally verifiable facts — a reviewer could independently confirm the incident occurred and which third party was involved.


reasoning: This paragraph explains why KVAC lacks cybersecurity risk to disclose—explicitly stating it has no operations and therefore no material cybersecurity threats—which directly answers none of the six substantive questions. The specificity is Generic Boilerplate because a SPAC with no operations provides no facts about cybersecurity practices, roles, tools, or any verifiable claims.


content_category: Strategy Integration

reasoning: The paragraph makes a materiality assessment about whether cybersecurity threats have affected or are reasonably likely to affect the company's business strategy, results of operations, or financial condition — the defining question of Strategy Integration. However, it contains zero specific facts: it is a standard cross-reference plus boilerplate negative assertion, with no domain terminology, firm-specific details, or verifiable claims.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors, with only a brief, generic acknowledgment that the company faces cybersecurity and data leakage risks. It contains no substantive cybersecurity disclosure—no governance structure, management role, program description, or incident information. Per Rule 6, with no actual cybersecurity measure, process, or assessment described, this is None/Other. The generic language ('increasingly dependent on information technology,' 'face certain risks') contains no domain-specific terminology, firm-specific facts, or verifiable claims, making it Generic Boilerplate.


reasoning: This paragraph primarily consists of a negative assertion about cybersecurity materiality combined with a cross-reference to Item 1A risk factors where the substantive cybersecurity risk disclosure is actually located. The dominant function is pointing readers elsewhere rather than providing any substantive cybersecurity disclosure in Item 1C itself. No specific facts, domain expertise, firm-specific details, or verifiable claims are present.


reasoning: The paragraph describes how the company manages third-party cybersecurity oversight—obtaining reports and conducting ongoing monitoring—placing it squarely in Third-Party Risk. However, all language is generic boilerplate: 'obtain reports,' 'ongoing monitoring,' and 'ensure compliance' are standard ERM phrases that could describe any risk category. No specific facts, named third parties, certifications, or verifiable claims are present, making this Level 1.


reasoning: The paragraph primarily addresses whether cybersecurity risks could affect business outcomes (SI) through its forward-looking disclaimer, though it opens with a brief description of implemented security measures (privileged access policies, MFA) that could suggest RMP. For specificity, the security measures named are generic domain practices without firm-specific implementation details, and the business-impact statement is standard boilerplate disclaimer language that appears across virtually all 10-K filings—no verifiable facts, named programs, or quantifiable claims present.


reasoning: The paragraph's first sentence is a backward-looking negative assertion about the absence of material cybersecurity incident effects on business outcomes, which directly answers 'how has cybersecurity affected business/financial outcomes?' (→ SI per Rule 5). The remaining content is standard speculative disclaimers about future incidents and a cross-reference to Risk Factors (→ N/O). For specificity: the negative assertion 'have not experienced' is a self-reported claim, not independently verifiable (per Rule 4 QV section: 'we did not experience a material incident' is NOT QV). No domain terminology (ERM test: 'cybersecurity incident', 'threat actors', 'information technology systems' are generic terms any ERM professional would use), no firm-specific facts, and no verifiable claims — all text is boilerplate.


reasoning: This paragraph is a general risk acknowledgment statement with no substantive disclosure about governance structures, management roles, cybersecurity processes, or specific incidents—it simply states that cybersecurity threats pose risks to various business elements. The paragraph contains no specific facts, domain terminology, firm-specific claims, or verifiable information; it is pure boilerplate applicable to any public company's cybersecurity disclosure.


reasoning: This paragraph is a glossary definition of 'cybersecurity threat' — it establishes terminology rather than describing any substantive aspect of the company's cybersecurity program, governance, or incidents. It answers no question from the six substantive categories. Specificity is Level 1 because the paragraph contains no domain expertise (beyond the universally known CIA triad), no firm-specific facts, and no verifiable claims.


fact: December 2022 — specific date of cybersecurity incident discovery

reasoning: This paragraph describes an actual cybersecurity incident with timeline, scope (personal data of employees extracted), and response actions, making it Incident Disclosure. The specific date 'December 2022' is an externally verifiable fact about when the breach occurred, elevating specificity to Level 4.


reasoning: This paragraph is a backward-looking negative assertion about whether cybersecurity threats have materially affected the company's business outcomes, making Strategy Integration the appropriate category per Rule 5. It contains no specific facts whatsoever — only a generic statement that no material cybersecurity incidents have occurred — resulting in Level 1 specificity (Generic Boilerplate).


reasoning: The paragraph describes the Audit Committee's oversight activities—periodic discussions with management and an annual review of the cybersecurity program. These are board-level oversight actions, making Board Governance the appropriate category. The paragraph contains no firm-specific facts (Audit Committee and annual/periodic cadences are universal to public companies) and no cybersecurity domain expertise beyond generic terms like 'identify and detect threats' that any ERM professional could use.


reasoning: The paragraph primarily answers 'Does cybersecurity materially affect the business?' through the negative assertion that the company is unaware of material risks from cybersecurity threats. The confidentiality framework language is generic boilerplate that lacks domain-specific detail — 'confidentiality agreements' and 'document management regulations' are standard business practices any company could claim, not cybersecurity domain expertise (ERM test: an ERM professional would naturally use this language). The materiality statement is a negative self-assertion that cannot be independently verified by an external party. No firm-specific facts, named roles, specific programs, or verifiable claims are present.


reasoning: The paragraph describes having an incident response plan/policy and mandatory annual employee training — these are generic cybersecurity program elements. Applying the ERM test, the language ('incident response plan,' 'annual training') is not specific to cybersecurity expertise; any enterprise risk management professional could describe compliance training in equivalent terms. No domain-specific security vocabulary (SIEM, SOC, EDR, NIST CSF, zero trust), no firm-specific facts (named roles, specific team size, named programs), and no verifiable claims (certifications, named assessors, specific dates) are present. This is standard boilerplate that could appear in any company's disclosure.


reasoning: This paragraph is centrally about third-party vendor oversight—describing due diligence processes, continuous monitoring, and scheduled meetings with managed service providers and CIO firms—which maps directly to the TP question of how third-party cyber risks are managed. However, the specificity is Level 1 because all terminology ('comprehensive due diligence checks,' 'continuous monitoring,' 'incident response protocols,' 'industry best practice') consists of generic business risk management language that any ERM professional could use; no domain-specific cybersecurity terms, named frameworks, specific tools, named third parties, or quantified metrics appear in the paragraph.


reasoning: The paragraph explicitly addresses third-party risk management (security assessments of providers, ongoing monitoring, compliance with cybersecurity standards), making 'Third-Party Risk' the primary category. However, all content consists of generic, non-specific descriptions of processes ('thorough security assessments,' 'ongoing monitoring') that lack any domain-specific terminology, named frameworks, or verifiable details — every public company could write identical language.


fact: Senior Director of Information Technology is responsible for implementing and maintaining cybersecurity risk assessment and management processes

fact: Senior Director of Information Technology has experience in roles responsible for securing networks and application systems

specificity_confidence: medium

reasoning: This paragraph primarily describes the organizational structure for cybersecurity management—who holds responsibility, their qualifications, and their specific duties—answering 'How is management organized to handle cybersecurity?' → Management Role. The specificity is Firm-Specific because the Senior Director of Information Technology role, with its specific cybersecurity experience description, distinguishes this company's management structure from generic governance language; while 'CEO,' 'CFO,' 'General Counsel,' and 'Audit Committee' are standard corporate roles, the Senior Director title with security-accountable responsibilities meets the firm-specific threshold.


reasoning: The paragraph describes maintaining information security processes to identify, assess, and manage cybersecurity risks (RMP), but all language is generic boilerplate that any ERM professional could write. Swapping 'cybersecurity' for 'financial' or 'operational' yields identical phrasing. No domain-specific security tools/practices, named frameworks, team compositions, or verifiable facts are present — the paragraph merely defines the scope of assets covered (networks, software, data) without describing actual program activities or methodology.


reasoning: This paragraph describes board-level cybersecurity oversight structure: the audit committee's role in overseeing the cybersecurity program, the information flow from the CFO to the audit committee, and reporting to the full board. This is textbook Board Governance (BG) content describing how the board fulfills its oversight function. For specificity, the paragraph contains only generic governance concepts (audit committee, CFO, periodic updates, board of directors) that appear in virtually every 10-K disclosure — no named committees with distinguishing identifiers, no specific cadences, no named individuals, no verifiable claims. The language is entirely boilerplate; a non-security professional could have written this.


