reasoning: The paragraph's primary communicative purpose is describing board and committee oversight of the ERM program that includes cybersecurity. The risk committee and audit committee are grammatical subjects in most sentences, overseeing the program, monitoring risk governance, and engaging with management. The named Risk Committee (non-generic, per IS list) and executive risk committee make this Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph carefully.

Content: Describes the ERM program, its oversight structure, and how cybersecurity risk fits within it. The board's risk committee oversees ERM, audit committee reviews it, there's an executive risk committee of senior leaders.

Category: This is primarily about Risk Management Process (ERM program description) with significant Board Governance elements. The paragraph starts with ERM program description, then discusses board oversight. The dominant topic is the ERM program structure and governance. Let me look more carefully...

The paragraph discusses:
1. Data security context (intro)
2. ERM program designed to manage risk including cyber threats
3. Risk committee of the board oversees ERM

4. Risk and audit committees review annually
5. Board engages with Chief Risk Officer, management, outside advisors
6. Executive risk committee of senior leaders

So the content weaves between describing the ERM program itself and the governance mechanisms around it. The board committees are heavily featured as overseers and reviewers, which pushes this toward Board Governance, but the framing remains centered on the ERM program structure. I'd categorize this as primarily Risk Management Process with Board Governance as a secondary element, since the board's role is presented as part of how the ERM program operates. I'm going back and forth on this. The board and committees are definitely the main actors in most sentences, which pushes toward Board Governance. But the paragraph's real purpose is explaining how the ERM program works—the board oversight is just one part of that structure. I think I should categorize this as Risk Management Process since that's the core subject, even though board governance features prominently.

Looking at the specific terms: "risk committee" is a named committee so that counts, "Chief Risk Officer" isn't on the cybersecurity-specific list, and "executive risk committee" could also be a named committee. The ERM framing is what ties everything together.

Since there are no dates, dollar amounts, headcounts, or third-party references, and the Risk Committee is a named non-generic committee, this falls under Firm-Specific classification.

fact: Risk committee of the board of directors oversees ERM program

fact: Executive risk committee comprised of senior leaders


content_category: Strategy Integration

category_confidence: medium

specificity_confidence: high

reasoning: The paragraph briefly mentions a past ransomware attack but its primary communicative purpose is the materiality assessment ('did not have a material impact on our business, operations, or financial condition') and the strategic consequence (accelerating IT initiatives). Per the tiebreaker rule, a brief mention of a past incident plus a materiality conclusion as the main point → Strategy Integration. The specific year '2021' is one hard fact, making it Firm-Specific but not Quantified-Verifiable.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: Describes a past ransomware attack (2021) and its business impact (not material, but accelerated IT initiatives).

Category: This has both incident description and strategy/impact elements. The first sentence describes what happened (ransomware attack). The second sentence assesses materiality and business impact. The incident description is brief ("suffered a ransomware attack on our information technology systems") while the rest is about materiality and strategic response. The dominant content is the business/strategic impact assessment - materiality conclusion + strategic response (accelerated initiatives). But actually, let me re-read the tiebreakers:

"Brief mention of a past incident + materiality conclusion as the main point → Strategy Integration"

This fits. The incident is briefly mentioned, and the main point is the materiality assessment and strategic consequence. So this is Strategy Integration.

Specificity: The paragraph mentions "In 2021" for the date, "ransomware attack" for the incident type, but no named firms, dollar amounts, headcounts, or tools. That's one specific fact.


content_category: Board Governance

category_confidence: high

reasoning: The Board is the grammatical subject creating working groups to oversee cybersecurity risks, making this Board Governance. No specific facts from the IS list are present — 'the Board,' 'informal working groups,' and 'from time to time' are all generic, yielding Generic Boilerplate.

thinking:
Classify this paragraph.

The board is the subject, creating working groups for cybersecurity oversight. This is Board Governance.

Specificity: No named frameworks, no specific facts from the IS list. "Informal working groups" is generic. "The Board" is generic. No cybersecurity-specific titles, no named committees, no dates, no numbers.

Generic Boilerplate.


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal cybersecurity processes: committee structure, risk assessment methodology, NIST CSF alignment, risk register, and monitoring cadence. The CIO is mentioned as attribution for who leads the committee, but the substantive content is about the function — risk assessment, controls evaluation, gap identification, and the risk register. Applying the person-vs-function test, the paragraph is about the program, not the person. Multiple firm-specific facts (CIO title, named Information Security Committee, specific departmental composition including mortgage/title operations) place this at Firm-Specific, but no two QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools) are present to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content Category: This paragraph describes the company's internal cybersecurity processes - the Information Security Committee, risk assessment methodology, NIST CSF framework, monitoring processes, and reporting structure. The CIO is mentioned as leading the committee, but the paragraph is about what the program does (the function), not about the person. The person-vs-function test: remove "The Company's Chief Information Officer" and the paragraph still describes the committee, risk assessment, framework, etc. → Risk Management Process.

Specific facts:
- CIO (cybersecurity-specific title) → named_role ✓
- Information Security Committee (named non-generic committee) → named_committee ✓

- Committee includes senior representatives from corporate functions, mortgage and title operations, IT infrastructure, IT security, and external security consultants → named_team ✓
- NIST CSF framework (sector-adapted level) → framework ✓
- Quarterly meetings and annual Board reports are generic cadences, not list-eligible
- CEO, CFO, CAO references are generic C-suite titles, not list-eligible

No QV-eligible facts present—no specific dates, dollar amounts, headcounts, named third-party firms, or named tools. The IS list facts are the CIO role and Information Security Committee.

The specific team composition across mortgage/title operations, IT infrastructure, IT security, and external consultants makes this Firm-Specific with multiple IS facts but no QV-eligible pair.

fact: CIO leads cybersecurity program

fact: Information Security Committee

fact: Committee comprised of senior representatives from primary corporate functions, mortgage and title operations, IT infrastructure, IT security, and external security consultants

fact: NIST CSF framework

type: framework


reasoning: The paragraph's primary communicative purpose is describing the company's process for integrating cybersecurity risk into its overall risk management system (2 of 3 sentences). The Audit Committee oversight mention in the final sentence is a subordinate component. No specific facts from the IS list are present — 'Audit Committee' is generic, no frameworks or cybersecurity-specific roles are named.

thinking:
Let me analyze this paragraph.

Content: Discusses importance of cybersecurity, integrating risk management process, and Audit Committee oversight.

Category: The paragraph has three parts: (1) generic importance statement, (2) risk management process integration, (3) Audit Committee oversight. The dominant content is split between RMP and Board Governance. The last sentence names the Audit Committee as the grammatical subject overseeing cybersecurity. But the middle sentence describes integrating processes.

Looking at dominant category - it's mixed. The first two sentences are about risk management process integration. The third is about Board/Audit Committee oversight. I'd say Risk Management Process is dominant (2 of 3 sentences), with the board mention being supplementary.

Reconsidering the structure: the opening is just generic framing, the core message is really about how the company integrates cyber risk into its management processes, with board oversight mentioned as part of that framework. Risk Management Process is the primary focus here. As for specificity, there are no named frameworks or concrete details from the IS list, and "Audit Committee" appears on the exclusion list anyway. The language is pretty standard boilerplate without any cybersecurity-specific terminology.


reasoning: The Board and Audit Committee are the grammatical subjects performing oversight of cybersecurity risk, clearly placing this in Board Governance. All elements — 'Board of Directors,' 'Audit Committee,' 'ERM program,' 'risk oversight' — are generic governance language found at virtually any public company; no cybersecurity-specific roles, named frameworks, or firm-specific facts are present.

thinking:
Classify this paragraph.

Content: Board oversight, delegation to Audit Committee, ERM program mention. Board is the grammatical subject throughout.

Category: Board Governance

Specificity: No named frameworks, no cybersecurity-specific roles, no specific dates/numbers. "Board", "Audit Committee", "ERM program" are all generic. → Generic Boilerplate


reasoning: The Board of Directors and the AFC (likely Audit and Finance Committee) are the grammatical subjects overseeing cybersecurity risk, with the CIO reporting to them — classic board oversight framing. The CIO is a cybersecurity-specific title on the IS list, making this Firm-Specific. The briefing topics listed in the bullets are generic and do not add further specificity. 'Quarterly' is a generic cadence and the AFC is essentially a variant of the standard Audit Committee, so neither elevates specificity beyond the CIO role.

thinking:
Let me analyze this paragraph.

Content: Board oversight, AFC (Audit and Finance Committee?) oversight, CIO provides quarterly updates to AFC or Board. Topics of briefings listed.

Category: Board Governance - the Board and AFC are the primary subjects of oversight. The CIO is mentioned but in context of reporting TO the board.

Specificity:
- "AFC" - this appears to be a named committee. But is it just the Audit Committee by another name? "AFC" likely stands for "Audit and Finance Committee" - this is essentially the Audit Committee variant. Per the codebook, "Audit Committee" is generic. AFC is basically the same thing.

- "CIO" is a firm-specific title that appears on the IS list, so that triggers Firm-Specific classification. The quarterly cadence is just generic timing, and the briefing topics themselves are standard governance subjects, but the CIO role is what makes this firm-specific.

fact: CIO provides updates to the AFC or Board


reasoning: The Board and Audit Committee are the grammatical subjects performing the primary actions (reviewing reports, receiving updates, undergoing training), making this Board Governance. The CIO is mentioned in a subordinate role providing information to the board. The CIO title is a cybersecurity-specific role on the IS list, elevating to Firm-Specific, but there is only one qualifying fact so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Board and Audit Committee review cybersecurity reports, CIO provides bi-annual updates to Audit Committee and annual briefings to Board, plus board member training.

