reasoning: Paragraph is a forward-looking disclaimer and cross-reference to Item 1A risk factors with no substantive cybersecurity disclosure, fitting None/Other per Rule 6 and N/O guidelines for cross-references. No domain terms, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: Paragraph states a backward-looking materiality conclusion ('have to date not materially affected... business strategy, results of operations or financial condition'), directly matching SI per Rule 5; vague mention of past threats/breaches lacks incident details for ID. No domain terms, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.

provider: x-ai

stage: benchmark


content_category: Third-Party Risk

reasoning: Paragraph primarily details due diligence, evidence requirements, and contractual notifications for third-party suppliers and partners, directly answering how third-party cyber risks are managed (TP central topic per Rule 3). No domain terms passing ERM test, firm-specific facts (e.g., no named roles/committees), or verifiable claims (no numbers/dates/names), resulting in Generic Boilerplate specificity.


reasoning: This paragraph states a conclusion about no material cybersecurity incidents affecting business outcomes in 2023, directly matching Strategy Integration per Rule 5 (backward- and forward-looking materiality assertions). No domain terms, firm-specific facts, or verifiable claims are present, resulting in Generic Boilerplate specificity.


content_category: Risk Management Process

reasoning: Paragraph primarily describes how cybersecurity risks are identified, assessed, and addressed through integration into overall risk management and a multi-faceted approach involving assessments, audits, and reviews, fitting Risk Management Process; no domain terminology passing ERM test (e.g., generic 'assessments and testing', 'internal audit'), firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate.


reasoning: The paragraph asserts no material cybersecurity impacts on operations or finances (negative materiality assessment), directly answering a Strategy Integration question per Rule 5, with a cross-reference as secondary; no domain terms, firm-specific facts, or verifiable claims anywhere, yielding Generic Boilerplate.


content_category: Incident Disclosure

fact: threat actor gained unauthorized access

fact: forensic investigation

fact: between approximately August 5-8, 2025

fact: 2025 Cybersecurity Incident

reasoning: Paragraph primarily describes a specific cybersecurity incident including timing, nature (unauthorized access, data acquisition), investigation completion, and ongoing impact evaluation, directly answering 'What happened in a cybersecurity incident?' (ID). Specificity reaches Quantified-Verifiable due to the specific dates (August 5-8, 2025) tied to the real event, alongside domain terms like 'threat actor' and 'forensic investigation'.


reasoning: Paragraph asserts no cybersecurity incidents with business impacts occurred, directly addressing materiality and effects on operations (SI per Rule 5 negative assertion example); no specific facts elevate beyond boilerplate as negative claims and reporting period are not verifiable or domain-specific (empty specific_facts → Generic Boilerplate).


content_category: None/Other

reasoning: This paragraph is a cross-reference to Item 1A Risk Factors with boilerplate speculative language about potential breach impacts, fitting None/Other per Rule 5 and Rule 6 (no substantive cybersecurity measures or processes described). No specific facts of any level are present, confirming Generic Boilerplate specificity.


fact: in November 2023, the Company initiated its cyber response protocol in response to a cybersecurity incident

fact: disruption of portions of its information technology systems

fact: LivaNova's cyber response protocol

reasoning: The paragraph primarily describes a specific past cybersecurity incident including timing (November 2023), nature (IT systems disruption), response (investigation, remediation, notifications), and containment, directly answering 'What happened in a cybersecurity incident?' despite opening SI materiality statement and cross-references; incident details dominate per Rule 4. Specificity reaches Quantified-Verifiable due to the verifiable specific date of the incident and named internal protocol, elevating beyond firm-specific elements.


reasoning: This paragraph primarily assesses the lack of material past and anticipated future impact of cybersecurity on business strategy, results of operations, or financial condition, directly matching Strategy Integration per Rule 5 (backward- and forward-looking materiality statements, negative incident assertion). No domain terms, firm-specific facts, or verifiable claims present anywhere, resulting in Generic Boilerplate specificity.


content_category: Board Governance

reasoning: Paragraph describes reporting of security program evaluations to the Board, Audit Committee, and senior management (ELT), directly answering how the board oversees cybersecurity via information flow and oversight structure (BG per Rule 1). No domain terms passing ERM test, no firm-specific roles/committees (Audit Committee and ELT/Board are generic), and no verifiable facts, resulting in Generic Boilerplate specificity.


fact: penetration testing

fact: threat monitoring

category_confidence: medium

reasoning: Paragraph centrally addresses third-party cybersecurity firms for services and vendor security control requirements, making third-party risk management the primary topic per Rule 3 (vendor oversight central) over RMP; domain terms like 'penetration testing' and 'threat monitoring' pass ERM test for Level 2, with no firm-specific or verifiable facts elevating further.


reasoning: Paragraph asserts no cybersecurity incidents or threats to date (negative assertion → SI per Rule 5) and speculates on potential material business/financial impacts, directly answering how cybersecurity affects the business; no domain terms passing ERM test, firm-specific facts, or verifiable claims found anywhere, resulting in Generic Boilerplate.


reasoning: The paragraph primarily describes vendor assessments for cybersecurity risks and security requirements for those accessing sensitive data, centrally addressing third-party risk management (TP). No domain terms passing the ERM test, firm-specific facts, or verifiable claims are present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph primarily states a conclusion about no material cybersecurity incidents experienced (negative materiality assertion), fitting Strategy Integration per Rule 5; cross-references and speculation are secondary. No domain terms passing ERM test, no firm-specific facts, and negative assertions are not verifiable, resulting in empty specific_facts and Generic Boilerplate specificity.


reasoning: This paragraph is a cross-reference to Item 1A Risk Factors with generic hypothetical risk language ('could experience adverse consequences'), fitting None/Other as it lacks substantive cybersecurity disclosure per Rule 6 and Rule 5 (speculation not SI). No specific facts of any level are present, resulting in Generic Boilerplate specificity.


fact: CISO

fact: information security team

fact: threat landscape

fact: client security audits

reasoning: Paragraph describes board-level oversight structure, delegation to Audit Committee, and reporting flow from CISO/team, directly answering 'How does the board oversee cybersecurity?' (BG). Specificity reaches Firm-Specific due to named CISO role and information security team, with domain terms like 'threat landscape' and 'client security audits' supporting but not exceeding Level 3; no verifiable quantities or dates.


reasoning: Paragraph describes board-level (Audit Committee) oversight of cybersecurity via management reports and evaluations, directly answering 'How does the board oversee cybersecurity?' (BG per Rule 1). Specificity driven by firm-specific named role 'Senior Director, Global Information Security' (L3), with no domain terms or verifiable facts elevating higher.


reasoning: Paragraph primarily states conclusions about no material past incidents or future risks affecting business strategy/operations/financials and cross-references risks, directly matching Strategy Integration per materiality rule (backward- and forward-looking assertions). No domain terms, firm-specific facts, or verifiable claims present anywhere, resulting in Generic Boilerplate specificity.


reasoning: This paragraph primarily states conclusions about past and potential material impacts of cybersecurity on business outcomes, directly matching Strategy Integration per Rule 5 (backward- and forward-looking materiality assessments). No domain terms, firm-specific details, or verifiable facts present anywhere, resulting in Generic Boilerplate specificity.


content_category: Management Role

fact: COO (Operations Officer) leads cybersecurity strategy and oversees risk assessments, incident response, and compliance

fact: COO has over 15 years of experience in cybersecurity

type: quantified

reasoning: Paragraph primarily describes the COO's leadership role, responsibilities, reporting line, and qualifications in cybersecurity, fitting Management Role per person-removal test where removing the role leaves generic activities. Specificity reaches Quantified-Verifiable due to the verifiable 'over 15 years of experience' claim and firm-specific COO cybersecurity leadership role.


fact: cybersecurity incident in 2024

fact: unauthorized access of an employee's email account

fact: threat actor fraudulently divert Company funds

reasoning: Paragraph describes a real 2024 cybersecurity incident including nature (email access, fund diversion), detection, and minimal impact, directly answering 'What happened in a cybersecurity incident?' (ID dominant over SI per Rule 4). Specificity reaches Quantified-Verifiable due to verifiable facts like the 2024 incident date and specific event details (unauthorized email access, fund diversion).


reasoning: This paragraph is speculative risk language admitting lack of resources without describing any cybersecurity measures, processes, or structure, fitting None/Other per Rule 6 (pure speculation without measures). No domain terms, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


fact: SOC2 report evaluations for security, availability of data, processing integrity, confidentiality and privacy controls

type: framework

reasoning: The paragraph centers on managing cybersecurity risks from third-party service providers, operators, managers, and vendors through assessments, due diligence, centralized registry, and SOC 2 reviews, directly answering the Third-Party Risk question as the central topic per Rule 3. Specificity reaches Domain-Adapted due to the SOC 2 framework and specific Trust Services Criteria, passing the ERM test for cybersecurity expertise; no firm-specific roles or verifiable claims elevate it further.