fact: April 28, 2023 — date phishing attack identified

fact: $54,300 — specific dollar amount incorrectly paid

fact: phishing attack — type of cybersecurity incident

fact: isolated incident perpetrated by an external source — investigation conclusion

fact: assistance of our bank — third party involved in recovery

fact: June 29, 2023 — date funds were fully recovered

fact: additional controls related to vendor verification — specific remediation

fact: additional review procedures of each payment made by several authorized individuals — specific remediation

reasoning: This paragraph describes a real cybersecurity incident with specific dates (April 28, 2023 identification; June 29, 2023 recovery), a specific dollar amount ($54,300), and concrete remediation steps — making it Incident Disclosure (ID) per Rule 4. The $54,300 figure and both calendar dates are hard, externally verifiable facts that establish Level 4 specificity. Even the remediation controls (vendor verification procedures, multi-person payment review) add specificity about what was done, not just that something was done.


reasoning: The paragraph describes what the cybersecurity program does (assessments, risk management, security controls, incident response, external assistance), making Risk Management Process the primary category. However, all content consists of generic program descriptors with no domain-specific terminology (no NIST, ISO, SIEM, EDR, etc.), no named roles or committees, no quantified facts, and no externally verifiable claims—making this purely generic boilerplate.


reasoning: This paragraph is a generic context-setting statement describing what types of information the company may collect and store. It does not describe any cybersecurity governance, processes, controls, or assessments—it merely states that the company handles customer information and proprietary/confidential business information. This type of broad assertion appears in virtually every company's privacy and security disclosures and contains no substantive cybersecurity disclosure.


fact: Senior Director, Information Protection & Compliance (role title with security qualifier at Director level)

fact: Management committee on cybersecurity (named internal committee)

reasoning: The paragraph describes board oversight structure and information flow (quarterly briefings to Audit and Finance Committee, annual board reviews, cybersecurity-focused briefings by specific roles) — this directly answers how the board oversees cybersecurity. Specificity is elevated to Level 3 by the Senior Director, Information Protection & Compliance (a Director-level role with security qualifier that is not generic) and the reference to a management committee on cybersecurity (a named internal committee). While cadences and committee names like 'Audit and Finance Committee' are generic, the presence of a security-qualified Director role is sufficient to distinguish this company's governance structure.


fact: cyber and information security control environment

fact: resiliency in the event of an intrusion

fact: Formalized vendor incident response procedures

reasoning: The paragraph centers on vendor cybersecurity oversight (tiering, assessments, due diligence questionnaires, incident procedures), which maps directly to the Third-Party Risk category under Rule 3. The specificity is Domain-Adapted because the paragraph demonstrates cybersecurity expertise through domain-specific vocabulary (control environment, intrusion resiliency, formalized vendor incident response) that a non-security ERM professional would not naturally use—these concepts require understanding of how cybersecurity third-party risk is specifically assessed and managed.


reasoning: The paragraph primarily answers 'Have cybersecurity incidents affected the business?' with a negative materiality assertion (SI per Rule 5). However, specificity is Generic Boilerplate because the negative assertion ('have not experienced any cybersecurity incidents that have been determined to affect us materially') is not externally verifiable per specificity guidelines, and all other content is either generic (Business Continuity, Incident Response programs — these are standard terms any ERM professional would use) or a cross-reference (Item 1A Risk Factors — N/O).


reasoning: The paragraph is a SPAC disclosure asserting the company has no business operations and therefore no cybersecurity risk management program or formal processes—this is a negative disclosure about the absence of cybersecurity measures, not a description of actual cybersecurity practices. No domain terminology, firm-specific details about cybersecurity operations, or verifiable facts are present; the content is generic SPAC boilerplate about lacking a program.


fact: system scans

fact: threat intelligence analysis

reasoning: The paragraph describes what the cybersecurity program does—employee training, managed service providers, system scans, threat intelligence, and third-party contractual requirements—making RMP the primary category. The specificity is Domain-Adapted because terms like 'system scans,' 'threat intelligence analysis,' and 'contractual requirements relating to privacy and cybersecurity standards' demonstrate cybersecurity domain expertise that an ERM professional without cybersecurity specialization would not naturally use; these practices and tools are specific to cybersecurity risk management rather than generic business processes.


fact: July 23, 2023 — specific date of cybersecurity incident

fact: $14.3 million — specific incident-related costs

reasoning: This paragraph describes a specific cybersecurity incident with a concrete date (July 23, 2023), affected systems, costs incurred ($14.3 million), and investigation outcome — directly answering what happened in an actual incident. The specificity level is driven by two externally verifiable facts: the specific incident date and the specific dollar amount of costs, both of which could be confirmed through financial and forensic records.


reasoning: This paragraph is a general preamble expressing the company's recognition of cybersecurity importance. It does not answer any of the six substantive questions (board oversight, management organization, risk management processes, third-party risk, incident disclosure, or strategy/materiality). The specificity is Level 1 (Generic Boilerplate) because the paragraph contains no specific cybersecurity practices, tools, roles, or measurable facts — only generic language about 'developing, implementing, and maintaining robust cybersecurity measures' that any public company could state.


fact: CTO and CISO titles

reasoning: The paragraph describes the qualifications and credentials of cybersecurity management personnel (CTO and CISO), directly answering 'how is management organized to handle cybersecurity?' by establishing who qualifies them (experience, certifications, professional backgrounds). Specificity is Firm-Specific because CTO and CISO are named cybersecurity leadership roles that would distinguish this company's cybersecurity governance from generic disclosures.


fact: cyber incident response plan

fact: prevention, detection, mitigation, and remediation of cyber threats

fact: third-party assessments

fact: cybersecurity policies and methodologies

reasoning: The paragraph describes the Steering Committee's oversight activities—monitoring program quality, receiving management updates on cybersecurity initiatives, reviewing policies and methodologies, and covering prevention, detection, mitigation, and remediation. Per Rule 1, management-level committee oversight activities map to RMP rather than MR. The specificity is Domain-Adapted because the paragraph demonstrates cybersecurity domain expertise (incident response plan, threat trends, third-party assessments) that goes beyond generic risk language any ERM professional could produce, though no firm-specific details or verifiable external claims are present.


reasoning: The paragraph describes cybersecurity program activities (using industry standards, deploying software, conducting internal audits, requiring SOC reports from vendors), making RMP the appropriate category. All content consists of generic practices any company could describe — no specific tools, named frameworks, roles, or verifiable claims are provided. The SOC report mention is one component of the internal program rather than the central topic, so TP does not apply.


reasoning: The paragraph focuses on the Board's recently reshaped oversight structure and its plans to address cybersecurity implementation, making Board Governance the primary category. However, specificity is Level 1 because the paragraph contains only generic cybersecurity terminology (readily swapable with non-cyber risk language), no named roles or committees, no specific practices or tools, and no quantifiable or externally verifiable facts — it describes the absence of current cybersecurity measures rather than a substantive cybersecurity program.


reasoning: This paragraph directly answers 'Has cybersecurity affected our business?' by stating it has not affected business strategy, results of operations, or financial condition — a backward-looking materiality assessment qualifying as Strategy Integration. The entire paragraph contains only generic language ('like other companies in our industry,' 'material cyber incidents') with no domain-specific terminology, firm-specific identifiers, or externally verifiable claims.


reasoning: The paragraph describes a management oversight structure for cybersecurity (CEO, MIS consultant, MIS supervisor) with a reporting relationship, which answers 'how is management organized to handle cybersecurity?' — fitting Management Role. For specificity: the roles mentioned (CEO, MIS consultant, MIS supervisor) are either generic (CEO exists at every company) or lack the firm-specific qualifiers needed (MIS supervisor is not a named cybersecurity leadership role at VP/Director level with security qualifier per the annotation guidelines); the activities described (prevention, detection, mitigation, remediation, updates) are generic risk management language that any ERM professional could write without cybersecurity domain expertise. No verifiable claims, named external assessors, specific tools, or firm-specific leadership structure.


fact: NIST CSF framework with Identify, Protect, Detect, Respond, Recover functions

reasoning: This paragraph describes the cybersecurity program's structure and framework methodology, directly answering 'What does the cybersecurity program do?' The reference to NIST CSF's specific five functions (Identify, Protect, Detect, Respond, Recover) demonstrates cybersecurity domain expertise that a general ERM professional would not naturally use — passing the ERM test and establishing Level 2 specificity.


reasoning: This paragraph contains only generic, aspirational language about cybersecurity importance and generic threat types (ransomware, denial-of-service) without describing any specific governance structure, management role, risk management process, or firm-specific cybersecurity program. The 'could materially adversely affect' language is speculative boilerplate, not an actual assessment of business impact. No specific facts, verifiable claims, or domain expertise terms are present.