Category: The board/Audit Committee is the primary subject - they review reports, receive updates. The CIO is mentioned but in service of describing what the board receives. → Board Governance

Specificity:
- "Audit Committee" → NOT list (generic)
- "Chief Information Officer" / CIO → IS list (cybersecurity-specific title)
- "bi-annual updates" → cadence but generic
- No named frameworks, no dates, no dollar amounts, no named firms

- CIO is on the IS list as a cybersecurity-specific title, so this scores as Firm-Specific (3)
- Only one IS fact present, so this doesn't qualify for QV

fact: Chief Information Officer (CIO) provides updates


reasoning: While the Board is the grammatical subject of the first two sentences, those sentences are generic trust/oversight framing. The substantive disclosure is in the third sentence describing cybersecurity integration into the ERM program and adoption of NIST and ISO 31000 frameworks — this is Risk Management Process content. Named frameworks (NIST, ISO 31000) trigger Sector-Adapted, but no firm-specific facts beyond standard names appear.

thinking:
Let me analyze this paragraph.

Content: The paragraph starts with the Board recognizing importance of trust, then discusses Board oversight of ERM, then describes cybersecurity integration into ERM with frameworks (NIST, ISO 31000).

Category: The Board is the grammatical subject initially, but the paragraph transitions to describing the company's cybersecurity program integration into ERM and framework adoption. The dominant content is about the risk management process - ERM integration and framework alignment. The Board mention sets context but the substantive content is about processes. Actually, let me re-read...

"Board recognizes importance" - generic board statement
"Board being involved in oversight of ERM program" - board governance

"cybersecurity policies... fully integrated into ERM program and are based on recognized frameworks" - Risk Management Process

The paragraph splits between Board governance and the actual risk management process. The substantive disclosure centers on how cybersecurity integrates into ERM through NIST and ISO 31000 frameworks, so Risk Management Process is the dominant category here. into ERM, based on NIST and ISO 31000 frameworks. That's the most substantive part of the disclosure. For specificity, the mention of recognized frameworks like NIST and ISO 31000 points to Sector-Adapted, while the lack of firm-specific details or named tools keeps it from being Company-Specific. So this lands at Sector-Adapted level 2.

fact: National Institute of Standards and Technology (NIST)


content_category: Management Role

reasoning: The paragraph's primary content is about the persons filling cybersecurity leadership roles — their combined experience (45+ years) and cybersecurity-specific experience (20+ years). While the second sentence touches on monitoring activities, the paragraph's communicative purpose is establishing who these leaders are and their qualifications. Two QV-eligible facts: '45 years' and '20 years' of experience as specific numbers.

thinking:
Let me analyze this paragraph.

Content: Describes CIO and Global Head of Cybersecurity - their experience, what they oversee, how they monitor. The paragraph is about the persons (their experience, combined 45 years, 20 years in cybersecurity) AND what they do (oversee policies, monitor efforts).

Person-vs-function test: The first sentence is about the people - their combined experience. The second sentence describes what the Global Head of Cybersecurity does - monitors through communication, tools, third-party assessments. If I remove the role titles and credentials, the second sentence still describes processes. But the first sentence is squarely about the persons' qualifications.

The dominant content here is about who these people are and their management roles. I'm noting the specific facts: the CIO title appears on the IS list, and "Global Head of Cybersecurity" is clearly cybersecurity-specific, also IS-eligible. The experience metrics are quantified - more than 45 years combined and over 20 years specifically in cybersecurity - so these qualify as quantified-verifiable facts.

fact: Chief Information Officer

fact: Global Head of Cybersecurity

fact: more than 45 years combined relevant experience

type: quantified

fact: over 20 years in cybersecurity


reasoning: The CISO is mentioned as attribution, but the paragraph's substantive content describes processes and activities: leveraging threat intelligence, monitoring information systems, and employing third-party advisory services. Replacing 'The CISO' with 'The Company' leaves the paragraph fully coherent as a process description, so this is Risk Management Process. CISO is the sole IS-list fact, yielding Firm-Specific.

thinking:
Let me analyze this paragraph.

The paragraph describes what the CISO does - leveraging threat intelligence, implementing monitoring processes, and using third-party advisory services. The key question is: is this about the person (Management Role) or the function (Risk Management Process)?

Applying the person-vs-function test: If I remove "The CISO" and replace with "The Company," the paragraph still makes complete sense as a process description. The content is about threat intelligence, monitoring, and third-party services - all process/function descriptions. The CISO is mentioned as attribution.

Category: Risk Management Process

Specificity:
- "CISO" is a cybersecurity-specific title → IS list item

- The advisory services and threat intelligence sources mentioned are all generic and unnamed, so they don't count as specific facts. Only the CISO reference qualifies as firm-specific information.

Firm-Specific

fact: CISO (cybersecurity-specific title)


reasoning: The ERM management committee is the primary subject, describing its cybersecurity oversight responsibility, composition including Chief Innovation Officer, and reporting cadence to the Board. The named non-generic committee (ERM management committee) triggers Firm-Specific; no second hard verifiable fact (dates, dollar amounts, named firms/tools) prevents QV.

thinking:
Let me analyze this paragraph.

The paragraph discusses the ERM management committee's role in cybersecurity oversight, its composition (senior leaders including Chief Innovation Officer), and reporting to the Audit Committee/Board.

Category: This is about a management committee responsible for cybersecurity risk oversight. The grammatical subject is "Our ERM management committee." It describes who comprises the committee and their reporting to the Board. This is a mix - it mentions board reporting (annual report to Audit Committee/Board) but the primary subject is the ERM management committee. The dominant focus is on the management committee's composition and responsibility.

Actually, let me reconsider. The ERM management committee is a management-level committee.

Looking at the codebook definition, Management Role covers management committees responsible for cybersecurity, and this paragraph is clearly about the ERM management committee's structure, composition, and reporting lines. The board reporting element is secondary to the main focus on the committee itself.

For specificity, the ERM management committee is a named non-generic committee on the list, making it firm-specific. The Chief Innovation Officer isn't a standard cybersecurity title like CISO or CIO, so that doesn't push toward specificity. The Audit Committee and Board are excluded from consideration anyway.

On the QV front, I only have one verifiable fact—the named committee itself—with no dates, amounts, named firms, tools, or certifications to back it up. So this lands as firm-specific with insufficient facts for QV.

fact: ERM management committee

fact: Chief Innovation Officer


content_category: Incident Disclosure

specificity_confidence: medium

reasoning: The paragraph narrates a cybersecurity incident — its timing, nature (IT infrastructure impact), scope (business applications, billing systems), and operational consequences (lost/deferred revenues, cash flow disruption). While the latter half discusses financial impact and ends with a materiality conclusion, the Incident Disclosure definition explicitly includes 'descriptions of affected data/systems scope or operational impact of a disclosed incident,' and the materiality sentence is subordinate to the overall incident narrative rather than the paragraph's main point. Two QV-eligible date references: the exact incident date (September 23, 2023) and the specific fiscal period impacted (first quarter of fiscal 2024).

thinking:
Let me analyze this paragraph.

Content: Describes a cybersecurity incident (Sept 23, 2023), its operational impact (disruptions, lost revenue, billing system issues), and concludes with a materiality assessment.

Category: This is tricky. It describes an incident (date, what happened) but also heavily discusses business/financial impact (lost revenues, expenses, billing disruptions, cash flow impact, materiality assessment).

The paragraph starts with incident narrative (when, what happened) but the bulk is about financial/operational impact and ends with a materiality conclusion. Let me apply the tiebreaker rules:

- "Paragraph DESCRIBES what happened in an incident (dates, access, encryption, scope, response actions) → Incident Disclosure"

- "Paragraph ONLY discusses financial cost, insurance, or materiality of an incident WITHOUT describing the event → Strategy Integration"

This paragraph does both - it describes what happened AND discusses financial impact. The first two sentences describe the incident itself. The remaining sentences discuss business impact. The dominant purpose seems mixed, but the incident description frames the paragraph and the financial impact is the consequence being reported.

Actually, looking more carefully: the first 2 sentences describe the incident, then 3+ sentences discuss business/financial impact (lost revenues, billing disruptions, cash flow, materiality). The dominant content is the business/financial impact. But the tiebreaker says "Mixed: 'We detected X... at [date]' AND discusses financial consequences" - this leans toward Incident Disclosure because the incident itself is explicitly described with dates and what happened. The financial impact is secondary context supporting why it matters.

Wait, Rule 4 clarifies: "if cost is one sentence in a paragraph about the incident → Incident Disclosure." Here the financial impact spans multiple sentences and dominates the paragraph's conclusion. The business impact assessment is the primary communicative goal - the incident details are just setup for explaining the financial consequences and materiality.

The paragraph's structure and emphasis point to Strategy Integration. The incident narrative is brief context, while the bulk of the content focuses on quantifying business impact and assessing materiality to financial statements. That's the dominant purpose here.

Actually, rereading more carefully - the paragraph does narrate what happened: access disruptions, billing system failures, cash flow effects. The financial consequences aren't separate from the incident description; they're integral to explaining the incident's scope and operational impact. The materiality statement concludes the incident narrative rather than pivoting to a separate business strategy discussion.