reasoning: The paragraph primarily assesses the materiality of past and potential future cybersecurity incidents on business outcomes, stating no material impacts to date and forward-looking risks, fitting Strategy Integration per Rule 5 (negative assertion and SEC Item 106(b)(2) language). No domain terms passing ERM test, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity with empty specific_facts.


fact: malware, viruses, worms and ransomware

fact: password spraying

fact: phishing

fact: denial-of-service attacks

fact: advanced persistent threat intrusions

reasoning: Paragraph describes general cybersecurity threat landscape without detailing oversight, processes, incidents, or business impacts, fitting None/Other per Rule 6 (pure speculation without measures). Specificity driven by multiple cybersecurity-specific threat types (e.g., ransomware, APT) that pass ERM test for domain expertise, elevating to Domain-Adapted with no higher-level facts.


reasoning: Paragraph primarily assesses the materiality of past (non-material) and potential future cybersecurity incidents on business, operations, and reputation, directly answering how cybersecurity affects the business (SI per Rule 5 backward-looking materiality assertion); generic process mentions and cross-reference are secondary. No domain terms passing ERM test, no firm-specific roles/committees, no verifiable facts like numbers/dates/names/certifications, resulting in Generic Boilerplate specificity.


reasoning: This paragraph provides a generic definition of 'systems' without addressing board oversight, management roles, risk processes, incidents, or strategy; it fits None/Other as non-substantive definitional content. No domain terms, firm-specific facts, or verifiable claims are present anywhere in the text, resulting in Generic Boilerplate.


fact: In October 2023, we experienced a cybersecurity incident

fact: certain information of our users was accessed and downloaded from individual 23andMe.com accounts

fact: Cybersecurity Incident Response Plan

fact: enhancements to our Security Operations

fact: required two-step verification

fact: enhanced our detection tools and capabilities

reasoning: The paragraph primarily describes a specific past cybersecurity incident including timing, nature (unauthorized access to 23andMe.com accounts), and remediation steps, directly answering 'What happened in a cybersecurity incident?' making it Incident Disclosure. Specificity reaches Quantified-Verifiable due to the verifiable specific date (October 2023) and named system (23andMe.com), with additional domain terms and firm-specific elements like the named Incident Response Plan.


reasoning: This paragraph primarily describes the integration of the cybersecurity program into the enterprise risk management framework, directly answering the Risk Management Process question on ERM integration. It contains no domain-specific cybersecurity terminology beyond generic risk management language, no firm-specific roles or structures, and no verifiable facts, resulting in Generic Boilerplate specificity.


fact: cloud-based technology to scan and analyze for vulnerable software or misconfigurations

reasoning: The paragraph primarily describes vendor oversight processes like questionnaires, contractual security controls, monitoring, and termination rights for third-party providers, making Third-Party Risk the central topic over Risk Management Process. Specificity is Domain-Adapted due to the domain-specific term describing vulnerability scanning and misconfiguration analysis, which demonstrates cybersecurity expertise beyond generic ERM language; no firm-specific roles or verifiable claims present.


fact: Director of IT Security and Compliance

fact: IT Steering Committee

fact: vulnerability assessments

fact: third-party control tests

reasoning: Paragraph primarily describes cybersecurity assessment methodologies (vulnerability assessments, audits, monitoring) and escalation processes, with substantive program details remaining after person-removal test, making it RMP over MR. Specificity reaches Firm-Specific due to named_role (Director of IT Security and Compliance) and named_committee (IT Steering Committee), plus domain_terms like vulnerability assessments.


reasoning: Paragraph states conclusions about no material past or likely future cybersecurity impacts on business, strategy, operations, or finances, directly matching Strategy Integration per Rule 5 (backward- and forward-looking materiality assessments). No domain terminology passing ERM test, firm-specific facts, or verifiable claims (negative assertions not verifiable), so empty specific_facts yields Generic Boilerplate.


fact: President and CEO leads information security team

fact: more than 20 years of experience in the Business Finance and Audit management industry

fact: Since January 2020

reasoning: Paragraph primarily describes the President and CEO's leadership role, qualifications (experience), and direct reporting line to the Board, answering 'How is management organized to handle cybersecurity?' (MR per Rule 1 and person-specific focus). Specificity reaches Quantified-Verifiable due to verifiable facts like 'more than 20 years of experience' (lower bound checkable) and 'January 2020' start date, plus firm-specific CEO cyber leadership.


reasoning: This paragraph is a cross-reference to Item 1A risk factors, providing no substantive cybersecurity disclosure and matching N/O for cross-references per Rule 5 and 6. No specific facts of any level are present, confirming Generic Boilerplate specificity.


fact: Namecheap

fact: Godaddy

fact: Cloudflare

reasoning: This paragraph centrally addresses third-party cyber risks by describing reliance on specific hosting providers for website services, directly answering how third-party risks are managed. Specificity is Quantified-Verifiable due to the named firms (Namecheap, GoDaddy, Cloudflare), which are externally verifiable claims.


reasoning: This paragraph provides a materiality assessment concluding no cybersecurity incidents have materially affected business strategy, results of operations, or financial condition, fitting Strategy Integration per Rule 5 (backward-looking negative assertion). It contains no domain terms, firm-specific facts, or verifiable claims, warranting Generic Boilerplate specificity.


reasoning: This paragraph primarily describes board-level oversight of cybersecurity, including review frequency and incident escalation processes, directly answering the Board Governance question. It contains no domain-specific terminology beyond generic oversight language, no firm-specific roles or committees, and no verifiable facts, warranting Generic Boilerplate specificity.


fact: routine scanning

fact: phishing attempts

fact: minor technical vulnerabilities

reasoning: Paragraph primarily states a conclusion about no material cybersecurity incidents impacting business/operations/finances over specific fiscal years, fitting Strategy Integration per Rule 5 (negative assertion). Domain terms like 'phishing attempts' and 'scanning' demonstrate cybersecurity expertise passing ERM test, setting specificity to Domain-Adapted with no higher-level facts.


reasoning: The paragraph's longest and most detailed sentence describes contractual requirements imposed on third-party service providers for security certifications and breach reporting, making Third-Party Risk the primary category over the shorter introductory negative materiality assertion (Strategy Integration); no domain terminology passing the ERM test, firm-specific facts, or verifiable claims are present anywhere in the text.


reasoning: The paragraph centrally describes a risk-based approach to assessing and overseeing cybersecurity risks from third parties like vendors and service providers, directly answering the Third-Party Risk question per Rule 3 (vendor oversight as central topic). No domain terms passing ERM test, firm-specific facts, or verifiable claims found anywhere, resulting in Generic Boilerplate specificity.


fact: Chief Operations Officer

reasoning: Paragraph describes the Incident Response Plan's framework, coordination, escalation, and evaluation, answering 'What does the cybersecurity program do?' (RMP); person-removal test confirms substantive program description remains. Specificity driven by firm-specific named role 'Chief Operations Officer' coordinating the plan (Level 3), no higher verifiable facts.


fact: obtains and reviews attest reports covering cyber-related controls at these third parties

fact: designs and implements complementary user entity controls

reasoning: The paragraph primarily details measures for managing third-party cybersecurity risks, including reviewing attest reports, implementing complementary controls, incident notifications, and contractual safeguards, making Third-Party Risk the central topic over general RMP. Specificity is Domain-Adapted due to domain-specific terms like 'attest reports covering cyber-related controls' and 'complementary user entity controls' that demonstrate cybersecurity expertise beyond generic ERM language.


reasoning: This paragraph primarily describes the Board's risk oversight function and delegation to the Audit Committee for cybersecurity oversight, fitting Board Governance per the governance-chain rule for board-level structures. No domain terminology passing the ERM test, firm-specific facts (Audit Committee is generic), or verifiable claims are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes the Board's oversight of cybersecurity risks, including delegation to the Audit Committee, directly answering the Board Governance question about oversight structure. No domain terms, firm-specific facts, or verifiable claims are present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph describes board assignment of cybersecurity oversight to the Audit Committee, update frequency at meetings, and information flow from senior management, directly answering 'How does the board oversee cybersecurity?' → Board Governance. No domain terms, firm-specific facts, or verifiable claims present; generic oversight language fails ERM test and contains no qualifying specifics → Generic Boilerplate.


fact: Progress software

fact: February 26, 2024

reasoning: Paragraph describes a real cybersecurity breach (public disclosure, customer notifications) and related SEC investigation with specific timing and software involved, directly answering 'What happened in a cybersecurity incident?'; specificity reaches Quantified-Verifiable due to the named Progress software and specific date of SEC request, both externally verifiable facts.