reasoning: Category: The paragraph directly addresses third-party vendor oversight for data protection, answering 'How are third-party cyber risks managed?' — clearly Third-Party Risk. Specificity: The language ('formal, documented process,' 'assess the data protection practices') is generic ERM vocabulary that any company could use about any vendor risk type (financial, compliance, operational). It fails the ERM test — a non-security professional would naturally say this. No domain-specific cybersecurity terminology (SOC 2, penetration testing, vulnerability scanning), no firm-specific details (named committees, roles, programs), and no verifiable claims — making this Generic Boilerplate.


fact: SOC reports referenced as assessment evidence (domain term showing specific security evidence reviewed)

fact: Complementary controls language (domain term from SOC 2 auditing framework)

reasoning: The paragraph's central question is how third-party cyber risks are managed, describing security assessments of providers, ongoing monitoring, SOC report reviews, and complementary controls — all vendor oversight activities. The specificity is Domain-Adapted rather than Firm-Specific because while the paragraph demonstrates cybersecurity domain expertise (mentioning SOC reports and complementary controls, which are specific to cybersecurity third-party assessments), it lacks any firm-specific identifiers (named vendors, specific team roles, or quantifiable metrics that would distinguish this company). The last sentence is a negative assertion about material impact rather than an incident disclosure, consistent with SI but subordinate to the TP focus.


reasoning: The paragraph describes what CSIRPs (Cybersecurity Incident Response Plans) do—listing standard incident response lifecycle phases (detection, analysis, containment, eradication, recovery, post-incident review) and stakeholder notification. This is a description of the cybersecurity program's capabilities, making it RMP. The Audit Committee mention is incidental (notification recipient within the response process), not describing board oversight structure. The content lists generic incident response phases that appear in virtually every IR framework without any firm-specific details, named programs with distinguishing features, verifiable facts, or cybersecurity domain expertise that would elevate it beyond Level 1.


reasoning: The paragraph's central topic is third-party cybersecurity risk management (TP), but it contains only generic assertions ('comprehensive due diligence,' 'stringent standards') with no domain-specific terms, firm-specific facts, or verifiable claims, resulting in Level 1 specificity.


reasoning: The paragraph describes the incident response team's structure—designated employees, CFO membership, and audit committee reporting—making Management Role the primary category as it addresses how management is organized around cybersecurity incidents. The specificity remains Generic Boilerplate because while the paragraph mentions the CFO and audit committee, it uses only generic operational language ('escalate,' 'mitigate,' 'remediate') without cybersecurity domain terminology, firm-specific details, or verifiable claims; the terminology would be equally applicable to any operational risk response.


fact: CFO has been responsible for oversight function as CFO for three years

fact: CFO has worked in financial services for more than 30 years

fact: CCO has been responsible for oversight functions for three years

fact: Current CCO has been serving since April 2025

fact: CCO has worked in financial services for more than 35 years

reasoning: This paragraph describes management's organizational structure for cybersecurity oversight, focusing on the specific roles, responsibilities, and qualifications of the CFO and CCO — making it a Management Role disclosure. Specificity reaches Level 4 due to multiple hard verifiable facts: the CFO's three-year tenure and 30+ years industry experience, and the CCO's specific start date (April 2025), three-year tenure, and 35+ years industry experience.


reasoning: This paragraph primarily answers 'How has cybersecurity affected the business?' through a negative assertion — no material incidents during fiscal year 2025 that affected business strategy, results of operations, cash flow, or financial condition — which is an SI assessment under Rule 5. The paragraph contains no specific facts; the time period 'fiscal year 2025' is a reporting anchor, and the absence-of-incidents claim is an unconfirmable self-assertion (not verifiable under Rule 5 specificity guidance). The language consists entirely of boilerplate disclaimers and standard negative assertions found in virtually every 10-K.


reasoning: This paragraph describes board-level cybersecurity oversight structure, cadence of briefings (monthly), and approval authority over cybersecurity materials — all hallmarks of Board Governance content. For specificity, the paragraph contains no domain-specific cybersecurity terminology (no SIEM, SOC, EDR, zero trust, etc.), no firm-specific identifiers (IT Committee exists at most companies; senior management composition is generic), and no verifiable claims (no named individuals, specific dates, hard numbers, or named third parties). The language is entirely boilerplate that could appear in any company's 10-K cybersecurity governance disclosure.


reasoning: This paragraph describes the purpose and scope of the company's cybersecurity program (evaluating and improving confidentiality, integrity, and availability of systems), which falls under Risk Management Process. However, all language is generic boilerplate that any company could use — there are no specific processes, tools, frameworks named, practices described, or any facts that would distinguish one company's program from another. The CIA triad and 'information security program' terminology is standard and would be used by any enterprise risk management professional, failing the ERM test for domain expertise.


fact: Incident occurred in May 2025

fact: Unauthorized changes to domain, DNS, and email configurations

fact: Origin of compromise: administrative credentials retained by a former employee

fact: Impact: brief email-routing disruption

fact: All production systems remained fully operational

fact: Investigation included internal reviews and independent external assessment

fact: Contained on the same day it was discovered

reasoning: This paragraph describes an actual cybersecurity incident (May 2025 unauthorized changes via a former employee's retained credentials), its technical nature, scope, impact, investigation process, and remediation timeline — satisfying the Incident Disclosure category. Specificity is Level 4 due to the specific date (May 2025), precise technical details (domain, DNS, email configurations), specific causal mechanism (retained credentials), and reference to independent external assessment — all of which are externally verifiable claims about a real event.


category_confidence: low

reasoning: The paragraph describes Catcha Investment Corp's organizational approach to cybersecurity — specifically that it has no internal cybersecurity personnel or processes and relies entirely on third-party technologies and personnel. This addresses the Management Role question of how the company is organized to handle cybersecurity, even though the answer is 'it is not.' The specificity is Generic Boilerplate because the paragraph contains no domain-specific cybersecurity terminology (no mention of specific security tools, frameworks, or practices), no firm-specific facts (SPAC structure, no operations, and third-party dependence are generic characteristics of blank-check companies), and no verifiable claims — only generic assertions that could appear in any SPAC's 10-K.


reasoning: The paragraph is explicitly titled 'Overseeing Third-Party Risk' and describes vendor security assessments and ongoing monitoring as the central topic (per Rule 3: vendor oversight as central topic → TP). Regarding specificity: the paragraph uses only generic risk management language ('thorough security assessments', 'ongoing monitoring', 'cybersecurity standards') that any ERM professional could write about third-party oversight. No domain-specific security vocabulary (SOC 2, penetration testing, specific tools), no named programs, no firm-specific titles or facts. The CIO reference is a generic executive role conducting generic assessments, not a cybersecurity-specific leadership claim.


reasoning: The paragraph is a negative assertion of past incidents combined with hypothetical future risk speculation ('could potentially lead'). It does not describe a real incident (ID), does not describe the cybersecurity program or its activities (RMP), does not assess actual business impact (SI), and does not address oversight, roles, or third-party risk. The language about 'formalized cybersecurity framework' is aspirational — describing what they lack rather than what they do — and fails the ERM test as any business professional could write this without cybersecurity domain knowledge.


reasoning: The paragraph describes board-level cybersecurity oversight delegation to the Audit Committee, which is the canonical Board Governance structure (Rule 1: Board committees → BG). However, it contains only generic boilerplate: 'Board of Directors,' 'Audit Committee,' and generic process language ('evaluates our cybersecurity program, risks and corresponding mitigations') that every public company could use. No named individuals, specific titles with security qualifiers, named committees, team compositions, or specific practices are present. The specificity is therefore Generic Boilerplate — zero specific facts were identified.


reasoning: The paragraph describes the company's approach to managing cybersecurity risks from third parties (vendors, CROs, service providers), which directly answers the TP question of how third-party cyber risks are overseen. However, the paragraph contains no specific facts—it only states that a 'comprehensive, risk-based approach' exists without describing any specific requirements, assessments, controls, or processes that would distinguish this company's TP program from any other. The language is entirely generic boilerplate that could appear in any company's Item 1C disclosure.


reasoning: This paragraph describes board-level cybersecurity oversight structure, assigning oversight to the Board and delegating it to the Audit Committee with CFO updates — the canonical description of board governance in SEC Item 1C disclosures. Specificity is Generic Boilerplate: all entities mentioned (Board of Directors, Audit Committee, CFO) are generic governance roles that exist at every public company, and no cybersecurity-specific domain terms, firm-specific roles, or verifiable claims are present.