This fits Incident Disclosure better. The category explicitly covers "descriptions of affected data/systems scope or operational impact of a disclosed incident," and that's what this paragraph is doing - describing the incident's nature, affected systems, and resulting operational/financial consequences.

For specificity, I have the weekend of September 23, 2023 and first quarter of fiscal 2024 - both specific enough for QV eligibility. Insurance recoveries are mentioned but no insurer is named. I'm leaning toward Firm-Specific since September 23, 2023 is the only definitively hard date—"fiscal 2024" is too borderline as a time reference to count as a specific date in the QV sense.

fact: Weekend of September 23, 2023

fact: First quarter of fiscal 2024 (billing disruption timing)


reasoning: The Board and its delegated Governance and Sustainability Committee are the grammatical subjects performing oversight of cybersecurity, making this Board Governance. Contains firm-specific facts (CISO, CDIO as cybersecurity-specific roles, and the non-generic Governance and Sustainability Committee) but lacks two hard verifiable facts (dates, dollars, headcounts, named firms/tools) needed for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity, delegated to Governance and Sustainability Committee, briefing cadence, mentions CDIO and CISO roles.

Category: Board Governance - the Board and its committee are the grammatical subjects performing oversight.

Specific facts:
- CDIO (Chief Digital and Information Officer) - cybersecurity-specific title? It's a unique title, yes
- CISO - cybersecurity-specific title ✓
- Governance and Sustainability Committee - named non-generic committee ✓
- "quarterly engagements" - generic cadence, NOT list

- "several times per year" - also generic cadence

Now checking for quantifiable verifiable facts like dates, dollars, or headcounts—there aren't any, so this doesn't qualify as QV. For the IS list, I've got the CISO, CDIO as a cybersecurity-specific title, and the Governance and Sustainability Committee as a named non-generic committee, which gives me three items. This falls into Firm-Specific.

fact: Chief Digital and Information Officer (CDIO)

fact: Chief Information Security Officer (CISO)

fact: Governance and Sustainability Committee


reasoning: The entire paragraph describes the CISO's tenure, career history, and prior roles — classic person-focused content. Multiple QV-eligible hard facts: specific tenure date (2018), 25 years of experience, named prior employers (Cavium, ServiceNow, Pinnacle Systems), and specific durations at each.

thinking:
Classify this paragraph.

This is about the CISO's background, experience, tenure, and career history. Classic Management Role.

Specific facts:
- CISO (cybersecurity-specific title)
- "since 2018" (specific date)
- "25 years" of experience (quantified)
- Cavium (named firm)
- "Vice President of Business Systems" at Cavium
- "eleven years" at Cavium (quantified)
- ServiceNow (named firm)
- "two years" at ServiceNow (quantified)
- Pinnacle Systems (named firm)

- "eight years" at Pinnacle Systems (quantified)

All the key markers are here for QV-eligible status: specific dates, quantified tenure across multiple named companies, and substantial experience totaling 25 years. This clearly qualifies as Quantified-Verifiable.

fact: CISO

fact: since 2018

fact: 25 years of experience

fact: Cavium

fact: eleven years at Cavium

fact: ServiceNow

fact: two years at ServiceNow

fact: Pinnacle Systems

fact: eight years at Pinnacle Systems


reasoning: The paragraph describes using NIST CSF as the basis for designing and assessing the company's cybersecurity program, which is a risk management methodology topic. It names the NIST CSF framework but includes no firm-specific facts beyond that—the disclaimer about not meeting particular standards is generic language.

thinking:
Classify this paragraph.

Content: Describes using NIST CSF as a guide for their cybersecurity program. This is about risk assessment methodology and framework adoption → Risk Management Process.

Specificity: Names NIST CSF framework. Any firm-specific facts? The disclaimer about not meeting particular standards is generic. No firm-specific facts beyond the named framework. → Sector-Adapted.

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


reasoning: The board of directors is the grammatical subject actively overseeing cybersecurity risk management, meeting with the CISO, and approving programs — classic Board Governance. The CISO title is the sole IS-list fact, making this Firm-Specific; no second QV-eligible hard fact exists to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Board of directors oversees cybersecurity risk management, meets with CISO annually, discusses/approves programs and policies.

Category: Board Governance - the board is the grammatical subject performing oversight actions.

Specificity:
- "CISO" - cybersecurity-specific title → IS list → Firm-Specific
- "At least once a year" - generic cadence, not a specific date
- "Audit Committee" not mentioned, but "board of directors" is generic
- "Farmer Mac" is company self-reference → NOT list

So one IS fact (CISO). That's Firm-Specific (3).

No quantifiable facts here—no specific dates, financial figures, headcounts, or named external references that would qualify for the QV list.


reasoning: The majority of the paragraph describes how the Technology and Cybersecurity Committee and Audit Committee oversee cybersecurity risks, with management and CISO reporting structures subordinate to the board oversight framing. The final sentences on insurance and no material breaches touch Strategy Integration but are secondary. The named non-generic committee (Technology and Cybersecurity Committee) and cybersecurity-specific role (CISO) are IS-list facts yielding Firm-Specific, but no two QV-eligible hard facts are present (no dates, dollar amounts, headcounts, or named third-party firms).

thinking:
Let me analyze this paragraph carefully.

Content: This paragraph covers multiple topics:
1. Technology and Cybersecurity Committee oversight (Board Governance)
2. Audit Committee's role (Board Governance)
3. Management reporting to committees (Board Governance)
4. CISO attending committee meetings (Board Governance - CISO is subordinate to board oversight framing)
5. Cyber insurance (Strategy Integration)
6. No material breaches in last three fiscal years (Strategy Integration)

The dominant topic is board/committee oversight. The majority of the paragraph describes how the Technology and Cybersecurity Committee and Audit Committee oversee cybersecurity. The last few sentences about insurance and no material breaches are Strategy Integration, but they're secondary.

Looking at the sentence breakdown, five out of eight sentences focus on board governance structures and committee oversight, making that clearly the dominant theme. The specific committee names and their defined roles establish this as a substantive governance discussion rather than generic oversight language.

For verifiability, I have the named Technology and Cybersecurity Committee and the CISO title, but everything else—the quarterly cadence, Audit Committee reference, three-year timeframe, and independent directors—lacks the concrete specificity needed for quantitative verification. No dollar amounts, headcounts, named firms, or specific dates appear anywhere in the passage.

This lands as Firm-Specific because of those named committee and role identifiers, but it doesn't qualify as Quantitatively Verifiable since I'm missing the hard numerical or dated facts that would make it independently checkable.

fact: Technology and Cybersecurity Committee

fact: CISO attends committee meetings


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of third-party service providers' security — requirements imposed on vendors and assessments of their security frameworks. No named standards, specific roles, dates, or firm-specific details are present; 'periodically' is a generic cadence and 'third-party service providers' are unnamed.


reasoning: The paragraph describes internal cybersecurity processes—assessments, penetration testing, organizational structure, and employee training—making Risk Management Process the dominant category. The Audit Committee mention is incidental context. The named 'Global Data Protection and Cybersecurity Oversight Team' is a firm-specific named team unique to Tredegar, yielding one IS-list fact and Firm-Specific specificity. No second QV-eligible hard fact is present to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes assessment results presented to Audit Committee, penetration tests, organizational structure with a "Global Data Protection and Cybersecurity Oversight Team", cross-sector collaboration, and employee training.

Category: The primary content is about internal cybersecurity processes - assessments, pen tests, organizational structure, training. The Audit Committee mention is brief. This is Risk Management Process.

Specificity: Let me check for specific facts:
- "Audit Committee" - NOT list (generic)
- "penetration tests" - NOT list (common practice)
- "Global Data Protection and Cybersecurity Oversight Team" - This is a named team with a unique identifier → IS list (named non-generic committee/team)

- "annual formal information security training" - generic practice
- "phishing and email security best practices" - generic

The "Global Data Protection and Cybersecurity Oversight Team" is the only firm-specific element here, a named organizational unit. No quantifiable facts like dates, amounts, or third-party vendors mentioned, so this falls under Firm-Specific (3).


reasoning: The paragraph is about the IT Director as a person — their years of experience, certifications, educational background, and collaborative relationships — making it Management Role per the person-vs-function test. Multiple QV-eligible hard facts exist: specific years of experience (10 years), named certification bodies (EC-Council, ODU Global), and named universities (Universidade Catolica de Pernambuco, Universidade Federal de Pernambuco), well exceeding the two-fact QV threshold.

thinking:
Let me analyze this paragraph.

Content: About the IT Director - their qualifications, certifications, education, responsibilities, and collaboration with other executives. This is about the person - their background, credentials, experience. The person-vs-function test: the paragraph is primarily about who the IT Director is and their qualifications.

Category: Management Role

Specific facts:
- "IT Director" - this is a cybersecurity-specific title (Director of IT Security equivalent)... actually, "IT Director" is closer to "Director of IT" which is on the NOT list. Let me reconsider. The NOT list says "Head of IT", "IT Manager", "Director of IT" are generic IT titles. "IT Director" = "Director of IT" essentially. Hmm, but this person has cybersecurity expertise and oversees the cybersecurity program.

The codebook distinguishes between "Director of IT Security" on the IS list versus "Director of IT" on the NOT list, so "IT Director" falls into the generic category. However, the person has over 10 years of cybersecurity expertise and holds EC-Council certifications, both of which are QV-eligible specifics. I need to check what else is mentioned about their background.