reasoning: Paragraph primarily describes board oversight of cybersecurity risks, including expertise, documentation, discussion frequency/topics, and reporting mechanisms, directly answering the Board Governance question. No domain terminology, firm-specific facts (e.g., named roles/committees beyond generic Board), or verifiable claims (e.g., numbers, dates, certifications) found anywhere, resulting in Generic Boilerplate specificity.


reasoning: Paragraph primarily assesses that no material cybersecurity incidents have affected the company to date and speculates on potential future material impacts on business strategy, results of operations, or financial condition, directly answering a Strategy Integration question per Rule 5 (backward-looking negative assertion and forward-looking materiality). No specific facts of any level found: generic disclaimers, no domain terminology passing ERM test, no firm-specific roles/committees, no verifiable claims like dates, numbers, or certifications.


reasoning: Paragraph primarily describes collaboration with third-party vendors on cybersecurity risks, making Third-Party Risk the central topic per Rule 3 (vendor oversight). No domain terms passing ERM test, firm-specific facts, or verifiable claims found anywhere, resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a generic commitment statement without describing any oversight structure, roles, processes, incidents, or impacts, fitting None/Other as it lacks substantive cybersecurity disclosure. No domain terms, firm-specific facts, or verifiable claims are present, resulting in Generic Boilerplate specificity.


fact: zero-day vulnerability

fact: MOVEit managed file transfer software

fact: Form 8-K filed on July 14, 2023

fact: informed on or about May 31, 2023

fact: First National 1870 and Guardian Mortgage divisions

reasoning: This paragraph describes a specific cybersecurity incident involving a zero-day vulnerability in the MOVEit software from a third-party vendor, including timing and usage details, directly answering 'What happened in a cybersecurity incident?' making it Incident Disclosure. Specificity reaches Quantified-Verifiable due to specific dates (July 14, 2023; May 31, 2023), named system (MOVEit), and domain term (zero-day vulnerability).


reasoning: This paragraph provides forward-looking disclaimers about potential cybersecurity incidents, vague insurance coverage, and a cross-reference to Risk Factors, answering no substantive question from the categories and fitting None/Other per rules on speculation and cross-references. No domain terms, firm-specific facts, or verifiable claims appear anywhere, confirming Generic Boilerplate specificity.


fact: CISO

fact: Security Governance Committee

fact: over 20 years of cybersecurity and technology management experience

reasoning: Paragraph describes management-level committee structure (Security Governance Committee membership) and CISO qualifications/experience, fitting Management Role per Rule 1 and person-removal test (collapses without people). Specificity reaches Quantified-Verifiable due to the CISO's 'over 20 years' experience (verifiable lower-bound fact), plus firm-specific named role and committee.


fact: forensic investigation

reasoning: This paragraph describes an actual cybersecurity incident including its nature (employee interactions with suspicious websites), response (promptly contained), investigation (forensic), and impact (no material), directly matching Incident Disclosure. Specificity reaches Domain-Adapted due to the domain term 'forensic investigation' demonstrating cybersecurity expertise; no firm-specific roles/committees or verifiable quantities/names/dates elevate further.


reasoning: This paragraph is a generic statement about the threat environment without describing any cybersecurity measures, processes, or structure, fitting None/Other as pure speculation. No specific facts, domain terms, or verifiable claims are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily describes management of third-party service provider risks through weekly compliance monitoring calls and immediate mitigation, making Third-Party Risk the central topic per Rule 3 (vendor oversight as focus). It lacks domain terminology passing the ERM test, firm-specific elements like named roles or committees, or verifiable claims like hard numbers or dates, yielding Generic Boilerplate specificity.


fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)

fact: Cyber Incident Response Teams

reasoning: This paragraph primarily describes management leadership roles (CIO overseeing CISO), team responsibilities, and structure (CISO's team and Cyber Incident Response Teams partnering with Risk and Legal), directly answering 'How is management organized to handle cybersecurity?' per Management Role; person-removal test confirms focus on roles over program activities. Specificity reaches Firm-Specific due to named VP-level roles (CIO, CISO) and named team (Cyber Incident Response Teams), with no higher verifiable facts.


fact: chief technology officer

fact: over a decade of industry experience

reasoning: Paragraph primarily describes the CTO's responsibilities, qualifications, team support, and reporting lines, fitting Management Role per person-specific focus on leadership organization (MR vs BG via Rule 1, as management roles are central); board reporting is secondary. Specificity reaches Quantified-Verifiable due to verifiable lower-bound experience claim ('over a decade') and firm-specific CTO role, with no domain terms elevating independently.


reasoning: Paragraph centrally describes vendor risk assessments, processes for third-party system risks, and notification requirements from vendors, directly answering 'How are third-party cyber risks managed?' with Third-Party Risk as the primary focus per Rule 3. No domain terms passing ERM test, firm-specific facts, or verifiable claims found anywhere, resulting in Generic Boilerplate specificity.


reasoning: Paragraph describes board oversight of ERM including cybersecurity delegation to the Audit Committee and its monitoring role, directly answering 'How does the board oversee cybersecurity?' (BG per Rule 1 for board-level committees). No domain terminology, firm-specific facts, or verifiable claims present; generic governance language yields Generic Boilerplate.


fact: executive risk committee

fact: Chief Financial Officer

fact: Chief Legal Officer

fact: Senior Vice President, Engineering Operations

fact: cybersecurity team

fact: computer science, cybersecurity assurance or other cybersecurity degrees

fact: monitoring, detecting, mitigating and preventing cybersecurity incidents

fact: testing cybersecurity processes

reasoning: Paragraph primarily describes the executive risk committee's structure, membership (CFO, CLO, SVP Engineering Operations), reporting from cybersecurity team, and their qualifications/expertise, answering 'How is management organized to handle cybersecurity?' (MR per Rule 1, management-level committee). Specificity reaches Firm-Specific due to named committee and specific VP-level roles in cyber oversight context; domain terms present but no verifiable hard facts like quantified headcount or certifications.


fact: data encryption

fact: breach notification

reasoning: Paragraph discusses external regulatory trends and general compliance monitoring, not answering any core cybersecurity oversight, management, process, or impact questions, making it None/Other. Contains domain terms like 'data encryption' and 'breach notification' that demonstrate cybersecurity vocabulary beyond generic ERM language, setting specificity to Domain-Adapted.


reasoning: This paragraph describes general investments in information technology systems for operational, compliance, and growth purposes with no mention of cybersecurity, making it None/Other. No cybersecurity-specific facts, domain terms, or verifiable claims are present anywhere in the text, confirming Generic Boilerplate specificity.


fact: DIT has over 20 years of experience in information security, risk management, and compliance

reasoning: Paragraph primarily details the Director of Information Technology's (DIT) role, qualifications, experience, reporting lines from CEO and audit committee oversight, and senior management support, answering how management is organized for cybersecurity (MR per Rule 1, as management's organizational role is primary over board oversight structure). Specificity reaches Quantified-Verifiable due to the verifiable claim of 'over 20 years of experience' (lower-bound hard number checkable against credentials), with no qualifying domain terms or firm-specific roles like security-qualified Director titles.


fact: Cybersecurity management team led by Brian Fellon, Vice President, Chief Information Officer and Chief Information Security Officer (VP, CIO and CISO)

fact: Mr. Fellon joined NW Natural and was appointed to his role in September 2024

fact: Mr. Fellon reports to Chief Financial Officer

fact: 28 years of experience in information technology

fact: Served as Director of Information Technology at Puget Sound Energy from 2016 to September 2024

reasoning: Paragraph details management structure, leadership roles, reporting lines, and qualifications/career history of the CISO, directly answering 'How is management organized to handle cybersecurity?' (MR per person-removal test). Specificity reaches Quantified-Verifiable due to verifiable facts like specific dates (September 2024, 2016-2024), quantified experience (28 years), named individual/role, and prior named firm.


reasoning: Paragraph assesses past lack of significant cybersecurity impacts and potential future material effects on business/finances, directly answering Strategy Integration question per Rule 5 (negative assertion of no material incidents to date). No domain terms passing ERM test, firm-specific facts, or verifiable claims present anywhere, yielding empty specific_facts and Generic Boilerplate specificity.


fact: in 2019, we were a victim of a wire fraud scheme

fact: compromised the email account of one of our employees and sent a fraudulent wire transfer request

fact: multi-factor authentication (MFA) across all our systems and email accounts

reasoning: Paragraph primarily describes a specific past cybersecurity incident (2019 wire fraud via email compromise, remediation steps), directly answering 'What happened in a cybersecurity incident?'; specificity reaches Quantified-Verifiable due to the verifiable specific date ('in 2019') and event details cross-referenced to Legal Proceedings.