fact: Chief Information Security Officer (CISO) role

fact: CISO reports to Chief Information Officer (CIO)

fact: CISO works with Chief Legal Officer (CLO)

fact: Over 30 years of cybersecurity and intelligence experience

fact: Experience with Department of Defense

fact: CIO Program Certificate from College of Information and Cyberspace, National Defense University

fact: CISSP (Certified Information System Security Professional) designation

fact: CIPP (Certified Information Privacy Professional) designation

reasoning: This paragraph is about Management Role — it describes the CISO position, reporting lines, and the CISO's professional background and credentials, which answers how cybersecurity management is organized. Specificity is Level 4 because the CISO's claimed certifications (CISSP, CIPP) and the CIO Program Certificate from National Defense University are independently verifiable through professional registries, and 'over 30 years of experience' is a verifiable lower-bound claim.


reasoning: This paragraph is purely a cross-reference directing readers to Item 1A Risk Factors for additional information. It contains no substantive cybersecurity disclosure—no governance structure, no program description, no incident details, no materiality assessment. It's a navigation aid with zero factual content.


reasoning: This paragraph describes the general business dependency on IT systems and data handling but does not answer any of the six substantive cybersecurity questions — it contains no description of oversight structure, management roles, security processes, third-party oversight, incident details, or strategy integration. The specificity is Level 1 because no domain-specific cybersecurity terms, firm-specific facts, or verifiable claims are present — the language (IT systems for product development, accounting, communication) is generic enough that any company could use it, and the paragraph would be equally true if 'cybersecurity' were replaced with any other business function.


fact: April 9, 2024 at 10:25 p.m. local Hong Kong SAR time — discovery date/time

fact: Wire transfer of $30,825 to third-party bank account on March 27, 2024

fact: April 11, 2024 — date of verification

fact: April 12, 2024 — date remediation actions adopted

fact: Internal incident report distributed by Company's Chief Information Security Officer

fact: Report recipients: senior officers, finance department personnel, Audit Committee, and Board

fact: Conversations with Company's bank and local law enforcement

fact: Recovery of $30,825 believed not possible

reasoning: This paragraph describes a real cybersecurity incident with specific dates, times, financial amount ($30,825), and response actions — clearly meeting the Incident Disclosure category. Multiple hard facts make this Level 4: the specific date/time of discovery (April 9, 2024 at 10:25 p.m.), the specific dollar amount ($30,825), and multiple verifiable dates (March 27, April 11, April 12, 2024).


reasoning: This paragraph describes the regulatory environment governing the bank's cybersecurity practices (federal banking agencies, SEC rules, Form 8-K requirements) and references another section for additional information. It does not substantively answer any of the six core questions about board oversight, management organization, risk management activities, third-party oversight, actual incidents, or business strategy impact — it merely contextualizes regulatory requirements and points elsewhere. No specific facts about the company's cybersecurity program, personnel, processes, or outcomes are provided.


fact: Manager has a Cyber Risk Committee

fact: CIO has more than twenty years of experience as an information technology professional

fact: CIO has been CIO since 2007

fact: CIO has periodic calls with a third-party virtual Chief Information Security Officer

fact: Cyber Risk Committee reviews and approves or rejects escalated non-standard IT change requests

reasoning: This paragraph is primarily Management Role (MR) because the majority of content describes the Cyber Risk Committee structure, the CIO's specific responsibilities (communication, representation, review of change requests), and the CIO's qualifications (20+ years of IT experience, CIO since 2007). The specificity reaches Level 4 (Quantified-Verifiable) because the CIO's tenure since 2007 and 20+ years of IT experience are externally verifiable facts (someone could check LinkedIn or a biography), and the specific function of the Cyber Risk Committee (reviewing non-standard IT change requests) provides a concrete, named program element that distinguishes this from generic committee descriptions.


fact: 26 BTC (specific quantity)

fact: $560,000 approximate value at time of incident

fact: Sphere 3D Corp. (named third-party entity)

fact: US Federal law enforcement engaged via counsel

fact: Recovery was not possible

reasoning: This paragraph describes an actual cybersecurity incident — a business email compromise/social engineering attack resulting in the loss of 26 BTC — including the nature of the attack, the specific quantity and dollar value stolen, and the law enforcement response. The hard numbers (26 BTC, ~$560,000) and named entity (Sphere 3D Corp.) are externally verifiable claims, making this Level 4 specificity.


fact: Security Governance Council (SGC) — named internal committee

fact: SGC is chaired by the CISO

fact: SGC meets on a quarterly basis

fact: SGC membership includes: Operations, Information Technology, Finance, Internal Audit, Legal, Human Resources and Organizational Development, and Risk Management

reasoning: The paragraph describes the SGC as a management-level governance body: its chair (CISO), cross-functional membership composition (8 departments named), quarterly cadence, and reporting line to CEO/Audit Committee. Per Rule 1, management-level committees focused on structure/membership → MR. The named committee, CISO chair role, quarterly meetings, and specific department roster are firm-specific facts distinguishing this company's cybersecurity governance structure from any other public company, supporting Level 3.


reasoning: The paragraph's primary focus is describing how the Board of Directors oversees cybersecurity through integration with the company's ERM program, making Board Governance the appropriate category. Despite mentioning NIST and ISO frameworks (domain-adopted terminology), the paragraph contains no firm-specific facts—no named committees beyond generic 'Board of Directors,' no named individuals, no specific team composition, no quantifiable metrics, and no distinguishing organizational details that would narrow down which company wrote this. The language about board oversight and cybersecurity as part of ERM is entirely generic boilerplate that could appear in virtually any public company's 10-K Item 1C.


reasoning: The paragraph describes third-party security consulting activities within the cybersecurity program (overseeing risk assessments, maintaining security controls, coordinating incident responses) — all generic program activities. No domain-specific security terminology beyond generic descriptors (no named tools, frameworks, standards, or technical practices); no firm-specific details (no named consultants, specific committees, or role titles); no verifiable claims. The language would apply equally to any company's description of third-party security assistance.


fact: SIEM/SOC monitoring

fact: automated off-boarding and access-revocation processes

fact: identity and domain anomaly monitoring

fact: targeted cybersecurity training

fact: quarterly access reviews

fact: domain, DNS, and email operations

reasoning: The paragraph describes past incident response actions (forensic investigation, remediation measures, monitoring implementation) and concludes with an impact statement, making it primarily about what happened. The specificity is driven by domain-specific terminology (SIEM/SOC, automated off-boarding, access revocation, identity/domain anomaly monitoring) that passes the ERM test — these are technical security concepts a non-security ERM professional would not naturally use. No firm-specific roles, named programs, or hard numbers are present.


reasoning: The paragraph describes management's organizational involvement in cybersecurity oversight—specifically responsibility for risk management framework, resource allocation, and strategic integration—which maps to Management Role as the primary question answered. However, all language consists of generic business management terms (oversight, coordination, resource allocation, incident response planning, business continuity) that any non-cybersecurity professional could use when describing ERM activities; no domain-specific cybersecurity vocabulary, firm-specific organizational details, or verifiable claims are present.


reasoning: The paragraph describes management's organizational role in cybersecurity oversight — identifying which executives (CFO, SVP and General Counsel) supervise efforts and the information channels they use. Per Rule 1, management-level organizational structure defaults to MR when the primary content is about who manages and how they are organized, rather than specific governance committee structure (BG). The paragraph contains no firm-specific facts, no named third parties, and no domain-specific technical language beyond generic 'security tools' and 'threat intelligence' — all of which any company could claim.


reasoning: This paragraph is a general risk overview that describes cybersecurity dependency and potential threats in highly speculative, forward-looking language ('may be vulnerable,' 'could be accessed,' 'could result in'). It does not describe a specific cybersecurity program, methodology, or organizational structure. The paragraph contains no firm-specific facts, no named individuals, no specific tools or frameworks, and no quantifiable claims — only generic boilerplate applicable to any company in the financial services industry. The materiality reference at the end is speculative risk language pointing elsewhere (Item 1A), not an actual assessment of business impact.


reasoning: This paragraph is a general commitment statement describing cybersecurity as an important concern without answering any of the six substantive questions — it describes neither board oversight, management organization, specific program activities, third-party risk management, a real incident, nor business/financial impact. The paragraph contains no domain-specific security terminology (fails ERM test — any ERM professional could write this about any risk type), no firm-specific identifiers (no named roles, committees, or organizational structure), and no externally verifiable claims.