Looking at the institutions and degrees listed, I see multiple named universities and a specific MBA in IT Management, which gives me well over the two QV-eligible facts needed. The team composition includes CFO and General Counsel (both on the NOT list), but "Compliance Manager" and "Human Resources Executive Director" as a specific team structure could indicate firm-specific context.

The paragraph focuses on this person's credentials and background rather than their management role, and I have multiple hard verifiable facts to work with—the 10+ years of experience, EC-Council certifications, and named educational institutions all support a Quantified-Verifiable classification.

fact: cybersecurity certifications from EC-Council

fact: certifications from ODU Global

fact: degree in Computer Science from Universidade Catolica de Pernambuco

fact: MBA in IT Management from Universidade Federal de Pernambuco


reasoning: The paragraph contains an explicit materiality assessment ('has not experienced any material cybersecurity incidents' and 'materially affected or are reasonably likely to materially affect... business strategy, results of operations or financial condition'), making it Strategy Integration per Rule 6. The cross-reference to Item 1A does not change the classification since a materiality conclusion is present. No specific facts from the IS list are present — 'last three fiscal years' is a vague timeframe, and the named Risk Factors subsection is a company self-reference.

thinking:
Materiality assessment + cross-reference. The paragraph makes an explicit materiality claim ("has not experienced any material cybersecurity incidents") and references whether risks "have materially affected or are reasonably likely to materially affect" business strategy/results/financial condition. Per Rule 6 and the codebook, this is Strategy Integration.

Specificity: "last three fiscal years" is a vague timeframe, not a specific date. The cross-reference to a specific Risk Factors subsection name is company-specific but it's a self-reference. No named frameworks, no hard facts. Generic Boilerplate.


reasoning: The paragraph is about the people on the CIRT and VP-IT — their experience, skill sets, and certifications — making it Management Role under the person-vs-function test. Numerous QV-eligible hard facts are present: specific years of experience (28, 67), specific certification count (29), and multiple named certifications (CISSP, CISM, CRISC, etc.) and credentialing organizations (ISC2, SANS, CompTIA, Cisco).

thinking:
Let me analyze this paragraph.

Content: Describes the CIRT team, their skills, the VP-IT's experience, team experience, and numerous certifications held by team members.

Category: This is about the people - their qualifications, experience, certifications. The person-vs-function test: the paragraph is about WHO these people are (experience, certifications, skill sets), not about WHAT processes they run. → Management Role

Specificity: Let me count hard verifiable facts:
- VP - IT (cybersecurity-specific title? It's "VP - IT" which is more like generic IT leadership... but let me check the IS list. "VP of IT/Security" is listed. This is "VP - IT" which seems to match.)

- 28 years of experience for the VP, 67 years combined across the team, and 29 certifications total - these are concrete numbers I can verify. The certifications themselves are named: CISSP, GCIH, GCCC, GMON, SSAP, CISM, CRISC, CISA. The issuing organizations are also specified: ISC2, SANS Institute, GIAC, CompTIA, Cisco. The team itself is identified as CIRT (Cybersecurity Incident Response Team), which is a named internal program. All of these are QV-eligible facts.

fact: VP - IT

fact: Cybersecurity Incident Response Team (CIRT)

fact: 28 years of experience in information systems and cybersecurity

fact: 67 years of additional combined experience

fact: 29 certifications in risk and information security

fact: CISSP

fact: GCIH

fact: GCCC

fact: GMON

fact: SSAP

fact: CISM

fact: CRISC

fact: CISA


reasoning: The paragraph describes how cybersecurity risk information flows through the organization — regular reporting to executive leadership and integration into ERM via internal audit. Applying the person-vs-function test: remove the CSTO title and the paragraph still describes processes (reporting cadence, ERM integration, internal audit of controls). The content is about the function, not the person's credentials or background. The 'Chief Security and Trust Officer' is a cybersecurity-specific title unique to Cisco's structure, qualifying as a firm-specific fact, but no second hard verifiable fact exists to reach QV.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. Chief Security and Trust Officer reports to executive leadership team
2. Cybersecurity risk integration into ERM through internal audit function

The primary actor in the first sentence is "The Chief Security and Trust Officer" - a management role. But the content describes what they do (reporting) and how cyber risk is integrated into ERM.

Person-vs-function test: Remove the role title - "Regular reports on the status of cybersecurity risks... integrated into broader enterprise risk management program through internal audit function." This is about processes - reporting and ERM integration.

Actually, the first sentence has the Chief Security and Trust Officer as the subject doing reporting. The second sentence is about ERM integration.

This is really about the operational processes - how cybersecurity risks get reported and woven into the broader enterprise risk management framework through the internal audit function. The CSTO is just the attribution point for where these reports originate. The paragraph focuses on Risk Management Process, not on the person's qualifications or background. The "Chief Security and Trust Officer" title is cybersecurity-specific, but the substance here is about the function and flow of risk reporting.

fact: Chief Security and Trust Officer


reasoning: The paragraph names a cybersecurity-specific role (CIO/VP-IT), describes their credentials (CISSP, 20+ years experience), reporting line to CFO, and team qualifications (USG clearances, additional CISSP member). While risk management processes are mentioned, the dominant content is about who the person is and their qualifications — the person-vs-function test points to Management Role. QV threshold met with CISSP certification + 20+ years of experience as two hard verifiable facts.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes:
1. Cyber risk assessment process
2. VP-IT/CIO role, reporting to CFO
3. CIO's CISSP certification, 20+ years experience
4. Team members with USG security clearances, additional CISSP member
5. External participation activities

Person-vs-function test: The paragraph spends significant text on who the CIO is (credentials, experience, reporting line) and the team's qualifications. But it also describes processes. The dominant content is about the people - who leads the effort, their qualifications, reporting structure, team credentials.

Actually, let me re-read. The paragraph starts with risk management process, then pivots to who leads it (CIO), their qualifications, reporting line, team qualifications.

The focus here is really on the people and their credentials rather than the process itself. Looking at what's verifiable: the CIO holds a CISSP certification and has over 20 years in the field—those are concrete facts I can check. The team has USG security clearances and includes another CISSP member. The CFO reporting line is just a generic corporate structure detail. So this qualifies as Quantified-Verifiable based on the specific certifications and years of experience mentioned.

fact: Vice President – Information Technology and Chief Information Officer (CIO)

fact: CISSP certification

fact: Over 20 years of information systems and information security leadership experience

fact: USG security clearances held by team members

fact: One additional CISSP certified team member


reasoning: While the CIO and CFO are the grammatical subjects, the paragraph's primary communicative purpose is describing how cybersecurity information flows upward to the Audit Committee and Board of Trustees for oversight — quarterly updates, annual reviews, and committee member expertise. The board/committee oversight structure is the dominant theme. Specificity is Firm-Specific: CIO is a cybersecurity-specific title (IS list), and 'two members' is a specific headcount, but only the headcount is QV-eligible (CIO as a named role does not count toward QV), yielding one QV fact — not enough for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes CIO reporting to CFO, then both reporting to Audit Committee and Board of Trustees. Mentions quarterly updates, annual reviews, committee member expertise.

Category: The paragraph describes reporting lines and oversight. The primary actors are CIO and CFO reporting TO the Audit Committee and Board. The dominant theme is board/committee oversight - the Audit Committee receives quarterly updates, annual reviews, and has members with cybersecurity expertise. The Board of Trustees gets annual reviews too.

Actually, let me reconsider. The first sentence has CIO reporting to CFO - that's management role territory. But then the bulk of the paragraph is about providing information to the Audit Committee and Board of Trustees, with committee expertise mentioned. The board/committee is the entity being served/informed.

The grammatical subjects are management roles, but the real focus is on how oversight flows to the board through the Audit Committee. The paragraph mixes management structure with governance oversight, though the emphasis falls on what information and expertise the board receives for its oversight function.

This is Board Governance. The CIO is a firm-specific role that appears on the IS list, which gives us a Firm-Specific classification. But checking for quantifiable verification—there are no dates, dollar amounts, or hard facts beyond the role name itself, so this doesn't meet the QV threshold.

fact: CIO is a cybersecurity-specific leadership role

fact: Two members of the Audit Committee possess cybersecurity and information systems experience


reasoning: The paragraph's primary communicative purpose is explaining how cybersecurity threats translate to potential business, financial, reputational, and competitive impact — core Strategy Integration territory. It discusses threat landscape context, potential material/adverse business impacts from cyber risks (including third-party and client-attributed incidents), and general investment in security infrastructure. However, it contains no actual materiality assessment conclusion, no specific budget or insurance details, no named frameworks, roles, dates, or firm-specific facts — everything is generic threat/risk language applicable to any technology company.

thinking:
Let me analyze this paragraph.

Content: Describes common cybersecurity threats (phishing, DDoS, malware, ransomware), AI-related risks, third-party/supply chain risks, client infrastructure vulnerabilities, and general investment in security. This is general risk language - it describes threats the company faces but doesn't describe specific processes, governance, incidents, or strategy details.

Category: This reads like general risk language. It mentions third-party risks but as part of a broader threat landscape description. There's mention of "materially and/or adversely impact" but it's hypothetical/forward-looking, not an actual materiality assessment. The last sentence mentions investing in security but is very generic.

This is fundamentally threat landscape language that doesn't fit cleanly into any substantive category—it's not describing governance, management roles, specific risk processes, or actual third-party risk management, just the general threat environment and conditional language about potential impacts. it's really just generic threat landscape language without substantive detail about actual programs or governance structures. The investment statement is too vague to constitute a real strategy disclosure. I'm leaning toward None/Other since this reads more like boilerplate risk acknowledgment than meaningful cybersecurity disclosure. The materiality language here is forward-looking and hypothetical rather than a substantive assessment, so this doesn't fit Strategy Integration's definition of explicit materiality conclusions. The paragraph is really just general risk factor language about potential threats and business impacts without naming specific programs, governance structures, or strategic decisions. I'll categorize this as None/Other with Generic Boilerplate specificity.