fact: ransomware

fact: malware

fact: computer viruses

fact: phishing attempts

reasoning: Paragraph primarily states a conclusion about no material cybersecurity incidents in the last three years, fitting Strategy Integration per Rule 5 (negative assertion). Specificity is Domain-Adapted due to cybersecurity-specific threat types like ransomware and phishing that pass the ERM test, with no firm-specific or verifiable facts.


fact: criteria for incident classification and procedures to escalate incidents

fact: security analytical and assessment tools

reasoning: Paragraph describes the components and activities of the cybersecurity program (risk assessments, training, tools, incident response plan with classification/escalation, monitoring), directly answering 'What does the cybersecurity program do?' → RMP; no board/management structure, no third-party focus, no incidents. Specificity driven by domain terms like 'incident classification' and 'security analytical tools' passing ERM test (cyber-specific practices), but no firm-specific roles/committees or verifiable facts like numbers/dates/names.


reasoning: This paragraph describes general IT and OT infrastructure and dependencies for business operations without any mention of cybersecurity measures, oversight, processes, or incidents, making it non-substantive cybersecurity disclosure (N/O). No cybersecurity-specific facts, domain terms, firm-specific cyber elements, or verifiable claims are present anywhere in the text, resulting in Generic Boilerplate specificity.


reasoning: Paragraph discusses cybersecurity insurance as a tool to manage financial risks from cyber-attacks, directly answering how cybersecurity integrates with business/financial strategy (SI). No domain terms passing ERM test, no firm-specific roles/committees/teams, and no quantified verifiable facts like amounts or named insurers, resulting in Generic Boilerplate specificity.


fact: utilizing a third-party security scoring system to evaluate the security posture

reasoning: Paragraph centers on processes to oversee and manage cybersecurity risks from vendors and third parties, including evaluation via a security scoring system, making Third-Party Risk the primary category. Specificity reaches Domain-Adapted due to the domain-specific term 'third-party security scoring system,' which demonstrates cybersecurity expertise beyond generic risk management.


reasoning: Paragraph describes a Director's responsibilities for the information security program, qualifications, and regular reviews with the CFO, directly answering how management is organized for cybersecurity (MR per person-removal test as content collapses without roles); no domain terms passing ERM test, no qualifying firm-specific roles (vague 'Director' lacks security qualifier, CFO generic), and no verifiable facts, yielding Generic Boilerplate.


fact: program maturity assessments

reasoning: Paragraph primarily describes cybersecurity processes including ERM integration, program maturity assessments, IT risk assessments, and third-party security assessments, directly answering 'What does the cybersecurity program do?' (RMP); brief Audit Committee oversight mention is subordinate. Specificity driven by 'program maturity assessments' as a domain term passing ERM test (cybersecurity-specific practice), with no firm-specific or verifiable facts.


reasoning: The paragraph describes the company's information security processes for identifying, assessing, and managing cybersecurity risks to specific assets, directly answering the Risk Management Process question without mentioning governance, roles, or incidents. No domain terms, firm-specific details, or verifiable facts are present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph describes speculative cybersecurity risks, potential business impacts, and cross-references Item 1A Risk Factors, matching None/Other for forward-looking disclaimers and cross-references without substantive cybersecurity disclosure (Rule 5, Rule 6). No specific facts elevating specificity: mentions of ransomware and cyberattacks are generic risk language any ERM professional would use, failing ERM test for domain expertise; no firm-specific roles, committees, or verifiable claims.


fact: Information Technology Board Committee (ITBC)

fact: IT Steering Committee (ITSC)

fact: Information Security Program (ISP)

reasoning: Paragraph describes oversight structure of the cybersecurity program by board-level (ITBC) and management-level (ITSC) committees, directly answering board oversight question per BG category and Rule 1. Specificity reaches Firm-Specific due to named committees and program (ITBC, ITSC, ISP), with no higher verifiable facts.


fact: Critical Threat Committee

reasoning: Paragraph describes the Critical Threat Committee's role in evaluating incident materiality, briefing the Board, and notifying the Chairman, focusing on oversight structure and information flow to the board (BG). Named 'Critical Threat Committee' is a firm-specific committee elevating specificity to Firm-Specific; no domain terms or verifiable facts present.


fact: Chief Financial Officer (CFO) and Chief Technology Officer (CTO)

fact: CTO has over 26 years of extensive information technology experience

fact: roles as Director of Technology, Information Technology Manager, Technical Manager, and Systems Analyst

fact: manages our cybersecurity team, which comprises certified and experienced information security professionals

reasoning: Paragraph primarily describes management leadership roles (CFO/CTO direction, responsibilities, CTO qualifications and career history, team management), fitting Management Role per person-removal test as it collapses without person-specific content. Specificity reaches Quantified-Verifiable due to 'over 26 years' experience (verifiable lower-bound number) and firm-specific roles/team, overriding domain terms like prevention/detection/mitigation/remediation.


fact: Director of Information Technology

fact: more than 20 years' experience in financial services

fact: degree from the University of California, Santa Barbara with focus on Business Administration coursework

fact: Certified Information Systems Security Professional from ISC2 Organization

reasoning: Paragraph details the qualifications, experience, and responsibilities of the Director of Information Technology in managing cybersecurity programs, directly answering 'How is management organized to handle cybersecurity?' (MR per person-removal test as it collapses without role details). Specificity reaches Quantified-Verifiable due to verifiable claims like CISSP certification, specific university degree, and >20 years experience.


fact: protection, detection, response, and recovery capabilities

reasoning: Paragraph primarily describes the cybersecurity program's activities (investments in processes/tech, risk avoidance/ID/assessment/mitigation/remediation, continuous enhancement of PDDR capabilities, ERM integration, stakeholder engagement), passing person-removal test for RMP over MR/BG; oversight mentions are subordinate. Specificity driven by domain terminology like 'protection, detection, response, and recovery' passing ERM test for Level 2, with no firm-specific roles/committees or verifiable claims.


fact: Chief Information Officer

reasoning: Paragraph describes Audit Committee and Board oversight of cybersecurity risks, reports, briefings, and presentations, directly answering 'How does the board oversee cybersecurity?' (BG). Specificity reaches Firm-Specific due to named C-level IT role (CIO), a firm-unique leadership fact; no domain terms pass ERM test and no verifiable claims present.


fact: technology committee of our board of directors

reasoning: Paragraph primarily describes board-level oversight structure including Audit Committee and technology committee responsibilities for cybersecurity risks, with management reporting, defaulting to Board Governance per Rule 1 governance-chain. Specificity reaches Firm-Specific due to the named non-generic 'technology committee,' with no domain terms or verifiable facts present.


fact: Chief Security Officer (CSO)

fact: Security Committee

fact: Cyber Risk Advisory Committee

reasoning: Paragraph primarily describes board and committee oversight structure for cybersecurity risks, including flow to CSO, fitting Board Governance per governance-chain default and Rule 1. Specificity reaches Firm-Specific due to named cybersecurity role (CSO) and named committees, with no higher verifiable facts.


reasoning: The paragraph primarily states a conclusion about no material past cybersecurity impacts on business outcomes and refers to forward-looking risks, directly answering a Strategy Integration question per Rule 5 (backward-looking materiality assessment). No domain terms, firm-specific facts, or verifiable claims anywhere in the text, resulting in Generic Boilerplate specificity.


fact: CISO and his team

reasoning: Paragraph describes information flow from CISO to Audit Committee and Board quarterly, answering how the board oversees cybersecurity risks (BG per governance-chain and board-level focus). Specificity driven by firm-specific named role 'CISO' (Level 3), no domain terms or verifiable facts elevate higher.


reasoning: This paragraph describes the company's cybersecurity strategy and processes, including risk identification, prioritization, mitigation analysis, policies, escalation, employee training, and use of consultants for assessments, directly answering 'What does the cybersecurity program do?' (RMP); third-party consultants are internal program support, not vendor oversight (Rule 3). No domain terms pass the ERM test (all generic risk management language), no firm-specific facts like named roles or committees, and no verifiable claims like numbers or dates, resulting in Generic Boilerplate specificity.


reasoning: This paragraph states conclusions about no material past or expected cybersecurity impacts on business strategy, operations, or finances, directly matching Strategy Integration's materiality assessments (backward- and forward-looking). No domain terms passing the ERM test, firm-specific details, or verifiable facts are present anywhere, yielding Generic Boilerplate specificity.


fact: security questionnaires

fact: security capabilities and maturity assessments

fact: controls evidence reviews

fact: application vulnerability assessments

fact: public internet presence monitoring

fact: alignment reviews with service-specific industry standards (e.g., NIST, ISO, HIPAA, and Payment Card Industry standards)

reasoning: Paragraph centrally describes supplier/vendor cybersecurity oversight via contracts, audits, assessments, and requirements, directly answering third-party risk management (TP per Rule 3). Specificity driven by multiple domain terms like vulnerability assessments, NIST/ISO/HIPAA/PCI that demonstrate cybersecurity expertise (Level 2 via ERM test), with no firm-specific roles/committees or verifiable quantities/dates (no Level 3/4).