fact: August 2021 cybersecurity incident

fact: January 2023 cybersecurity incident

fact: Both incidents resulted in lawsuits, mass arbitration claims, and class action lawsuits

fact: January 2023 incident resulted in consumer class actions and regulatory inquiries

reasoning: This paragraph describes two actual cybersecurity incidents (August 2021 and January 2023) with their consequences (lawsuits, arbitration, class actions, regulatory inquiries), making Incident Disclosure the primary category per Rule 4. The specificity is Firm-Specific (Level 3) because the paragraph contains company-specific temporal facts (two named incidents with specific months/years) and specific legal consequences that distinguish T-Mobile's situation from any other company's generic incident disclosure.


fact: Named internal report types: IT Risk Assessment, Cybersecurity Risk Assessment, Annual IT Program Status Report, Vendor Management Risk Assessment, and Quarterly Internal Vulnerability Reports

reasoning: The paragraph describes board-level oversight via the Risk Management Committee receiving specific named internal reports, making this clearly Board Governance. The specificity is Firm-Specific due to the unique internal report titles (e.g., 'Quarterly Internal Vulnerability Reports') which distinguish this company's governance structure from others.


fact: penetration testing (internal and external)

fact: vulnerability scanning

reasoning: The paragraph describes what the cybersecurity program does—specifically employee training, penetration testing, and vulnerability scanning with remediation processes—which directly answers 'what does the cybersecurity program do?' → RMP. The specificity level is Domain-Adapted because the paragraph contains cybersecurity-specific domain terminology (penetration testing, vulnerability scanning, remediation based on criticality) that an ERM professional wouldn't naturally use without a cybersecurity qualifier, but lacks any firm-specific identifiers (named leaders, specific team size, named committees) or hard verifiable facts (specific dates, named third-party firms, specific headcount).


fact: senior IT executive with ten years of cybersecurity experience

fact: senior IT executive with thirty-five years of experience in various technology domains

fact: specific domains: IT Infrastructure, Cloud, Cybersecurity, and Application Development

fact: experience includes both Fortune 500 and large semiconductor companies

reasoning: The paragraph primarily describes the governance oversight structure for cybersecurity risks—identifying executives, IT management, and the Cybersecurity Committee as responsible for assessing/managing risks and overseeing policies. This is a Board Governance paragraph. Specificity reaches Level 4 due to the quantified claims about the senior IT executive's experience: ten years in cybersecurity and thirty-five years in technology domains, with specific domain names listed. These are verifiable facts about a named leadership role.


fact: October 28, 2023 — specific announcement date of the cybersecurity incident

fact: $1.5 million of expenses incurred related to the cybersecurity incident in Q1 fiscal 2024

fact: Facilities returned to normal operations by mid-December 2023

reasoning: This paragraph describes a real cybersecurity incident: its discovery date, operational impact (inability to ship orders), recovery timeline, and financial cost ($1.5 million). The $1.5 million expense figure and specific dates (October 28, 2023; mid-December 2023) constitute externally verifiable claims. While the paragraph includes a forward-looking disclaimer and cross-references risk factors, the dominant content is incident description — what happened, when, and its quantified impact.


fact: May 2014 (specific date of incident)

fact: email spoofing technique (domain terminology)

fact: scammer impersonating one of the Company's subsidiaries (firm-specific attack vector)

fact: existing customer targeted (firm-specific)

fact: no money was sent to scammer (outcome)

reasoning: Paragraph describes an actual email spoofing incident (what happened, when, outcome), fitting Incident Disclosure. Specificity is Level 4 due to the hard date 'May 2014' which is externally verifiable against company records.


fact: Chief Information Officer (CIO) holds primary responsibility for the cybersecurity program

fact: CIO has more than 20 years of experience in information and operational technology

reasoning: The paragraph's primary focus is describing the CIO's organizational role and credentials as the person accountable for cybersecurity, making Management Role the correct category. The specific claim of 'more than 20 years of experience' is a lower-bounded verifiable fact tied to a named role, elevating specificity to Level 4.


reasoning: This paragraph is purely speculative risk-factor language (Item 1A-style) using 'may be unable,' 'could expose,' 'could result,' and 'risk of' throughout. It describes hypothetical consequences of hypothetical breaches rather than actual cybersecurity incidents, governance structures, management organization, or program activities. Per Rule 5, speculative 'could have a material adverse effect' language is not Strategy Integration — it is standard boilerplate found in every 10-K. There are no specific facts present: no named roles, no processes described, no verifiable claims, only generic risk-consequence language.


fact: CISO joined Workday in 2010

fact: CISO has served as CISO since April 2018

fact: CISO has more than 15 years of experience in cybersecurity and information technology risk management

fact: CISO worked at a large public company and a recognized consulting firm

fact: CISO has a degree in information systems management

reasoning: The paragraph is clearly about Management Role (MR) — it describes the CISO's leadership responsibilities, career history, experience level, and educational credentials. Applying Rule 2 (person-removal test), the paragraph collapses to nothing without the person-specific content, confirming MR as the correct category. Specificity is Quantified-Verifiable (Level 4) because the paragraph contains multiple externally verifiable claims: April 2018 start date, 2010 join date, 'more than 15 years' of experience (lower-bound number), and a named degree program. Any of these could be confirmed against employment records.


reasoning: This paragraph contains only placeholder language ('fluid situation,' 'then-current status,' 'additional steps indicated') without describing any actual cybersecurity governance structure, processes, or measures. It states an intent to meet 'periodically' without specifics and provides no substantive disclosure about how the company manages cybersecurity risk — making it a None/Other classification. No domain-specific terminology, firm-specific identifiers, or verifiable facts are present, resulting in Generic Boilerplate specificity.


fact: posture and intelligence reviews

fact: evaluations of critical vendors

fact: security requirements assessment

fact: service level agreements with embedded cyber controls

reasoning: The paragraph's central topic is third-party vendor cybersecurity oversight—specifically how the company extends cybersecurity expectations to vendors through monitoring services, intelligence assessments, vendor evaluations, and contractual security requirements. This passes the TP test (requirements imposed ON vendors, not services hired BY the company). The specificity is Domain-Adapted because the language demonstrates cybersecurity domain expertise that a general ERM professional would not use (open-source intelligence risk assessments, posture reviews, embedded cyber controls in SLAs)—these are not generic business process descriptions but specific security program vocabulary.


reasoning: This paragraph is general introductory language about the company's technology dependency without describing any specific cybersecurity governance, processes, or measures. It does not answer any of the six substantive disclosure questions (board oversight, management organization, risk management activities, third-party risk management, incident details, or business impact). No specific facts, domain terminology, or verifiable claims are present—the language is boilerplate applicable to virtually any technology-dependent company.


fact: October 28, 2023 - date the company identified the cybersecurity incident

fact: $1.5 million - specific expenses incurred related to the cybersecurity incident in Q1 fiscal 2024

fact: mid-December 2023 - date facilities returned to normalized operations

fact: first quarter of fiscal 2024 - timeframe when the incident adversely affected ability to ship orders

reasoning: This paragraph is primarily about an actual cybersecurity incident that occurred on October 28, 2023, describing the nature of the incident, its operational impact (shipping disruption), timeline (Q1 FY2024, recovery by mid-December 2023), and specific financial impact ($1.5 million in expenses). The forward-looking statement at the end functions as standard legal disclaimer language rather than the substantive content. Specificity reaches Level 4 due to multiple hard verifiable facts: the exact incident discovery date, the specific dollar amount of expenses, and the precise recovery timeline.


fact: Monthly phishing simulations sent to each employee by a third-party vendor

fact: Information security and data privacy training required for all employees

fact: Results of phishing security tests reported to management

reasoning: The paragraph describes the company's cybersecurity training program and periodic phishing simulation exercises conducted by a third-party vendor — these are active security program practices, not governance structures or management roles. The specificity is Domain-Adapted because the description of simulated phishing attacks as a testing methodology demonstrates cybersecurity domain expertise that goes beyond generic risk management language any ERM professional could write about non-cyber risks.


reasoning: This paragraph is forward-looking risk acknowledgment language about potential cybersecurity incidents rather than a substantive disclosure. It describes no actual cybersecurity measures, governance structure, or business assessment—only speculative consequences ('could cause,' 'could materially impact'). Per Rule 5, 'could have a material adverse effect' style language does not qualify as Strategy Integration. The paragraph contains no domain-specific terminology demonstrating cybersecurity expertise, no firm-specific facts, and no verifiable claims.