But wait—I need to reconsider whether None/Other even applies here. The paragraph does contain cybersecurity content, not just headers or disclaimers. Rule 5 says to assign None/Other only when there's no substantive disclosure. This is describing threat types and potential impacts, which is cybersecurity content, but it's entirely generic and tells us nothing about the company's actual governance, processes, or risk management approach. This feels like a borderline case—risk factor language that belongs in a different section, not substantive disclosure about the company's cybersecurity posture.

Looking at it again, the paragraph does touch on supply chain risks and security investments, which could suggest Strategy Integration. But the execution is so generic—just listing threat types and mentioning "our clients" and "our acquisition targets" without any real detail—that it reads more like boilerplate risk language than actual strategy disclosure. I'm going to classify this as None/Other with Generic Boilerplate specificity, since the paragraph lacks substantive disclosure about the company's cybersecurity program or governance. I keep second-guessing myself on this. The paragraph does extensively discuss cybersecurity, which makes None/Other feel off per the rules, but the examples for Strategy Integration all show concrete assessments or actual business decisions, whereas this is purely hypothetical risk language without any real materiality conclusion. I'm going to commit to None/Other—this is general threat landscape description without the substantive strategic assessment that would trigger the other categories. Looking back at the specific details, point 4 stands out—the idea that client infrastructure vulnerabilities could be attributed to Tyler's software is actually somewhat distinctive to their business model as a software provider, even though the rest of the paragraph relies on generic threat language. The overall purpose is risk contextualization, explaining why cybersecurity matters to the business through the lens of potential impact and investment. Given that there are no firm-specific facts beyond that one point about client attribution, I'm settling on Strategy Integration with Generic Boilerplate classification.


reasoning: The paragraph describes the company's internal cybersecurity processes: security measures, employee training, disaster recovery, and business continuity planning. Third parties are mentioned as a component of the internal program (Rule 3), not as the central topic. No named frameworks, roles, tools, firms, dates, or specific numbers appear — everything described (training, disaster recovery, business continuity evaluation) is generic and could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes security measures, employee training, third-party IT support, disaster recovery, business continuity plans, and evaluating third-party service provider threats.

Category: This is primarily about the company's internal cybersecurity processes - security measures, training, disaster recovery, business continuity. Third parties are mentioned but as components of the internal program. → Risk Management Process

Specificity: Let me check for specific facts:
- No named frameworks, no named roles, no named tools, no dates, no numbers, no named firms
- "third parties" is generic, "cybersecurity training" is generic, "business continuity plans" is generic

- Nothing on the IS list → Generic Boilerplate


reasoning: The Board of Directors is the grammatical subject performing the primary action — appointing and delegating cybersecurity risk oversight responsibility to a management officer. Per Rule 2, board delegation to management is Board Governance. The named title ('Senior Managing Executive Officer and Chief Officer for Automobile Operations') is not a cybersecurity-specific role from the IS list (not CISO/CTO/CIO), and 'Risk Management Officer' is a general corporate role, so no specific facts qualify.

thinking:
Let me analyze this paragraph from American Honda Finance Corp's 10-K filing, Item 1C.

The paragraph describes Honda's Board appointing a specific officer (Senior Managing Executive Officer and Chief Officer for Automobile Operations) as the Risk Management Officer who monitors cybersecurity risks.

Category: The Board is the actor appointing, but the substantive content is about who fills the risk management role. The board's action (appointing) sets up the management role. The paragraph tells us about who the person is (their title) and what they do. The grammatical subject starts with "Board of Directors" but the purpose is to identify the management role holder. This is a borderline Board vs Management case.

The board appointed this person as Risk Management Officer, which is a delegation of responsibility from the board to management. Per the tiebreaker rule, when the board delegates responsibility to management, that's Board Governance. However, the title "Senior Managing Executive Officer and Chief Officer for Automobile Operations" isn't a cybersecurity-specific role like CISO or CIO, so it's not on the Information Security list.


reasoning: The paragraph describes management-level committee structures (Company Operating Committees, Confidentiality Committees) responsible for cybersecurity, their reporting lines, and their membership composition. The primary subjects are management committees and their roles/composition, not the board and not internal processes — fitting Management Role. Multiple firm-specific facts (named non-generic committees like Confidentiality Committees, CISO role, specific team composition) establish Firm-Specific, but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools) reach the two-fact threshold for Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes management committees (Company Operating Committees, Confidentiality Committees) and their roles in cybersecurity oversight, including membership composition.

Category: This is about management committees responsible for cybersecurity. The grammatical subjects are committees (Company Operating Committees, Confidentiality Committees). These are management-level committees, not board committees. The paragraph describes their roles and composition. This fits Management Role - it's about the organizational structure of who manages cybersecurity at the management level.

Wait - let me reconsider. The committees advise the President on operations including cybersecurity. The Confidentiality Committees include CISO, Risk Management Officers, etc.

Looking at the specific details here, I'm seeing named committees like the Confidentiality Committees with clearly defined cybersecurity roles - the CISO is explicitly mentioned as a cybersecurity-specific title, and the Risk Management Officers represent firm-specific positions. The composition includes these specialized roles alongside broader organizational representation, which confirms this is about the management-level structure overseeing cybersecurity operations.

I'm checking whether this qualifies as quantifiable - there are no dates, financial figures, headcounts, third-party vendor names, tools, or certifications mentioned, so this stays in the Firm-Specific category rather than QV-eligible.

fact: Company Operating Committees

fact: North American Regional Operating Board

fact: Confidentiality Committees

fact: Chief Information Security Officer

fact: Committee composition: Risk Management Officers, CISO or IT representative, and members from various areas


reasoning: The paragraph describes the cybersecurity team's internal process for building a strategic vision, setting risk management goals, and tracking/reporting outcomes — all process activities. The CISO is mentioned as attribution ('led by the CISO') rather than as the paragraph's subject; removing it, the paragraph still describes processes. Reporting to the Audit Committee and CEO is incidental. CISO is a cybersecurity-specific title (IS list), yielding Firm-Specific; no second QV-eligible hard fact exists.

thinking:
Let me analyze this paragraph.

Content: Describes how the cybersecurity team builds a strategic vision, sets goals, and reports to CEO and Audit Committee. The CISO is mentioned as leading the team. The paragraph describes internal processes (goal-setting, tracking, reporting) with the cybersecurity team as the primary actor.

Category: This is about the cybersecurity team's process for setting goals and integrating into risk management. The CISO is mentioned as attribution ("led by the CISO"). The primary content is about the process - building strategic vision, setting goals, tracking, reporting. This is Risk Management Process with the person-vs-function test - remove "led by the CISO" and it still describes processes.

The reporting goes to the CEO and Audit Committee, but they're recipients rather than the main subject. The CISO is the only firm-specific title here, while CEO and Audit Committee are generic governance roles. There's one IS fact with the CISO designation, but no quantifiable details like dates or headcounts.

fact: CISO leads the cybersecurity team


reasoning: The Audit Committee is the primary subject overseeing cybersecurity risks, with management figures reporting TO it — classic Board Governance framing. All named roles (CFO, CAO, VP of Internal Audit) are generic corporate titles on the NOT list, not cybersecurity-specific titles; 'Audit Committee' is standard governance; 'annual' and 'as needed' are generic cadences. No IS-list facts remain after filtering.

thinking:
Let me analyze this paragraph.

Content: Board/Audit Committee oversight of cybersecurity, with management reporting to the committee. The Audit Committee is the primary subject - it oversees cyber risks, and management reports TO it.

Category: Board Governance - the Audit Committee is the entity being described as overseeing cybersecurity risks, and management figures report to it.

Specificity analysis:
- "Audit Committee" - NOT list (generic governance)
- "Executive Vice President and Chief Financial Officer" / "CFO" - NOT list (generic C-suite)
- "Chief Accounting Officer and Corporate Controller" / "CAO" - NOT list (generic C-suite)

- "Vice President of Internal Audit" - also a generic corporate role, not cybersecurity-specific
- "annual update" - just a standard reporting cadence
- "IT management" - generic terminology

None of these roles are cybersecurity-specific titles like CISO, CTO, or CIO. There are no named frameworks, specific dates, or particular tools mentioned. This is clearly generic boilerplate language.


reasoning: The entire paragraph describes the CISO's personal qualifications — degree, university, years of experience, and certification tenure. This is squarely about the person, not the function. Multiple QV-eligible hard facts: named university (Washington State University), specific years of experience (24), named certification (CISSP), and specific certification duration (19 years).

thinking:
Classify this paragraph about GBCI's CISO credentials.

Content: About the person - degree, experience, certifications. Clear Management Role.