reasoning: The paragraph provides a backward-looking materiality assessment stating no material impact from cybersecurity threats on business strategy, results of operations, or financial condition over the last three fiscal years, directly matching Strategy Integration per Rule 5. It contains no domain terms, firm-specific facts, or verifiable claims, resulting in Generic Boilerplate specificity.


fact: ransomware attack

fact: late May 2023

reasoning: This paragraph describes a specific ransomware incident including timing, nature, and initial response actions, directly answering 'What happened in a cybersecurity incident?' making it Incident Disclosure. Specificity reaches Quantified-Verifiable due to the verifiable date 'late May 2023' and domain term 'ransomware attack'.


reasoning: Paragraph states backward-looking conclusions on no material cybersecurity incidents or expenses over a specific period, directly addressing materiality impact on business outcomes per SI rules (negative assertions qualify as SI); cross-reference is secondary. No domain terms, firm-specific facts, or verifiable claims present (negative assertions on incidents/expenses not externally verifiable), yielding Generic Boilerplate.


reasoning: The paragraph primarily states a conclusion about no material cybersecurity incidents in 2023 affecting business strategy, operations, or financial condition, directly matching Strategy Integration per materiality rule (backward- and forward-looking assertions). No domain terms, firm-specific facts, or verifiable claims are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes the board's oversight structure via the Audit Committee interacting with the Manager's Director of IT and management, directly answering the Board Governance question about oversight flow (governance-chain defaults to BG per Rule 1). No domain terminology passing ERM test, no firm-specific roles (Director of IT lacks security qualifier), and no verifiable facts, resulting in Generic Boilerplate specificity.


fact: GISO

fact: Chief Information Security Officer

fact: cybersecurity maturity assessments

fact: independent reviews of our cybersecurity control environment and operating effectiveness

reasoning: Paragraph primarily describes the cybersecurity program's use of third-party vendors and experts for protection and assessments (e.g., maturity assessments, audits), fitting RMP as third parties hired to support the internal program per Rule 3, with reporting as secondary; firm-specific named roles (GISO, CISO) drive Firm-Specific level over domain terms alone.


reasoning: Paragraph centrally describes vendor assessment process for data security prior to engagement, calibrated by risk—directly answers Third-Party Risk question. No domain terms passing ERM test (e.g., CIA triad-like language is generic), no firm-specific roles/committees, no verifiable facts like names/numbers/dates → Generic Boilerplate.


reasoning: This paragraph states conclusions about no material past or likely future cybersecurity impacts on business outcomes, directly matching Strategy Integration per materiality rule (backward- and forward-looking negative assertions). No domain terms, firm-specific details, or verifiable facts present anywhere, resulting in Generic Boilerplate specificity.


fact: identity management and access control safeguards

fact: system and network security and monitoring

reasoning: This paragraph lists specific protective measures implemented in the cybersecurity program, directly answering 'What does the cybersecurity program do?' making it Risk Management Process; no board, management roles, or incidents mentioned. Specificity reaches Domain-Adapted due to cybersecurity-specific terms like 'encryption of data in transit and at rest' and 'identity management and access control' that demonstrate domain expertise beyond generic ERM language, with no firm-specific or verifiable facts.


reasoning: This paragraph is a forward-looking disclaimer acknowledging unmitigable risks and cross-referencing Risk Factors, providing no substantive cybersecurity details and fitting None/Other per rules on speculation and cross-references. No domain terms, firm-specific facts, or verifiable claims are present anywhere in the text, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes Audit Committee oversight of cybersecurity risks and incidents via reports from management, directly answering the Board Governance question about board-level oversight structure and information flow. No domain terms, firm-specific facts, or verifiable claims are present, resulting in Generic Boilerplate specificity.


fact: security event monitoring and detection

fact: extended detection and response

fact: vulnerability scanning

fact: phishing simulations

fact: penetration tests

reasoning: Paragraph describes specific components of the cybersecurity program including monitoring, EDR, vulnerability scanning, training, phishing simulations, and incident response team, plus third-party audits/pen tests hired for the company, directly answering 'What does the cybersecurity program do?' (RMP per Rule 3). Multiple domain terms like EDR, vulnerability scanning, phishing simulations, and pen tests pass ERM test for Domain-Adapted specificity (Level 2), with no firm-specific roles/committees or verifiable claims.


fact: security threat intelligence system

fact: vulnerability management tools

fact: patch management standard

fact: Security Operations Center

fact: event correlation

reasoning: Paragraph describes cybersecurity program components like threat intelligence, vulnerability management, patching, and SOC operations, directly answering 'What does the cybersecurity program do?' (RMP). Specificity reaches Firm-Specific due to firm-unique claims like maintaining a Security Operations Center and patch management standard, plus multiple domain terms like vulnerability management tools and event correlation.


fact: In October 2023, cybersecurity incident where user information was accessed and downloaded from 23andMe.com accounts

fact: 23andMe.com accounts

fact: reset customer passwords, required two-factor verification for new and existing customers

reasoning: Paragraph primarily describes a specific past cybersecurity incident including timing, nature (unauthorized access to 23andMe.com accounts), and remediation steps, fitting Incident Disclosure. Specificity reaches Quantified-Verifiable due to the verifiable specific date (October 2023), named system (23andMe.com), and domain terms like two-factor verification.


reasoning: The paragraph primarily states a conclusion about no material cybersecurity incidents impacting business strategy, results of operations, or financial condition, directly matching Strategy Integration per materiality rule 5 (negative assertion and forward-looking likelihood). No specific facts elevate specificity: negative self-assertion is not verifiable, no domain terms pass ERM test, no firm-specific roles/committees, and cross-reference is boilerplate.


reasoning: The paragraph primarily describes the company's cybersecurity policies, processes for risk assessment and management, incident response planning, and use of third-party assessors for program evaluation, directly answering 'What does the cybersecurity program do?' (RMP); third-party provider risk oversight is mentioned but not central (Rule 3). No domain-specific terminology passing the ERM test, firm-specific details, or verifiable facts are present anywhere in the paragraph, resulting in Generic Boilerplate specificity.


fact: Security Incident Response Plan ("SIRP")

fact: encryption protocols

fact: multi-factor authentication

fact: data loss prevention controls

reasoning: The paragraph primarily describes the cybersecurity program's incident response framework (SIRP), data protection measures (encryption, MFA, DLP), and BC/DR testing, answering 'What does the cybersecurity program do?' (RMP); vendor engagement is subordinate to internal processes. Specificity reaches Firm-Specific due to the named SIRP program, with supporting domain terms like encryption protocols, MFA, and DLP.


reasoning: The paragraph primarily describes due diligence processes for critical third-party service providers handling sensitive information, including access assessments and contractual validations, making third-party risk management the central topic (Third-Party Risk). It lacks any domain-specific cybersecurity terminology beyond generic risk management language, firm-specific details like named roles or committees, or verifiable facts such as quantities or dates, resulting in Generic Boilerplate specificity.


fact: In 2023, the Cybersecurity Incident related costs net of an expected insurance receivable totaled $1.0 million

fact: Our system remediation efforts regarding the Cybersecurity Incident were concluded as of December 30, 2023

fact: In the fourth quarter of 2024, we received proceeds from our insurance claim that exceeded the amount recorded as a receivable by $0.6 million

reasoning: This paragraph details the specifics of a real cybersecurity incident including containment actions, restoration timeline, remediation completion date, and associated costs/insurance proceeds, directly answering 'What happened in a cybersecurity incident?' making it Incident Disclosure. Multiple quantified costs ($1.0M, $0.6M) and a specific date (December 30, 2023) elevate specificity to Quantified-Verifiable.


fact: Cybersecurity Leadership Team

reasoning: This paragraph describes the Board's oversight of cybersecurity risks, delegation to the Audit Committee, and reporting flows from management teams, directly answering the Board Governance question per Rule 1 (board-level committee). Specificity reaches Firm-Specific due to the named 'Cybersecurity Leadership Team,' a firm-unique organizational entity; no domain terms pass the ERM test and no verifiable facts present.


fact: CISO

fact: steering committee on information security

fact: over 20 years of experience

fact: CIO Executive Education Certificate from Stanford University

reasoning: Paragraph primarily describes management organization via CISO role, steering committee structure/membership, and CISO qualifications, fitting Management Role per MR focus on leadership roles/responsibilities over governance chain or program activities. Specificity reaches Quantified-Verifiable due to verifiable claims like 'over 20 years of experience' and named Stanford certificate, plus firm-specific named role/committee.