reasoning: This paragraph is a general company identity statement describing the firm's business and a generic commitment to security — it does not answer any of the six substantive cybersecurity questions (board governance, management roles, risk processes, third-party risk, incident disclosure, or strategy integration). No specific cybersecurity facts, domain terminology, firm-specific details, or verifiable claims are present — only boilerplate business description language that could appear in any company's filing.


reasoning: This paragraph is primarily a forward-looking risk disclaimer that states cybersecurity threats 'could have a material adverse effect' and points readers to Item 1A for more information. The only substantive content is a negative assertion ('To date, we have not had a cybersecurity incident') and generic process language ('proactively seek to detect and investigate') that any non-security professional could write. There are no domain-specific security terms (ERM test passes), no firm-specific roles or named programs, and no verifiable quantified claims.


fact: Chief Technology Officer reports to Executive Vice President – Operations

fact: Cybersecurity incidents are reported to the legal department

fact: Executive Vice President – Operations lacks technology services background

fact: Legal department members lack technology services background

reasoning: The paragraph describes the organizational structure for cybersecurity management within the company—the CTO's reporting line to the EVP-Ops and the incident escalation pathway to legal—making it a Management Role disclosure. Specificity is Firm-Specific because the named roles (CTO, EVP-Operations) and their specific reporting relationships constitute firm-specific organizational facts that distinguish this company's structure from others. No domain expertise terms are present, and no externally verifiable claims (certifications, numbers, named assessors) appear.


fact: cybersecurity

fact: information systems technology

fact: regulatory compliance

fact: corporate governance

fact: cybersecurity incidents

reasoning: This paragraph primarily answers 'How is management organized to handle cybersecurity?' by identifying responsible roles (COO, CCO), their relevant expertise areas, and how they monitor cybersecurity matters—classic Management Role content. The specificity reaches Domain-Adapted because the expertise domains listed (information systems technology, cybersecurity, regulatory compliance, corporate governance) represent cybersecurity-relevant terminology that passes the ERM test: an enterprise risk management professional would not naturally use 'information systems technology' or 'cybersecurity' in describing oversight of other risk types. The COO and CCO titles are generic executive roles (not cybersecurity-titled roles like CISO), so they do not elevate to firm-specific Level 3.


reasoning: The paragraph addresses cybersecurity insurance as a financial risk management mechanism, which maps to Strategy Integration. However, it contains no specific facts—the statement about carrying cyber risk insurance is generic (universal to most public companies), and the disclaimer 'there can be no assurance' is standard legal boilerplate rather than a material assessment. No firm-specific details (coverage amount, policy terms) or verifiable claims are present.


reasoning: The paragraph's central function is a backward-looking negative assertion (no material cybersecurity incidents have occurred), which Rule 5 explicitly classifies as Strategy Integration. It contains no domain expertise language, firm-specific identifiers, or externally verifiable claims, making it purely boilerplate.


reasoning: The paragraph opens with a backward-looking SI assessment ('no cybersecurity incidents have materially impacted... business strategy, results of operations, or financial conditions') and is explicitly titled 'Impact of Material Risk,' directly answering how cybersecurity has affected business outcomes. Despite the SI framing, the paragraph contains no firm-specific facts (no named roles, committees, or programs), no verifiable claims (the negative assertion is not independently confirmable), and uses only generic risk language ('risk-based approach,' 'cybersecurity policies, procedures and controls') applicable to any financial institution's boilerplate disclosure.


reasoning: This paragraph is a forward-looking disclaimer about potential future impact, containing the exact 'could have a material adverse effect' language that Rule 5 explicitly excludes from Strategy Integration. While it references past assessments ('have not materially affected'), these are embedded within boilerplate hedging language rather than constituting a substantive standalone assessment. No specific cybersecurity governance, process, or incident details are provided.


reasoning: The paragraph is a standard SEC materiality assessment—backward-looking ('have not materially affected') and forward-looking ('reasonably likely to materially affect')—making Strategy Integration the primary category per Rule 5. The specificity is Generic Boilerplate because the paragraph contains no domain expertise, firm-specific distinguishing facts, or externally verifiable claims; 'have not experienced... undetected cybersecurity incident' is a negative self-assertion that cannot be independently confirmed.


fact: penetration testing

fact: managed detection and response services

fact: intrusion prevention and detection applications

reasoning: The paragraph's central focus is vendor risk management oversight of third parties (reviews, performance evaluations, escalation), making it TP. Specificity is Level 2 because the three named services (penetration testing, managed detection and response, intrusion prevention/detection) demonstrate cybersecurity domain expertise that passes the ERM test, but no firm-specific or externally verifiable facts are present.


reasoning: This paragraph primarily answers 'What impact did cybersecurity have on the business?' by stating no past incidents had a material adverse effect on strategy, operations, or financial condition — a backward-looking materiality assessment that fits Strategy Integration under Rule 5. The paragraph contains only generic boilerplate language (reference to past incidents without describing them) and a cross-reference to Item 1A Risk Factors, with no domain-specific terminology, firm-specific facts, or externally verifiable claims, yielding Generic Boilerplate.


fact: Forensic investigation completed December 13, 2023

fact: Last confirmed unauthorized third-party activity occurred November 20, 2023

fact: Malware deployed was specifically described as non-self-propagating

fact: No evidence of direct impact to customer-owned systems

reasoning: This paragraph describes an actual cybersecurity incident with specific dates, attack method (non-self-propagating malware), and scope (data exfiltration, unauthorized third-party access). The two calendar dates (November 20 and December 13, 2023) are independently verifiable factual claims about the incident timeline, making this Level 4.


reasoning: The paragraph describes oversight structure—specifically how management reports to the Audit Committee—which is the hallmark of board governance. The CEO directing cybersecurity and management providing updates to the Audit Committee on risks, mitigation, and vulnerability management is generic oversight language that any public company could write, with no domain-specific terminology (ERM test), no named individuals or roles beyond generic titles, and no specific committee beyond the standard Audit Committee. No facts elevate above boilerplate.


fact: Ransomware attack occurred in May 2020

fact: Cybercriminal removed a copy of a subset of data from self-hosted environment

fact: Subject to certain legal proceedings, claims and investigations as a result

fact: References Note 11 to consolidated audited financial statements

reasoning: This paragraph primarily describes an actual cybersecurity incident—the May 2020 ransomware attack—providing the specific timing, nature of the breach (data exfiltration from self-hosted environment), and ongoing legal consequences. Per Rule 4, describing what happened (timeline, scope, response) maps to Incident Disclosure. The specific date (May 2020) and factual description of the incident constitute externally verifiable claims about a real event, meeting Level 4 specificity.


reasoning: The paragraph describes a governance chain (Board Audit Committee → CISO → cybersecurity program), which primarily answers 'how does the board oversee cybersecurity?' The CISO management mention is subordinate to the governance description, triggering Rule 1's default to BG for governance-chain paragraphs. For specificity, the paragraph contains only generic ERM-style language ('identify, assess and mitigate,' 'policies and safeguards') that any ERM professional could write, no domain-specific cybersecurity terminology that would require expertise, no firm-specific distinguishing facts (CISO role title without name or VP-level organizational context, generic Audit Committee), and no externally verifiable claims.


reasoning: The paragraph's opening sentence directly assesses whether cybersecurity has materially affected or is reasonably likely to materially affect the company's business strategy, results of operations, or financial condition—this is the quintessential Strategy Integration assessment under Rule 5. The specificity is Generic Boilerplate because the only substantive claim is a negative self-assertion ('we are not aware of any material risks') which cannot be independently verified, while the subsequent risk enumeration uses only generic terms any company could employ (unauthorized access, cyber-attacks, privacy laws, theft, fraud, extortion).