Specific facts:
- Named university: Washington State University (QV-eligible)
- 24 years of experience (QV-eligible - specific number)
- CISSP certification (QV-eligible - named certification)
- 19 years holding CISSP (QV-eligible - specific number)

Multiple QV-eligible facts → Quantified-Verifiable

fact: Degree from Washington State University

fact: Over 24 years of experience in cybersecurity

fact: CISSP held for over 19 years


reasoning: The paragraph's dominant content describes the company's internal cybersecurity program: policies and procedures, external assessments, biannual NIST CSF maturity assessments, and incident response preparedness reviews. Third-party vendor requirements, insurance, and a closing materiality disclaimer are subordinate components. The NIST CSF reference triggers at least Sector-Adapted, and the specific date 'fiscal 2023' in the materiality sentence is an IS-list fact elevating to Firm-Specific. Only one QV-eligible hard fact (fiscal 2023), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This is a dense paragraph covering multiple topics. Let me identify them:

1. Information security program - policies, procedures (Risk Management Process)
2. Third-party vendor requirements (Third-Party Risk)
3. Technology team (Management Role / RMP)
4. External third-party assessments (Risk Management Process)
5. NIST CSF biannual maturity assessments (Risk Management Process)
6. Cyber insurance (Strategy Integration)
7. Materiality disclaimer (Strategy Integration)

The dominant content is about the company's internal risk management processes - the program, policies, assessments, external reviews, NIST framework alignment. The third-party vendor mention is one component of the broader program. The materiality statement and insurance are at the end.

Now I'm checking the specificity of the details mentioned. The NIST Cybersecurity Framework is a named framework that counts as sector-adapted, and fiscal 2023 is a specific date that should be flagged. The biannual cadence for assessments is mentioned, though generic timeframes like quarterly or annual don't typically count as specifics. I'm also noting that the third-party vendor requirements are present but secondary to the main focus on internal risk management processes. So the materiality statement shouldn't pull the whole paragraph into Strategy Integration—the core focus is really on risk management processes. Even though that final sentence mentions materiality, it's just one line at the end of a much longer discussion about how they manage risks. The category should be Risk Management Process, and since "fiscal 2023" gives us a specific date and NIST CSF is a named framework, this lands as Firm-Specific.

fact: NIST Cybersecurity Framework

fact: fiscal 2023


reasoning: The paragraph introduces the Security Committee and CIO but the bulk of the content describes what the committee *does*: reviewing governance KPIs (events, investigations, mean response time), overseeing the security roadmap, and monitoring policies covering backup, disaster recovery, incident management, etc. Applying the person-vs-function test, the substantive content is about internal processes and monitoring activities, not the people's credentials or backgrounds — replacing 'The Security Committee' with 'The Company' leaves the process description intact. The Security Committee (non-generic named committee) and CIO (cybersecurity-specific title) are firm-specific facts, but neither qualifies as QV-eligible (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a "Security Committee" led by the CIO, comprised of IT department individuals including dedicated security team members. It describes what this committee does: reviews information security program governance, KPIs, oversees security roadmap, monitors policies and procedures.

**Content Category:**
This is about a management-level committee (Security Committee) and its functions. The Security Committee is led by the CIO - this is a management committee, not a board committee. The paragraph describes what the committee does (reviews, oversees, monitors).

Is this Management Role or Risk Management Process? The person-vs-function test: The paragraph names the Security Committee and CIO, but the bulk of the content describes what the committee *does* — reviews governance, KPIs, oversees roadmap, monitors policies.

The substantive content focuses on the function and processes rather than the people's roles or qualifications. The Security Committee serves as the mechanism through which these processes—reviewing governance, monitoring KPIs, overseeing the roadmap, and tracking policies—are executed. So this leans toward **Risk Management Process**, where the committee and CIO are just the organizational structure enabling the actual work being described.

For specificity, "Security Committee" is a named, firm-specific committee and "CIO" is a cybersecurity-specific title, both of which appear on the IS list. The security certifications mentioned are generic, so they don't add firm-specific detail.

Looking at the quantifiable verification check: the CIO is a named role and the Security Committee is a named committee, but neither qualifies as a hard verifiable fact in the QV sense. There are no dates, dollar amounts, headcounts, named firms, tools, or specific certifications listed. This doesn't meet the QV threshold.

So this lands as Firm-Specific.

fact: Security Committee (named non-generic committee)

fact: CIO leads the Security Committee


reasoning: The paragraph contains an explicit materiality assessment ('not aware of any cybersecurity incidents that have materially affected us'), which per Rule 6 makes it Strategy Integration even though it also includes a cross-reference to Risk Factors and a forward-looking caveat. No firm-specific facts, named standards, or verifiable details are present — the materiality language is boilerplate.

thinking:
Let me analyze this paragraph.

Content: Materiality assessment ("not aware of any cybersecurity incidents that have materially affected us") + forward-looking caveat + cross-reference to Risk Factors.

Category: The paragraph contains an explicit materiality assessment - "not aware of any cybersecurity incidents that have materially affected us." Per Rule 6 and the codebook, this is Strategy Integration. The cross-reference doesn't change it.

Specificity: The materiality language is boilerplate. No named entities, no dates beyond generic, no specific facts. → Generic Boilerplate.


reasoning: The paragraph identifies who is responsible for cybersecurity leadership (CFO as accountable leader) and management's responsibility scope, making it about the person/role rather than the processes themselves. However, CFO is a generic C-suite title per the IS-NOT list, 'management' is generic, and the activities listed (identifying, assessing, prioritizing, managing, mitigating) are boilerplate — no cybersecurity-specific titles, named frameworks, or firm-specific facts remain after validation.

thinking:
Let me analyze this paragraph.

Content: Management's role in cyber risk, CFO identified as accountable leader for IT and cybersecurity.

Category: This is about who is responsible - the CFO is identified as the accountable leader. The paragraph tells us about the person's role (CFO as accountable leader for cybersecurity). But the first sentence is generic about management responsibilities. The second sentence names CFO as the specific leader - but CFO is on the "IS NOT" list as generic C-suite. However, the fact that the CFO (not a CISO) is the accountable leader for cybersecurity is somewhat notable.

Wait - the person-vs-function test: The first sentence describes what management does (day-to-day risk management activities).

The second sentence identifies the CFO as the accountable leader, which is more about role assignment than describing what the program actually does. Since the paragraph is telling us who's responsible rather than what processes or frameworks are in place, and the CFO falls under generic C-suite terminology, this lands in generic boilerplate territory. The activities mentioned—identifying, assessing, prioritizing, managing, mitigating—are all standard language without any specific frameworks or concrete details from the IS list.


reasoning: The paragraph describes the company's general approach to cybersecurity risk management — developing a risk appetite, balancing innovation with risk mitigation, and ensuring risks are measured and managed. While extremely generic, this is about the company's own internal risk management philosophy rather than board oversight, a specific person, or a materiality assessment. No named frameworks, roles, dates, or firm-specific facts are present; the company self-reference does not count.

thinking:
Let me analyze this paragraph.

Content: General risk acknowledgment language about the financial industry, threat landscape, and commitment to balancing innovation with risk mitigation. Mentions developing a "risk appetite" aligned with strategic goals. Ends with company name.

Category: This is general business language about risk. It mentions cybersecurity tangentially ("cyberattacks and information security incidents") but the primary content is about general risk philosophy. However, it does discuss risk management approach - "risk appetite," "framework," balancing innovation and risk mitigation. This leans toward Risk Management Process but is extremely generic.

Actually, re-reading: "we have developed a risk appetite that aligns with our strategic goals and regulatory requirements. This framework encourages innovation while ensuring our risks are well-understood, measured, and managed." This is describing their risk management approach, albeit very generically.

The language is completely generic boilerplate with no specific frameworks, metrics, or named roles mentioned. It's categorized as Risk Management Process since it describes their approach to managing cyber risk, but it lacks any concrete details or evidence of actual implementation.


reasoning: The paragraph's primary purpose is identifying the security governance function's composition — naming specific teams (Information Security, Legal, Privacy) and cybersecurity-specific roles (CIO, CISO) who are responsible for various activities. While it lists what they do (policies, IRP, incident response), these describe the scope of the named roles' responsibilities rather than detailed process methodology. Multiple IS-list facts (CISO, CIO, specific team composition) establish Firm-Specific, but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools) are present.

thinking:
Let me analyze this paragraph carefully.

Content Category: This describes management roles and their responsibilities. The grammatical subjects are "Our security governance function" and key employees including CIO and CISO. But the person-vs-function test: the paragraph describes what the function does (establishing policies, developing IRP, managing incident response, overseeing exceptions). The CIO and CISO are mentioned as examples of who's in the function, but the content is about processes and responsibilities. However, the paragraph is primarily about WHO is responsible - it names specific roles and team compositions.

Actually, let me re-read. "Our security governance function, which includes key employees who work in Information Security, Legal, and Privacy teams, such as our CIO and CISO, are responsible for..." - This is about the management structure and who is responsible. The activities listed (establishing policies, developing IRP, managing incident response) describe what these people do, but the primary purpose is identifying WHO does it.

Now I'm testing whether this is really about the management structure or the processes themselves. If I strip away the role titles and team names, the core content still reads as a process description—establishing policies, developing incident response plans, managing incidents, overseeing exceptions. But the paragraph leads with organizational structure and role identification, which suggests its primary intent is defining who's accountable. This is a borderline case since it emphasizes both the people and their responsibilities equally.

Looking back at the codebook examples, I notice the CISO example that describes the cybersecurity program's activities is classified as Risk Management Process, not Management Role. My paragraph is structured similarly—it names the roles and then lists what they do. The key difference might be whether the paragraph's main point is "here's our governance structure" versus "here's what our cybersecurity program encompasses." I'm leaning toward Management Role because the governance composition and accountability structure seem to be the primary focus, with the activities serving as scope definition rather than detailed process steps.