fact: Incident Response Team (IRT), a committee of IT members including the Company's Chief Information Officer

fact: Chief Information Officer

fact: DPT (Disclosure Policy Team?) responsible for overseeing investigation and response

reasoning: Paragraph primarily describes the Incident Response Plan (IRP) processes for handling cybersecurity incidents (containment, review, escalation, recovery, remediation), passing the person-removal test for RMP over MR; firm-specific facts like named IRT committee, CIO role, and DPT elevate to Firm-Specific, with no domain terms or verifiable claims overriding.


fact: ransomware attack

fact: In March 2020

reasoning: The paragraph primarily details a specific past cybersecurity incident (ransomware attack in March 2020), including its nature, scope, remediation, and assessed impacts, directly answering 'What happened in a cybersecurity incident?' rather than broader strategy or governance. Specificity is Quantified-Verifiable due to the verifiable specific date 'March 2020' tied to the real event and the domain term 'ransomware attack' demonstrating cybersecurity expertise.


fact: Pension Benefit Information, LLC ("PBI")

fact: Progress Software Corporation's MOVEit Transfer software

fact: Form 10-Q for the quarter ended June 30, 2023

fact: approximately 850,000 of Jackson's customers

fact: PBI rectified the MOVEit vulnerability

reasoning: Paragraph describes a real past cybersecurity incident at vendor PBI involving MOVEit software, including scope (850k customers' PII), timing (Q2 2023 10-Q), and remediation, directly answering 'What happened?' for Incident Disclosure. Multiple verifiable facts (named firms, software, date, quantified impact) drive Quantified-Verifiable specificity.


reasoning: Paragraph primarily describes oversight and security requirements imposed on an engaged IT consultant, making third-party risk management the central topic despite some overlap with internal processes (Rule 3: requirements ON vendors → TP). No domain terms passing ERM test, firm-specific facts, or verifiable claims found anywhere, resulting in Generic Boilerplate specificity.


fact: risk assessments designed to help identify material risks from cybersecurity threats to our critical systems and information, as well as risks of data leakage and unauthorized access to sensitive information

fact: ongoing review of the controls framework to support the security of emerging technologies, including artificial intelligence (AI) and generative AI (GenAI)

reasoning: Paragraph lists key elements of the cybersecurity program including risk assessments, security controls, incident response, training, and third-party processes, directly answering 'What does the cybersecurity program do?' (RMP); third-party mention is subordinate. Specificity reaches Domain-Adapted due to cyber-specific terms like 'data leakage', 'unauthorized access', and 'security of AI/GenAI' passing ERM test, with no firm-specific roles/teams or verifiable claims.


reasoning: Paragraph describes the board and Audit Committee's oversight of cybersecurity risks, with information flowing to management including the CFO, directly answering 'How does the board oversee cybersecurity?' making it Board Governance per governance-chain default. No domain terms passing ERM test, no firm-specific roles beyond generic CFO/Audit Committee, and no verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: Paragraph primarily answers how third-party cyber risks are managed through detailed vendor requirements like security certifications, compliance with laws, reasonable measures, and breach reporting, outweighing earlier mentions of hired auditors/experts for internal program support (RMP); most text dedicated to TP. No domain terms passing ERM test, firm-specific facts, or verifiable claims present anywhere, yielding Generic Boilerplate.


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

reasoning: This paragraph is a forward-looking disclaimer about program limitations with a cross-reference to Risk Factors, fitting None/Other per rules on speculation and non-substantive content. It includes the CIA triad as a domain term passing the ERM test (cyber-specific vocabulary), elevating specificity to Domain-Adapted with no higher facts.


reasoning: The paragraph primarily answers whether cybersecurity has affected business outcomes via a negative assertion of no material breaches and potential financial impact, classifying as Strategy Integration per Rule 5 (negative assertions are SI). No domain terms, firm-specific facts, or verifiable claims (negative self-assertion not externally verifiable) found anywhere, yielding Generic Boilerplate specificity.


fact: vulnerability management policy

fact: incident detection and response policies and procedures

fact: encryption of data

reasoning: Paragraph primarily describes cybersecurity program activities like vulnerability management, incident response, and encryption, answering 'What does the cybersecurity program do?' (RMP). Specificity is Domain-Adapted due to domain terms passing ERM test (vulnerability management, incident detection/response, encryption), with no firm-specific or verifiable facts.


reasoning: Paragraph primarily assesses cybersecurity's lack of impact to date ('To date, we have not had a cybersecurity incident') and potential future material effects on business, fitting SI per Rule 5's negative assertion guidance, despite boilerplate speculation and generic process mentions; no specific facts elevate beyond Generic Boilerplate as all content is vague, non-verifiable, and lacks domain terms passing ERM test, firm-specific details, or quantified claims.


fact: Director of ITD

fact: over 7 years of experience leading cybersecurity teams and programs

reasoning: Paragraph primarily describes the board's oversight of cybersecurity, including reporting lines from management (ITD Director to CFO to Board) and escalation processes, fitting Board Governance per governance-chain default. Specificity reaches Quantified-Verifiable due to the verifiable lower-bound experience claim ('over 7 years') and firm-specific 'Director of ITD' role in cybersecurity context.


fact: CISO

fact: Chief Information Officer

reasoning: Paragraph describes board and Audit Committee oversight of cybersecurity risks, including update frequency and escalation protocols from CISO/CIO, directly answering 'How does the board oversee cybersecurity?' (BG per governance-chain default). Specificity reaches Firm-Specific due to named cybersecurity leadership roles (CISO, CIO); no domain terms or verifiable facts elevate higher.


fact: Vice President of Information Technology

reasoning: Paragraph describes board-level oversight via the audit committee, including meeting frequency and annual reviews by management, directly answering 'How does the board oversee cybersecurity?' (BG). Specificity reaches Firm-Specific due to the named VP of Information Technology role, a firm-unique leadership fact; no domain terms or verifiable claims present.


reasoning: This paragraph provides generic boilerplate about ongoing exposure to cybersecurity risks and vague commitments to improvement without addressing any substantive question on governance, management, processes, incidents, or strategy integration. No specific facts, domain terms, firm-specific details, or verifiable claims are present, resulting in Generic Boilerplate specificity.


fact: VP of IT

reasoning: Paragraph primarily describes Board and Audit Committee oversight structure, delegation, and reporting flow for cybersecurity risks, directly answering 'How does the board oversee cybersecurity?' (BG). Specificity driven by firm-specific 'VP of IT' role (Level 3 named role); no domain terms pass ERM test and no verifiable claims present.


fact: Chief Information Security Officer (CISO)

fact: Chief Risk Officer (CRO) supervises CISO

fact: Chief Technology Officer (CTO)

reasoning: Paragraph primarily describes management roles, reporting lines (CISO under CRO, coordinating with exec team), and responsibilities for implementing the security program, fitting Management Role per person-removal test and Rule 1 (management-level structure). Specificity reaches Firm-Specific due to named cybersecurity-relevant VP+ roles (CISO, CRO, CTO); no domain terms pass ERM test and no verifiable claims present.


reasoning: Paragraph contains forward-looking speculation ('could have a material adverse effect') and a cross-reference to Item 1A, which per Rule 5 and 6 is None/Other as it lacks substantive cybersecurity disclosure. No domain terms, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


fact: patching and vulnerability management

fact: cybersecurity tabletop exercise

fact: incident preparedness

fact: security awareness training

fact: cybersecurity threat assessment

reasoning: This paragraph describes board oversight through briefing frequency (annual report, semiannual sessions) and scope of topics covered, directly answering the Board Governance question. Multiple domain terms like 'patching and vulnerability management' and 'cybersecurity tabletop exercise' demonstrate cybersecurity expertise, setting specificity to Domain-Adapted with no firm-specific roles or verifiable claims.


fact: VP of IT has served in various roles in information technology and information security for over 24 years

fact: VP of IT served as the Chief Information Security Officer of a healthcare company

fact: VP of IT was a member of the cyber emergency response team at several companies

fact: VP of IT holds undergraduate and graduate degrees in computer science

fact: VP of IT has attained various professional certifications in cybersecurity

fact: Cybersecurity Response Committee

fact: NVP of Finance and the rest of the Cybersecurity Response Committee have over 50 years of collective experience

reasoning: Paragraph details management leadership qualifications, experience, and committee composition, directly answering 'How is management organized?' (MR per person-removal test: collapses without persons, no program activities). Specificity reaches Quantified-Verifiable due to hard lower-bound numbers ('over 24 years', 'over 50 years') and firm-specific elements like VP of IT role and named Cybersecurity Response Committee.


reasoning: The paragraph primarily states a conclusion that cybersecurity incidents have not materially affected business strategy, results of operations, or financial condition (backward-looking materiality assessment per Rule 5), with additional generic threat discussion and cross-reference, making Strategy Integration the best fit over None/Other. No domain terms passing ERM test, firm-specific facts, or verifiable claims anywhere in the text, resulting in Generic Boilerplate specificity.