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors, and the quoted text consists entirely of hypothetical risk language ('could materially and adversely affect,' 'if we fail to manage') with no description of actual cybersecurity governance, programs, or measures. No substantive cybersecurity disclosure is provided here.


reasoning: The paragraph's primary function is a negative assertion about past material incidents ('we have not had any known instances of material cybersecurity incidents'), which qualifies as Strategy Integration under the Rule 5 materiality rule for backward-looking negative assertions. However, the specific claim that no material incidents occurred is a self-reported statement that cannot be externally verified—absent evidence to the contrary, it's the company's own characterization. Combined with the generic forward-looking disclaimer and cross-reference to Item 1A, no verifiable, firm-specific, or domain-adapted facts are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the Board's oversight of cybersecurity through the Audit Committee, detailing briefing frequency (quarterly) and topics covered — the quintessential Board Governance disclosure. For specificity, the paragraph contains no named individuals, no specific dates or numbers, no verifiable external claims, and no cybersecurity-specific terminology beyond 'vulnerability assessments.' The ERM test is decisive: 'cybersecurity risk profile,' 'threat environment,' and 'mitigation activities' are terms any enterprise risk management professional would use about any risk category; none of this language demonstrates that the writer understands how cybersecurity actually works.


fact: Executive Steering Committee (named internal committee)

fact: Committee composition: CEO, CFO, Executive Vice President Engineering, Senior Director IT, General Counsel

fact: Reporting to Audit Committee and Board

reasoning: This paragraph describes the governance-chain showing how cybersecurity oversight flows upward from the CISO and Executive Steering Committee to the Audit Committee and Board, which is the defining characteristic of Board Governance (BG). The specificity reaches Level 3 due to the named Executive Steering Committee (distinct from generic 'cross-functional team'), its specific member composition (CEO, CFO, EVP Engineering, Senior Director IT, General Counsel), and the explicit board reporting structure — all firm-specific identifiers that would distinguish this company's governance structure from others.


reasoning: The paragraph describes Discover's Third Party Program for managing third party risk, making third-party risk management the central topic. However, the language is entirely generic — terms like 'identification, measurement, management, monitoring and reporting' are standard ERM vocabulary that any risk professional would use for non-cybersecurity risks, failing the ERM test for domain expertise. No cybersecurity-specific practices, tools, or standards are mentioned, and no firm-specific or externally verifiable facts are present.


fact: System and Organization Controls (SOC) reports

reasoning: The paragraph directly addresses how third-party cyber risks are managed through vendor evaluation and SOC report requirements, making Third-Party Risk the primary category. The reference to SOC (System and Organization Controls) reports as the specific evidence-gathering mechanism demonstrates cybersecurity domain expertise—knowing to request these attestation reports requires specialized knowledge beyond generic ERM language, qualifying this as Domain-Adapted specificity. No firm-specific identifiers or externally verifiable quantified facts are present.


fact: Executive Vice President of Technology (VP-level title with IT/cybersecurity qualifier)

fact: reports directly to the Chief Executive Officer (specific reporting line)

fact: over 16 years of experience managing information technology and cybersecurity matters (specific number, externally verifiable)

reasoning: The paragraph's primary function is describing who manages cybersecurity risks and their organizational position — the EVP of Technology, their reporting line to the CEO, and their qualifications — making this a Management Role disclosure. The 'over 16 years of experience' claim is a hard, externally verifiable fact (specific number + domain expertise), which elevates specificity to Level 4, with the VP-level title and direct reporting relationship adding firm-specific grounding.


reasoning: This paragraph primarily acknowledges the company's third-party cybersecurity reliance and generic board oversight, but contains no substantive description of cybersecurity measures, governance specifics, or verifiable facts. The disclosure lacks any firm-specific details (no named committees, roles, or programs), domain expertise (no security-specific terminology demonstrating professional-level knowledge), and quantifiable claims — characteristic boilerplate for a SPAC with minimal operational cybersecurity infrastructure to disclose.


reasoning: The paragraph describes the board's oversight structure for cybersecurity risk, specifically identifying the Risk Committee of the Board of Directors as responsible for cybersecurity oversight. This is a Board Governance paragraph describing how the board oversees cyber risks. However, the content is entirely generic governance language (management assesses risk, board oversees, risk committee handles cybersecurity) with no domain-specific security terminology, no named individuals, no firm-specific committee names beyond standard board structure, and no verifiable facts — all of which would appear in virtually any public company's Item 1C disclosure.


reasoning: The paragraph describes third-party vendor oversight and contractual cybersecurity requirements imposed on vendors, making Third-Party Risk the appropriate category. However, it contains no domain-specific security terminology (fails the ERM test), no firm-specific identifiers, and no externally verifiable claims—all described in generic boilerplate language with 'specified ways' left undefined.


fact: Head of Information Technology for Latin America oversees Cybersecurity

fact: 25 years of experience in strategic IT leadership and global project management

reasoning: The paragraph describes a named management role and the individual's professional background, which is the core of Management Role — it establishes who is responsible and their qualifications. The specificity is driven by the hard number '25 years of experience,' which is externally verifiable against a resume or LinkedIn profile, making this Level 4 even though the core content is about role qualifications.


fact: In February and April 2025, Microsoft notified the Company about unauthorized activity within our Azure environment

fact: A suspected nation-state threat actor was identified as responsible for the activity

fact: The Company immediately activated its incident response plan

fact: Security advisories were issued and advanced security measures were implemented, including enhanced rotation of credentials and strengthened security monitoring

reasoning: The paragraph primarily describes an actual cybersecurity incident — a specific threat in February/April 2025 involving unauthorized activity by a suspected nation-state actor in Commvault's Azure environment, including the timeline, nature, and remediation steps — making it Incident Disclosure. The specificity level is elevated to QV by externally verifiable facts: specific dates (February and April 2025), named third party (Microsoft), named cloud environment (Azure), and attributed threat actor type (suspected nation-state), all of which an external party could independently confirm or investigate.


fact: vulnerability scanning

fact: penetration testing

fact: network assessments

fact: PCI DSS

reasoning: This paragraph describes what the cybersecurity program does (vulnerability scanning, penetration testing, network assessments) — these are security activities, not governance roles or business impacts — making it clearly a Risk Management Process disclosure. The specificity is Domain-Adapted because the paragraph uses cybersecurity-specific terminology (vulnerability scanning, penetration testing, PCI DSS compliance) that an ERM professional would not naturally use about non-cybersecurity risks, demonstrating domain expertise rather than generic process language.


reasoning: This paragraph answers 'Does cybersecurity affect our business or finances?' through materiality assessments — a backward-looking negative assertion ('not aware of any cyber incidents...material to our operations') and a forward-looking conclusion ('not reasonably likely to materially affect our strategy, results of operations or financial condition over the long term') — both meeting Rule 5's SI criteria. Specificity is Generic Boilerplate because the paragraph contains only self-reported negative assertions about incident absence and speculative opinions about future impact, with no domain terminology, firm-specific facts, or externally verifiable claims.


reasoning: The paragraph's dominant sentence is a backward-looking materiality assessment ('not aware of any cybersecurity risks...that have materially affected...our business strategy, results of operations, or financial condition') — a classic Strategy Integration statement per Rule 5. The second sentence touches on third-party oversight but is too brief (one line) to constitute a primary answer to a TP question. For specificity: the negative assertion about no material incidents is self-reported and non-verifiable; 'due diligence and ongoing monitoring' are generic ERM-level terms any company could use — neither domain-specific security vocabulary, firm-specific identifiers, nor hard facts are present. This is pure boilerplate.


reasoning: This paragraph describes the Board's oversight structure for cybersecurity, specifically identifying the Audit Committee as having primary responsibility for risk oversight including cybersecurity risks. This is a Board Governance (BG) paragraph because it answers 'how does the board oversee cybersecurity?' through the committee delegation structure. The paragraph contains no firm-specific facts (the Audit Committee is a generic governance role at every public company), no domain expertise beyond generic 'risk assessment' and 'risk management' terms that any ERM professional could use, and no verifiable claims — making it Generic Boilerplate.


fact: layered security model

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

reasoning: The paragraph describes the cybersecurity program's approach and components (layered security model, hardware/software/services stack, CIA triad objectives), making it primarily about what the program does → RMP. It contains domain terminology ('layered security model', 'confidentiality, integrity, and availability') that demonstrates cybersecurity domain expertise beyond generic ERM language, but no firm-specific or externally verifiable facts.


reasoning: This paragraph contains explicit materiality assessments about cybersecurity's effect on business outcomes — both a backward-looking 'have not materially affected' and a forward-looking 'are reasonably likely to materially affect' — which qualify as Strategy Integration per Rule 5. However, it contains no specific facts whatsoever: no named tools, processes, certifications, dollar amounts, dates, or other verifiable details. The entire paragraph consists of standard SEC boilerplate assertions and a cross-reference to Item 1A Risk Factors, with no cybersecurity-specific content.


reasoning: This paragraph describes the company's ongoing activities to improve cybersecurity capabilities (working with external parties to develop expertise, processes, procedures, and response plans), which maps to what the cybersecurity program does → RMP. The paragraph contains no domain-specific security terminology (would pass ERM test swapped with any risk type), no firm-specific roles or structures, and no verifiable claims → Level 1.


reasoning: The paragraph's primary purpose is answering whether cybersecurity has affected or could affect the Partnership's business outcomes — a negative assertion ('prior cybersecurity incidents have not had a material adverse effect') and a forward-looking risk statement. This maps to Strategy Integration per Rule 5. The specificity is Generic Boilerplate: the paragraph contains no domain-specific cybersecurity terms, no firm-specific claims, and no externally verifiable facts — the 'negative assertion' about incident impact is self-reported and cannot be independently confirmed.