Now I'm checking the specificity criteria. The CIO and CISO are both on the Information Security list, and "Information Security, Legal, and Privacy teams" clearly identifies specific team compositions. The "Incident Response Plan" has an abbreviation but isn't particularly unique or distinctive—it's a standard practice name rather than a proprietary program.

Looking at the quantifiable verification requirement, I don't see any hard facts like dates, dollar amounts, headcounts, or named external firms. The named roles themselves don't count toward QV. Since there's at least one Information Security fact present, this qualifies as Firm-Specific rather than Quantifiable Verification.

fact: CIO (Chief Information Officer)

fact: CISO (Chief Information Security Officer)


reasoning: The paragraph describes the company's internal Enterprise Risk Committee and how it integrates cybersecurity into the ERM framework, BCDR planning, and incident assessment—all internal process content. While the ERC is a management-level committee, the paragraph's primary communicative purpose is describing processes (ERM integration, team composition for incident response, third-party risk evaluation), not the individuals' qualifications. Contains firm-specific facts (named ERC committee with unique identifier, specific departmental composition of the response team) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, or named third-party firms/tools).

thinking:
Let me analyze this paragraph.

Content: Describes the Enterprise Risk Committee (ERC), its composition, cross-functional nature, integration of cybersecurity into ERM framework, BCDR planning, service provider management, and the assessment/response team composition.

Category: This is about internal risk management processes - the ERC's role in managing operational risk including cybersecurity, ERM integration, BCDR planning, incident assessment team composition. The ERC is a management-level committee, not a board committee. The paragraph describes what the company's internal processes and structures do. → Risk Management Process

Specific facts:
- "Enterprise Risk Committee ("ERC")" - named committee with unique identifier → named_committee (this is a non-generic committee name)

- The committee comprises company executives leading day-to-day risk management, so it's management-level rather than board governance
- Information security, risk management, compliance and legal groups form the cross-functional team composition → named_team
- BCDR planning program and service provider management policy are named internal programs
- The paragraph focuses on internal processes and structures, not board-level governance → Risk Management Process
- These are firm-specific facts but lack the quantifiable elements needed for QV eligibility (no dates, dollar amounts, headcounts, or named third parties) → Firm-Specific (3)

fact: Enterprise Risk Committee ("ERC")

fact: information security, risk management, compliance and legal groups compose the assessment and response team

fact: BCDR planning program


reasoning: The paragraph introduces the company's awareness of cybersecurity risk categories, framing it as risk assessment/identification language under Item 106(b). However, it contains no specific processes, frameworks, roles, or firm-specific details — it is entirely generic language that could apply to any company.


reasoning: The paragraph's primary purpose is identifying which management roles are responsible for cybersecurity risk — General Counsel, Assistant General Counsel–Compliance, CEO, and the legal/compliance team working with IT leaders. While it touches on risk management activities, the dominant content is about organizational responsibility allocation. No cybersecurity-specific titles (CISO, CIO, CTO) appear; General Counsel and CEO are on the NOT list as generic C-suite, and 'IT leaders' is unnamed/generic, so no IS-list facts are present.

thinking:
Let me analyze this paragraph.

The paragraph describes who drives the cybersecurity program and who is responsible for risk management. Let me apply the person-vs-function test.

Content: General Counsel and Assistant General Counsel – Compliance drive the program. Executive leadership team including CEO and management team are responsible for identifying/assessing/managing/mitigating risks. Legal and compliance team works with IT leaders on cybersecurity risks.

This is about management roles and responsibilities - who is responsible for what. But let me check: is this about the *person* (credentials, background) or the *function* (what the program does)?

The paragraph describes organizational responsibility - who does what.

So the key question is whether this is really about the people themselves or about the functions they perform. When I strip away the role titles, what's left are the actual functions: driving the program, identifying and assessing risks, managing and mitigating them, working with IT leaders to evaluate cybersecurity risks. The management figures are just the vehicles for these functions, not the focus. This leans toward function rather than person. The paragraph is really about organizational structure and how risk management responsibilities flow through the company—legal and compliance coordinate with IT leadership while the executive team handles identification and assessment. Even though it mentions specific titles like Assistant General Counsel for Compliance, those aren't cybersecurity-specific roles, so the specificity score stays low. This lands in Management Role since it's fundamentally describing who's accountable for cybersecurity within the organization and how those responsibilities connect across departments. Looking at the person-versus-function distinction more carefully, this paragraph is really about establishing who holds responsibility for cybersecurity rather than describing how the process works. Even though it touches on risk management activities, the emphasis is on the organizational structure and roles. I'm settling on Management Role as the category with moderate confidence, since the primary intent is to identify the management structure overseeing cybersecurity.


reasoning: The paragraph lists components of the company's information security program — oversight structure and a documented incident response plan. While it mentions the board and senior management, these are listed as elements of the broader program, not as the primary focus. The named 'Risk Committee' (a non-generic board committee) qualifies as a firm-specific fact, but no second hard verifiable fact exists to reach QV.

thinking:
Let me analyze this paragraph.

Content: mentions oversight by senior management, board-level Risk Committee, Board of Directors, and a Cybersecurity Incident Response Plan.

Category: This describes components of the company's cybersecurity program - oversight structure and incident response planning. The primary content is about internal processes/program components. It mentions board and management oversight as components of the broader risk management program, not as the central focus. → Risk Management Process

Specific facts:
- "Risk Committee" — named non-generic committee (IS list) → Firm-Specific
- "Cybersecurity Incident Response Plan" — generic program name without unique identifier, no abbreviation that distinguishes it... wait, it's just "Cybersecurity Incident Response Plan" which is fairly generic.

The Incident Response Plan isn't on the IS list, so that's not firm-specific. But the Risk Committee is a named non-generic committee that appears on the IS list, giving me one firm-specific fact. There are no quantitative values like dates, dollar amounts, headcounts, or named external firms or tools. So this falls under Firm-Specific (3).

fact: board-level Risk Committee


reasoning: The paragraph opens with an explicit materiality assessment ('no material cybersecurity incidents in 2024'), making it Strategy Integration per Rule 6. The remainder is generic threat landscape language and a cross-reference to Risk Factors. The year 2024 is a specific date anchoring the materiality claim to this company, yielding one IS-list fact and Firm-Specific specificity.

thinking:
Let me analyze this paragraph.

Content: States no material incidents in 2024, discusses potential future threats, references Risk Factors. The first sentence is a materiality assessment. But the bulk of the paragraph is generic risk language about threats. The last sentence is a cross-reference.

Category: The opening statement "We had no material cybersecurity incidents in 2024" is a materiality assessment. Then it goes into generic threat landscape language. The materiality assessment at the start is the substantive disclosure per Rule 6. → Strategy Integration

Specificity: "in 2024" is a specific date. But the rest is boilerplate. Let me check - "2024" is a specific date reference.

The year 2024 ties this to the company's actual experience, making it firm-specific even though it's just a fiscal year reference. That's one concrete fact from the IS list.


reasoning: The paragraph describes the company's internal cybersecurity policies, risk-based approach, written procedures, and annual training requirements — all core risk management process activities. No named frameworks, cybersecurity-specific roles, tools, dates, or other specific facts are present; 'annually' is a generic cadence and 'social engineering, cybersecurity, and compliance training' are common practices.

thinking:
Let me analyze this paragraph.

Content: Describes the company's risk-based approach, cybersecurity policies, written procedures, and annual training requirements. This is about internal processes.

Category: Risk Management Process - describes internal cybersecurity processes, policies, and training.

Specificity: Let me check for specific facts.
- No named frameworks (NIST, ISO, etc.)
- No cybersecurity-specific titles (CISO, CIO, etc.)
- No named tools, firms, dates, numbers
- "social engineering, cybersecurity, and compliance training programs annually" - common practices, generic cadence
- "written policies and procedures" - generic

- "risk-based approach" and "nonpublic information" are standard regulatory language without concrete details

No IS-list facts or named standards present, so this qualifies as generic boilerplate.


reasoning: The paragraph primarily describes a specific cybersecurity incident — the MOVEit security event in May 2023 — including timeline, response actions (decommissioning, forensic engagement), scope (no customer data compromised), and operational impact. While a materiality assessment appears at the end, the dominant content is the incident narrative. Two QV-eligible hard facts: specific date (May 2023) and named product (MOVEit).

thinking:
Let me analyze this paragraph.

Content: Describes a specific cybersecurity incident (MOVEit security incident in May 2023 at Umpqua Bank), response actions, forensic engagement, and a materiality assessment.

Category: This describes what happened in an incident - timing, scope, response, and impact. The dominant content is the incident narrative. There's a materiality statement at the end, but the bulk is incident description. → Incident Disclosure

Specificity facts:
- "May 2023" - specific date
- "MOVEit" - named product/system
- "Umpqua Bank" - company self-reference (NOT list)

- "independent forensics firm" - unnamed (NOT list)
- Materiality language - boilerplate

The paragraph has two hard verifiable facts: the specific date and the named product, which qualifies it as Quantified-Verifiable.

fact: MOVEit (named product/system involved in incident)


reasoning: The paragraph describes the company's internal data protection processes — DLP, classification labels, encryption for structured and unstructured data. These are internal cybersecurity activities, making it Risk Management Process. No named frameworks, tools, dates, or other specific facts from the IS list are present; 'industry cybersecurity standards' is generic.

thinking:
Classify this paragraph.

Content: Describes data classification, DLP, encryption, structured/unstructured data protection. Internal processes/tools.

Category: Risk Management Process - describes internal cybersecurity processes.