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

fact: Risk Management and Processes (named department/team)

reasoning: Paragraph describes integrating cybersecurity risk management into the ERM framework with CIA triad protection goals, directly answering 'What does the cybersecurity program do?' (RMP, ERM integration). Specificity reaches Firm-Specific due to named 'Risk Management and Processes' department and domain term CIA triad; no verifiable Level 4 facts.


reasoning: Paragraph centrally describes processes for identifying, monitoring, addressing, recommending measures for, requiring management of risks by, and conducting audits on third-party service providers and supply chain, making Third-Party Risk the primary category per rules (vendor oversight central). No domain terminology passing ERM test, firm-specific elements (e.g., named roles/committees), or verifiable facts (no numbers, dates, named firms); fully generic boilerplate.


fact: Senior Vice President of Engineering

fact: Chief Information Security Officer (CISO)

fact: Chief Privacy Officer

fact: Privacy and Security Council

reasoning: Paragraph primarily describes management organization, roles (CISO, SVP Engineering, CPO), reporting lines to CEO/GC, and the Privacy and Security Council structure for handling cybersecurity (MR per Rule 1/2, person-removal leaves team activities but focus is on who/organization). Specificity driven by multiple firm-specific named roles and committee (Level 3), no domain terms or verifiable claims.


fact: ransomware virus

fact: one cybersecurity incident in the last decade

reasoning: Paragraph details an actual ransomware incident's nature (ransomware encrypting machines), response (identified, isolated, restored from backup), scope, and minimal impact, directly answering 'what happened' for Incident Disclosure per rules. Specificity is Quantified-Verifiable from the hard count 'one incident' (verifiable threshold over decade prior to 2024 filing) and domain term 'ransomware virus' passing ERM test.


reasoning: The paragraph states a conclusion about past cybersecurity incidents not materially affecting business strategy, results of operations, or financial condition, directly matching Strategy Integration per Rule 5 (backward-looking materiality assessment). No domain terminology passing the ERM test, firm-specific facts, or verifiable claims are present anywhere in the text, warranting Generic Boilerplate specificity.


fact: threat intelligence

fact: security tools deployed in the information technology environment

reasoning: Paragraph primarily describes the cybersecurity program's activities (developing risk methodology, prevent/detect/mitigate/remediate efforts via threat intelligence, security tools alerts), passing the person-removal test for RMP over MR despite management as subject; board oversight is introductory. Specificity driven by domain terms like 'threat intelligence' and 'security tools' passing ERM test, no firm-specific or verifiable facts.


reasoning: This paragraph details the incident response process (initial assessment by IT team, cross-functional team review of scope, impact, materiality), directly answering what the cybersecurity program does, classifying as Risk Management Process; not Incident Disclosure as it is hypothetical ('in the event of'). No domain-specific cybersecurity terms passing ERM test (generic incident steps any ERM pro would describe), no firm-specific roles/teams (IT team and cross-functional team are generic), and no quantifiable or verifiable facts, resulting in Generic Boilerplate.


reasoning: This paragraph describes quarterly briefings from management to the Audit Committee (board-level) on cybersecurity topics, answering how the board oversees risks via information flow and oversight structure (BG per Rule 1). No domain terms passing ERM test, firm-specific facts, or verifiable claims found anywhere, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily describes vendor oversight processes, contractual requirements, pre-engagement reviews, annual re-evaluations, and data deletion obligations, making third-party risk management the central topic (TP per Rule 3). No domain terminology passing the ERM test, firm-specific facts (e.g., named roles/committees), or verifiable claims (e.g., numbers, dates, certifications) are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph is primarily a cross-reference to Item 1A Risk Factors with a vague mention of senior leadership evaluation, which lacks substantive cybersecurity disclosure and fits None/Other per rules on cross-references and non-specific content. No domain terminology passing the ERM test, firm-specific facts, or verifiable claims are present anywhere, confirming Generic Boilerplate specificity.


fact: security incident in January 2023

reasoning: This paragraph describes a real cybersecurity incident including timing (January 2023), nature (impacted computer systems), response (reported to law enforcement, restored systems), and no data misuse, directly answering 'What happened in a cybersecurity incident?' making it Incident Disclosure. Specificity reaches Quantified-Verifiable due to the specific date 'January 2023' tied to the event, which is externally verifiable.


fact: incident response lifecycle

reasoning: The paragraph primarily describes the components and features of the incident response plan (team, lifecycle, templates, timelines, communication, notification), answering 'What does the cybersecurity program do?' which is Risk Management Process; the negative incident history and physical security event are secondary. Specificity is Domain-Adapted due to the domain-specific term 'incident response lifecycle' demonstrating cybersecurity expertise via the ERM test, with no firm-specific roles/committees or verifiable claims like hard numbers, dates, or certifications.


fact: third-party risk management (TPRM) program

reasoning: Paragraph centrally describes policies and a program for managing third-party security risks, directly answering the Third-Party Risk question per Rule 3 (vendor oversight as central topic). Specificity reaches Firm-Specific due to the named internal TPRM program, a distinguishing firm-unique fact; no domain terms pass ERM test for L2, no verifiable claims for L4.


fact: Enterprise Risk Committee ("ERC")

fact: Operational Risk Committee ("ORC")

fact: Chief Information Security Officer ("CISO")

fact: Cybersecurity team coordinates with Compliance, Human Resources, Internal Audit and Legal

reasoning: Paragraph describes management-level committees (ERC, ORC), CISO responsibilities, reporting lines, and team coordination, directly answering 'How is management organized to handle cybersecurity?' per MR category and Rule 1 (management-level, not board). Specificity driven by multiple firm-specific facts like named committees, CISO role, and listed stakeholder departments, reaching Firm-Specific (Level 3) with no higher verifiable claims.


reasoning: Paragraph describes the cybersecurity program's procedures for mitigating internal risks through employee communication/training at onboarding and annually, directly answering 'What does the cybersecurity program do?' with no substantive domain terms, firm-specific details, or verifiable facts elevating beyond generic boilerplate.


fact: encryption

fact: data loss prevention technology

fact: authentication technology

fact: entitlement management

fact: access control

fact: anti-virus and anti-malware software

fact: transmission of data over private networks

fact: National Institute of Standards and Technology Cybersecurity Framework

reasoning: The paragraph primarily describes the cybersecurity program's tools, technologies, and framework (NIST CSF), directly answering 'What does the cybersecurity program do?' for Risk Management Process; it contains multiple domain-specific terms like data loss prevention, entitlement management, and NIST CSF that demonstrate cybersecurity expertise, elevating specificity to Domain-Adapted with no higher-level facts.


fact: Cybersecurity Manager

reasoning: The paragraph primarily describes processes for assessing and monitoring third-party providers before engagement and ongoing, making vendor oversight the central topic (TP); the final sentence on no material incidents is secondary (SI per Rule 5). Specificity reaches Firm-Specific due to the named 'Cybersecurity Manager' role, a firm-unique leadership position with cybersecurity qualifier; no domain terms pass ERM test and no verifiable facts present.


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

reasoning: Paragraph describes the cybersecurity program's activities including risk assessment, monitoring, user training, incident response, and ERM integration, directly answering 'What does the cybersecurity program do?' (RMP). Specificity reaches Domain-Adapted due to the CIA triad reference, a cybersecurity-specific concept passing the ERM test, with no firm-specific roles or verifiable claims.


fact: Chief Information Officer

fact: Chief Information Security Officer

reasoning: Paragraph primarily describes Audit Committee oversight of cybersecurity risks, including quarterly reports from CIO/CISO and annual evaluations provided to the Board, directly answering 'How does the board oversee cybersecurity?' (BG per governance-chain and board-level committee rules). Specificity reaches Firm-Specific due to named VP-level cybersecurity roles (CIO, CISO), with no higher verifiable facts.


fact: CISO

fact: CIO

fact: CCO of the Company

fact: Morgan Stanley's Cybersecurity Program

reasoning: Paragraph describes board oversight of cybersecurity, including updates from specific officers on the program and threats, directly answering 'How does the board oversee cybersecurity?' → Board Governance. Named cybersecurity roles (CISO, CIO) and the firm's Cybersecurity Program elevate to Firm-Specific as firm-unique organizational details.


fact: Chief Information Security Officer ("CISO")

reasoning: Paragraph details the CISO's leadership responsibilities, oversight, coordination, and reporting for the cybersecurity program, directly answering 'How is management organized to handle cybersecurity?' (MR per person-removal test as it centers on the role). Specificity reaches Firm-Specific due to the named CISO role, a firm-unique leadership fact; no higher verifiable claims present.