fact: CISO has more than 20 years of experience directing disparate teams across application and product security, cyber defense, risk management, information governance, information technology compliance, information technology training and sales

fact: CISO and CRO provide periodic reports to the RACC at least quarterly

fact: CISO is appointed by the RACC

fact: Information security program includes incident response procedures designed to facilitate escalation of actual or potential cybersecurity incidents to security team members, senior management, and the RACC

reasoning: The paragraph primarily describes board oversight structure — how the RACC appoints and oversees the CISO, receives periodic reports (at least quarterly), and exercises governance over the information security program. The governance chain (Board/RACC → CISO/CRO → Security team) is the central organizing logic. The specificity level is driven by verifiable claims: the CISO's 'more than 20 years of experience' is a hard lower bound that could be confirmed via public resume or LinkedIn, and 'at least quarterly' reporting is a verifiable cadence.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors for cybersecurity risk disclosures. It contains no substantive cybersecurity content—only a pointer to where such information might be found. Per Rule 6 (N/O threshold), paragraphs with no actual cybersecurity measures, processes, or assessments are N/O. The 'materially affect' language here is speculative (referencing future potential) rather than a completed assessment, distinguishing it from Strategy Integration.


reasoning: This paragraph describes the board's oversight structure for cybersecurity (Audit Committee reporting to Board, annual board review of material risks), which is a Board Governance question. The specificity is Generic Boilerplate because 'Audit Committee,' 'Board of Directors,' and 'at least annually' are generic governance terms found in every public company's filings, and the language about 'processes to prevent, detect and mitigate cybersecurity incidents' is standard ERM terminology any non-security professional could write.


reasoning: The paragraph is a backward-looking materiality assessment stating that cybersecurity threats have not materially affected and are not anticipated to significantly affect the company's business strategy, results of operations, or financial condition, which maps directly to Strategy Integration under Rule 5. The paragraph contains no specific facts whatsoever—no domain-specific expertise (the language would apply equally to any enterprise risk), no firm-specific identifiers, and no externally verifiable claims—making it pure Generic Boilerplate.


reasoning: This paragraph is a pure cross-reference directing readers to Item 1A Risk Factors for cybersecurity disclosures. It contains no substantive cybersecurity content—no measures, processes, assessments, or conclusions about actual cybersecurity practices. Per Rule 6 (N/O threshold), this qualifies as None/Other because it describes no actual cybersecurity measures or disclosures. Specificity is Generic Boilerplate with no specific facts, domain terms, firm-specific claims, or verifiable claims.


fact: IT Lead has 5 years of experience in roles that include oversight of cybersecurity risk management programs

reasoning: The paragraph focuses on who manages cybersecurity risk assessment (IT Lead and external agency) and their qualifications, making Management Role the primary category. The specificity level is Quantified-Verifiable because it contains a specific hard number (5 years of experience) about the IT Lead that is externally verifiable.


reasoning: The paragraph's central topic is third-party/vendor cybersecurity risk management (developing a vendor risk management program), making Third-Party Risk the appropriate category. For specificity, the paragraph contains no domain-specific cybersecurity terminology (no specific practices, tools, or standards), no firm-specific facts (the program is aspirational 'developing'), and no externally verifiable claims—every statement could apply to generic ERM vendor risk management rather than cybersecurity specifically.


reasoning: The paragraph describes the Board's oversight structure for cybersecurity (Board sets risk appetite, Technology Committee approves policies and oversees implementation), which directly answers how the board oversees cybersecurity. However, it contains no specific facts — no named board members, no cybersecurity-specific tools or practices, no domain terminology (no mention of NIST, SIEM, SOC, threat intelligence, etc.), no quantified claims, and no firm-specific identifiers beyond generic 'Board of Directors' and 'Technology Committee' that exist at many companies. All described activities (approving policies, overseeing mitigation plans, conducting risk assessments) are generic governance language any ERM professional could write without cybersecurity domain expertise.


fact: Chief Information Security Officer (CISO) — VP-level role with cybersecurity qualifier

fact: Chief Information Officer (CIO) — VP-level role with IT qualifier

fact: Technology and Operations Committee — named cross-functional committee with cybersecurity oversight responsibilities

fact: CISO reports to CIO with open line of communication to Bank President

fact: Technology and Operations Committee reports to Management Committee

reasoning: The paragraph describes management's cybersecurity organizational structure — named roles (CISO, CIO), specific reporting lines, and an internal committee with defined oversight responsibilities and reporting chain. All entities are management-level, not board-level, making Management Role the appropriate category. The presence of named cybersecurity leadership roles and a specific named committee establishes firm-specific facts at Level 3.


reasoning: The paragraph primarily addresses whether cybersecurity incidents have affected business outcomes (negative assertion: 'have not...materially impaired') and mentions cyber liability insurance as a financial risk management tool. Under Rule 5, the backward-looking assessment 'have not materially impaired' is a Strategy Integration assessment. However, the specificity is Generic Boilerplate because all content consists of standard negative assertions and generic insurance disclaimers that appear verbatim across thousands of SEC filings—no specific facts, domain expertise, or verifiable claims are present.


reasoning: This paragraph is forward-looking risk disclaimer language about the potential financial consequences of hypothetical security breaches. Per Rule 5, 'could have a material adverse effect' language is standard boilerplate that does not qualify as Strategy Integration. It contains no substantive cybersecurity disclosure—no specific practices, tools, programs, or assessments are described. The language ('procedures and controls to monitor and mitigate') is generic and would be identical swapped for any other operational risk.


reasoning: The paragraph's central question is how third-party cyber risks are managed, which maps to Third-Party Risk. However, the paragraph contains no specific facts: no named vendors, no specific tools or practices, no verifiable claims about the program's scope or effectiveness. The language ('third-party risk management program') is entirely generic and could appear in any company's 10-K disclosure, failing the ERM test for domain expertise and containing no firm-specific or externally verifiable details.


fact: service organization controls reports

fact: Initial and continuing due diligence

fact: Risk Management, Legal and/or Information Security Departments review higher risk and material contracts

reasoning: This paragraph's central question is how third-party cyber risks are managed—it describes a third-party service provider management program, contractual review processes, SOC report requirements, and due diligence procedures. The specificity level is Domain-Adapted (Level 2) because the reference to 'service organization controls reports' (SOC reports) demonstrates cybersecurity domain expertise that a general ERM professional would not naturally use; this is the specific evidence format used in third-party security assessments. The named departments (Risk Management, Legal, Information Security) are generic organizational functions rather than firm-specific cybersecurity roles.


reasoning: The paragraph describes the board's oversight structure and committee reporting chain, which is the central question of Board Governance. It contains no domain-specific cybersecurity terms, no firm-specific facts (no named officers, committees with distinguishing names, or specific cadences), and no verifiable claims — only generic governance language that appears in any public company's 10-K.


reasoning: This paragraph describes the board's cybersecurity oversight structure, including delegation to the Audit Committee and reporting mechanisms, making Board Governance the appropriate category. The paragraph contains no firm-specific facts (all roles exist at every public company), no domain-specific technical terms, and no verifiable claims—it uses only generic governance language any company could employ.


reasoning: This backward-looking negative assertion about the absence of material cybersecurity incidents is framed as a business impact assessment (per Rule 5 SI), making it Strategy Integration. It contains no domain-specific terminology, no firm-specific facts, and no externally verifiable claims — only a self-reported negative assertion that cannot be independently confirmed, resulting in Generic Boilerplate specificity.


reasoning: The paragraph focuses on third-party service provider cybersecurity oversight—specifically assessing and managing threats from vendors—which maps directly to Third-Party Risk. However, the language is entirely generic ('assesses and manages,' 'communicated to management for review, response, and mitigation') with no domain-specific practices (SOC 2, penetration testing, encryption requirements), no named frameworks, and no firm-specific or verifiable facts. The vocabulary passes the ERM test—a non-security risk professional would naturally use this same language for any operational risk category.


reasoning: The paragraph's central topic is managing cybersecurity risks from third-party service providers through a third-party risk management program, making Third-Party Risk the appropriate category. However, the paragraph contains no domain-specific cybersecurity expertise (the phrase 'third party risk management program' would be used by any ERM professional regardless of cybersecurity knowledge), no firm-specific facts (no named vendors, specific committee structures, or organizational details), and no externally verifiable claims (no certifications, named third parties, specific dates, or hard numbers).