Specificity: No named frameworks, no named tools, no dates, no numbers. "industry cybersecurity standards" is generic. "ERP systems" is generic. No IS-list facts. → Generic Boilerplate.


reasoning: The paragraph describes external parties engaged to perform vulnerability monitoring and scanning for the company's own IT environment. Per Rule 3, external assessors hired to test/monitor the company serve the company's internal security program, making this Risk Management Process rather than Third-Party Risk. No named firms, tools, frameworks, dates, or quantified facts are present — 'third parties' and 'vulnerability scanning' are generic.

thinking:
Classify this paragraph.

Content: Describes engaging third parties for vulnerability monitoring and scanning. The central topic is what these external parties do for the company - monitoring, assessment, vulnerability scanning. But are these third parties being overseen (Third-Party Risk) or are they serving the company's internal security processes (Risk Management Process)?

Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." These third parties are providing assessment and scanning tools to detect vulnerabilities - they serve the company's security program.

Category: Risk Management Process

Specificity: No named frameworks, no named firms, no named tools, no dates, no numbers. "third parties" is generic. "vulnerability scanning" is a common practice. → Generic Boilerplate.


reasoning: The paragraph's central topic is managing cybersecurity risk associated with third-party service providers through due diligence, monitoring, and contractual obligations — all squarely about requirements imposed on vendors. No named frameworks, specific facts, dates, or firm-specific details are present; the language is generic and could apply to any company.

thinking:
Classify this paragraph.

Content: About managing cybersecurity risk with third-party service providers - due diligence, monitoring, contractual obligations. Central topic is vendor oversight.

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

Specificity: No named frameworks, no firm-specific facts, no dates, no names. Generic practices described. → Generic Boilerplate


reasoning: The paragraph describes the company's internal cybersecurity risk management processes — risk identification, continuous monitoring, and mitigation strategies — as part of its ERM program. Third-party risk is mentioned as one component of monitoring, not the central topic. The named Risk Committee (a non-generic committee on the IS list) elevates specificity to Firm-Specific; NIST is also named but alone would only reach Sector-Adapted. No two QV-eligible hard facts are present (no dates, dollar amounts, headcounts, named firms, or named tools).

thinking:
Let me analyze this paragraph carefully.

Content: Describes the company's internal cybersecurity risk management processes - risk identification, monitoring, mitigation strategies. Mentions ERM integration, various assessment methods, NIST framework, third-party risk monitoring (but as component of internal program), incident response process.

Category: Risk Management Process - clearly about internal processes, tools, methodologies. Third-party risk is mentioned as one component, not the central topic.

Specificity analysis:
- "Risk Committee" - this is a named non-generic committee → IS list ✓
- "NIST" framework named → Sector-Adapted at minimum

- "warm failover site" is a technical detail but not a named product or tool, so it doesn't qualify as an IS fact
- "Incident Management and Information Security Plan" is too generic without a unique identifier
- Common practices like tabletop exercises and penetration tests are standard methodologies, not IS facts

So I'm identifying Risk Committee as a firm-specific fact, which gives me one IS fact. But that's not enough for the QV check since Risk Committee itself isn't independently verifiable as a hard fact.

Looking at what's left, there are no specific dates, dollar amounts, headcounts, named third parties, products, tools, or certifications that would satisfy the QV requirement. So the final classification is Risk Management Process as Firm-Specific with a count of 3.

fact: Risk Committee receives reports on significant risk fluctuations

fact: NIST framework for incident response


reasoning: The paragraph describes a recurring process—quarterly meetings to identify emerging risks, develop solutions, and evaluate mitigation progress. While a named committee is the vehicle, the substantive content is about the risk identification and evaluation process rather than governance structure or personnel. 'Cybersecurity Committee' is a named non-generic committee on the IS list, yielding Firm-Specific; however, 'quarterly,' 'external experts,' and the described activities are all generic, so only one IS fact is present (no QV).

thinking:
Let me analyze this paragraph.

Content: Describes a Cybersecurity Committee meeting quarterly with external experts to identify risks, evaluate mitigation progress.

Category: This is about a committee's oversight activities. The "Cybersecurity Committee" - is this a board committee or management committee? The paragraph doesn't say it's a board committee. It mentions "members and external experts" meeting to identify risks and evaluate mitigation. This feels like it could be Risk Management Process (describing internal processes) or Board Governance.

The grammatical subject is "Our Cybersecurity Committee members and external experts." Without explicit indication this is a board-level committee, and given it's focused on identifying risks and evaluating mitigation activities, this leans toward Risk Management Process. But "Cybersecurity Committee" could be a governance body.

Looking back at the codebook definitions, Board Governance specifically requires the board or a board committee as the grammatical subject. Since this paragraph doesn't explicitly identify the Cybersecurity Committee as a board committee, it's more likely a management-level committee. The focus on describing what the committee does—the quarterly process of identifying risks and evaluating mitigation—points toward Risk Management Process rather than Management Role, which would emphasize the people and their qualifications. The committee's activities—identifying risks and evaluating mitigation progress—are fundamentally about the risk management process itself rather than governance structure. Since the paragraph focuses on what the process does rather than who oversees it, Risk Management Process is the better fit. For specificity, "Cybersecurity Committee" is a named non-generic committee that appears on the IS list, so that would be Firm-Specific.

fact: Cybersecurity Committee


reasoning: The paragraph is primarily about the people on the Cybersecurity Committee — their functional backgrounds, combined qualifications, and experience — making it about the persons rather than the function (person-vs-function test). The named non-generic Cybersecurity Committee and specific departmental composition are IS-list facts triggering Firm-Specific. Only one QV-eligible hard fact exists ('14 decades' of experience); generic mentions of 'certifications' and 'independent third parties' without names do not count toward QV, so it stays at Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes the Cybersecurity Committee composition, its members' qualifications, and mentions external assessments.

Category: This is about management roles - describing who is on the Cybersecurity Committee, their qualifications, experience. The paragraph tells us about the people (their roles, experience, qualifications) rather than the processes they run. The primary content is about WHO these people are and what makes them qualified. → Management Role

Wait, let me reconsider. The "Cybersecurity Committee" is a named non-generic committee. The paragraph describes committee composition and qualifications. Is this Board Governance or Management Role?

Actually, looking at the specific roles listed—property information technology directors, Corporate Controller, VP of Internal Audit, Corporate Secretary and General Counsel, Western Director of Finance—these are all management-level positions, not board members. The focus is on who these people are and their qualifications rather than what processes they oversee, so this is clearly Management Role.

For the quantifiable verification requirement, I have the named committee, the specific team composition across departments, and the "approximately 14 decades" of combined experience. But checking against the IS/NOT lists, most of these roles—Corporate Controller, General Counsel, Western Director of Finance—are generic corporate positions, not cybersecurity-specific titles. The VP of Internal Audit and Compliance is closer but still not explicitly cybersecurity-focused. That leaves me with only the committee name and the quantified experience as truly hard-verifiable facts, which falls short of the 2+ needed for QV.

fact: Members include property IT directors, Corporate Controller, VP of Internal Audit and Compliance, Corporate Secretary and General Counsel, Western Director of Finance

fact: Approximately 14 decades of combined direct IT leadership experience


reasoning: The paragraph describes how the IT Provider identifies significant risks through discussions with management and develops mitigating actions — this is a description of the company's risk management process. No cybersecurity-specific roles (CISO, CIO, etc.), no named frameworks, no named firms, no dates, and no other facts from the IS list are present; 'President,' 'IT Provider,' and 'Affiliated Group' are all generic references.

thinking:
Let me analyze this paragraph from Kaanapali Land LLC's 10-K filing.

The paragraph describes how an "IT Provider" reports to the President and upper management as part of a risk management process, identifying risks and developing responses.

Content category: This is about how the IT Provider (which seems to be an outsourced IT function) reports to management and identifies risks. The primary topic is the risk management process - how risks are identified and mitigated. The IT Provider reporting to the President is part of describing the process flow, not about a person's qualifications or background.

Actually, let me reconsider. "IT Provider" suggests a third-party service provider. But the paragraph describes the risk management process involving this provider reporting to management.

Looking at the specifics here, I'm seeing generic references throughout - the President is just a standard C-suite title, the IT Provider is unnamed, and the Affiliated Group is a vague company reference. There are no frameworks, dates, or specific named roles mentioned. This reads like standard boilerplate language about how risk management flows through the organization, without any concrete details or facts that would distinguish it from typical corporate governance disclosures.


reasoning: The paragraph contains an explicit materiality assessment ('we did not experience any cybersecurity incidents that materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition'), which per Rule 6 is Strategy Integration regardless of surrounding boilerplate risk language and cross-reference. 'During 2024' is a specific date anchoring the assessment to this company's fiscal year, yielding one IS-list fact → Firm-Specific.

thinking:
Let me analyze this paragraph.

The paragraph discusses potential material impacts of cybersecurity threats, then makes an explicit materiality assessment for 2024, and ends with a cross-reference to Risk Factors.

Category: Strategy Integration - contains an explicit materiality assessment ("During 2024, we did not experience any cybersecurity incidents that materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition"). Per Rule 6, materiality disclaimers → Strategy Integration.

Specificity: The paragraph mentions "During 2024" which is a specific date. Let me check - is that enough for Firm-Specific? Yes, "fiscal 2025" or year references count. But wait, "During 2024" is a specific date reference. That's one fact from the IS list → Firm-Specific. Only one hard verifiable fact, so not QV.

fact: During 2024