fact: three Directors... who have cybersecurity risk management experience

fact: Ann Bordelon, Chair of the Audit Committee

fact: Paulette Dodson... who have cybersecurity risk management experience

fact: Noah Glass... who have cybersecurity risk management experience

reasoning: Paragraph primarily describes Board and Audit Committee oversight of cybersecurity risks, including updates, discussions, and director expertise, directly answering the Board Governance question. Specificity is Quantified-Verifiable due to the quantified claim of three directors with cyber experience and named individuals, which are externally verifiable via company filings or bios.


fact: members hold CISSP certification

fact: members hold CCNP certification

fact: members hold CISA certification

fact: members hold CySA+ certification

reasoning: Paragraph describes the qualifications (experience and certifications) of the management team responsible for cybersecurity risks, directly answering 'How is management organized to handle cybersecurity?' (MR per rules). Specificity reaches Quantified-Verifiable due to named certifications (CISSP, CCNP, CISA, CySA+) held by team members, which are externally verifiable via certification registries.


fact: identification and testing of vulnerabilities

fact: phishing simulations

fact: cybersecurity awareness training

fact: targeted attack simulations

reasoning: Paragraph describes specific cybersecurity program activities like vulnerability testing, phishing simulations, and targeted attack simulations, directly answering 'What does the cybersecurity program do?' (RMP); no board/management structure or third-party oversight as central. Specificity driven by multiple domain-specific cyber practices (vulnerability testing, phishing sims, attack sims) that pass ERM test, reaching Domain-Adapted with no firm-specific roles/teams or verifiable claims.


reasoning: The paragraph primarily states a backward-looking materiality conclusion that cybersecurity risks have not materially affected the business, directly answering a Strategy Integration question per Rule 5; the vague mention of occasional threats and cross-reference do not override this. No domain terms passing the ERM test, firm-specific facts, or verifiable claims are present anywhere, resulting in Generic Boilerplate specificity.


fact: Risk Committee

reasoning: Paragraph describes how management and Risk Committee provide regular updates (quarterly cyber events, annual program overview) and risk assessments to the board, directly answering board oversight and information flow → Board Governance. Specificity driven by named Risk Committee (firm-specific Level 3); no domain terms pass ERM test, no verifiable facts.


fact: management team including those from legal, finance, and internal audit

fact: threat intelligence

reasoning: Paragraph primarily describes management's organizational involvement in supervising cybersecurity efforts, specifying departments like legal, finance, and internal audit (MR per person-removal test and team composition). Specificity reaches Firm-Specific due to named team composition (legal, finance, internal audit); threat intelligence adds domain term but does not exceed L3.


fact: CSO (Chief Security Officer)

fact: Executive Vice President and Chief Operations Officer

fact: CSO has over 20 years of security experience

fact: certifications such as Certified Information Systems Security Professional (CISSP) or Certified Information Security Manager (CISM)

reasoning: Paragraph primarily describes board-level oversight (annual briefings) and Audit Committee quarterly reports from CSO, with flow to management roles, fitting BG per governance-chain rule despite MR details on CSO quals. Specificity driven by verifiable facts like 'over 20 years' experience and named certifications CISSP/CISM, plus firm-specific CSO role.


fact: Chief Information Security Officer

fact: prevention, detection, mitigation and remediation of cybersecurity incidents

reasoning: Paragraph primarily describes the cybersecurity program's activities (protect systems, respond to incidents, monitoring prevention/detection/mitigation/remediation per IR plans), passing person-removal test for RMP over MR. Specificity driven by firm-specific CISO role (L3) and domain terms like prevention/detection/mitigation/remediation (L2), with no L4 facts.


fact: CIO has over two decades of experience in technology development, management, and security

fact: CEO, CFO, and GC each have over 15 years of experience managing enterprise risks, including cybersecurity threats

fact: The Company's CIO

reasoning: Paragraph details executive qualifications, experience, and roles in cybersecurity, directly answering 'How is management organized to handle cybersecurity?' (MR per leadership credentials focus; person-removal test leaves no program description). Specificity driven by verifiable quantified experience claims ('over two decades,' 'over 15 years') and firm-specific CIO role, maxing at Level 4.


fact: vulnerability scans related to vendors

fact: reviewing security assessments and responses to security questionnaires

reasoning: Paragraph centrally describes vendor management program for cybersecurity risks, including assessments, reviews, audits, vulnerability scans, and contractual obligations imposed on providers, directly answering 'How are third-party cyber risks managed?' making it Third-Party Risk. Specificity is Domain-Adapted due to cyber-specific practices like vulnerability scans and security questionnaires that demonstrate domain expertise beyond generic ERM language, with no firm-specific roles or verifiable quantified facts.


fact: Vice President of IT

fact: Randy Jepsen

fact: over 25 years of experience in the IT industry

fact: 19 years at Smith Douglas and The SMART Builder Solutions

fact: Russell Devendorf

fact: oversaw ... from 2008 to 2017

fact: previous combined experience of almost 50 years

reasoning: Paragraph focuses on management team's roles, responsibilities, qualifications, and experience in cybersecurity oversight, fitting Management Role per person-specific details on leadership (Rule 2). Specificity reaches Quantified-Verifiable due to multiple hard facts like named executives, specific experience years (over 25, 19), and dates (2008-2017).


reasoning: Paragraph primarily describes ongoing cybersecurity program activities like periodic assessments, testing, audits, and reviews with adjustments, answering 'What does the cybersecurity program do?' (RMP); the non-material incident note and cross-reference are secondary and do not shift to SI or ID as they lack detail or forward-looking assessment dominance. No domain terms, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


fact: CISO

fact: CIO

fact: Audit & Finance Committee

reasoning: Paragraph describes Audit & Finance Committee oversight of cybersecurity strategy, governance, policies, and briefings from CISO/CIO/external advisors, directly answering board oversight question (BG per Rule 1). Specificity reaches Firm-Specific due to named cybersecurity roles (CISO, CIO) and named committee, with no domain terms or verifiable claims elevating higher.


fact: Enterprise Risk Committee ("ERC")

fact: Operational Risk Committee ("ORC")

fact: Chief Information Security Officer ("CISO")

fact: TPG's cybersecurity team

fact: over a 17-year period

fact: holds a Bachelor of Science in Electrical Engineering and Mathematics from the University of Texas at Arlington

fact: Certified Information Systems Security Professional (CISSP)

reasoning: The paragraph details TPG's management-level committees (ERC, ORC), CISO responsibilities, reporting lines, team coordination, and leadership qualifications, directly answering how management is organized for cybersecurity (Management Role per Rule 1). Multiple verifiable facts including 17 years experience, specific degree/university, and CISSP certification elevate specificity to Quantified-Verifiable.


fact: dedicated management-level cybersecurity risk committees

fact: Non-Financial Risk Committee

fact: Firm Risk Committee

fact: BOTC

fact: Head of Operational Risk

reasoning: Paragraph describes oversight structure via management-level committees, escalation paths, and reporting lines from officers (CIO, Head of Operational Risk) to firm committees (Non-Financial Risk, Firm Risk, BOTC) and boards, answering 'How does the board oversee cybersecurity?' per governance-chain default to BG. Specificity reaches Firm-Specific due to multiple named committees and senior roles (CIO, Head of Operational Risk), with no domain terms or verifiable claims elevating higher.


fact: ISO 27001:2022 information security standard

fact: Security Operations Center (SOC)

reasoning: Paragraph primarily describes the cybersecurity program's activities, including risk assessment using ISO 27001:2022 and maintenance of a SOC for monitoring, answering 'What does the cybersecurity program do?' → Risk Management Process. Specificity driven by domain terms ISO 27001:2022 (framework) and SOC (security infrastructure expertise beyond generic ERM language) → Domain-Adapted; no firm-specific roles/committees or verifiable quantities/dates.


fact: Vice President of IT

fact: Information Security Manager

fact: United States Computer Emergency Readiness Team alerts

reasoning: Paragraph primarily details management-level roles (CFO, VP of IT, ISM) and reporting lines between them (weekly/quarterly), with board briefings secondary, fitting Management Role over Board Governance per most text rule and MR focus on organization/reporting; firm-specific named roles (VP of IT, ISM) drive Firm-Specific level, augmented by domain term US-CERT but no verifiable facts for L4.


fact: Chief Capability Officer (CCO)

fact: Chief Information Officer (CIO)

fact: Chief Information Security Officer (CISO)

reasoning: Paragraph primarily describes Audit Committee oversight of cybersecurity via quarterly reports, direct engagement with named executives, and audit results reporting, answering 'How does the board oversee cybersecurity?' (BG per Rule 1). Named CISO, CIO, and CCO roles are firm-specific facts elevating specificity to Firm-Specific (Level 3); no domain terms or verifiable claims present.