reasoning: This paragraph is a cross-reference to risk factor disclosures in another section (Item 1A), providing no substantive cybersecurity information itself, fitting None/Other per Rule 5 and 6. No specific facts of any level are present, confirming Generic Boilerplate specificity.


content_category: Strategy Integration

category_confidence: high

specificity_confidence: high

reasoning: This paragraph states a conclusion about the lack of material past and anticipated future impact of cybersecurity on business strategy, results of operations, and financial condition, directly answering a Strategy Integration question per the materiality rule. No specific facts, domain terms, firm-specific details, or verifiable claims are present, resulting in Generic Boilerplate specificity.

provider: x-ai

stage: benchmark


content_category: Risk Management Process

fact: layered security model

fact: confidentiality, integrity, and availability of our information systems

reasoning: Paragraph primarily describes the cybersecurity program's components and objectives (layered security model protecting CIA triad), directly answering 'What does the cybersecurity program do?' → RMP. Includes domain-specific terms like 'layered security model' and CIA triad that demonstrate cybersecurity expertise beyond generic ERM language → Domain-Adapted.


content_category: Board Governance

reasoning: Paragraph describes board-level oversight of cybersecurity risks by the Board and its Risk Committee, directly answering 'How does the board oversee cybersecurity?' (BG per Rule 1). Specificity at Firm-Specific due to the named non-generic board committee 'Risk Committee of the Board of Directors' distinguishing the company's structure.


content_category: Management Role

fact: threat intelligence

reasoning: Paragraph primarily describes executive leadership roles (CFO, SVP/GC) and their supervisory responsibilities over cybersecurity efforts, fitting Management Role per person-removal test where removing roles leaves generic supervision without substantive program details. Specificity at Domain-Adapted due to 'threat intelligence' as a cybersecurity-specific term passing ERM test; no firm-specific roles (CFO/GC generic) or verifiable facts.


fact: vulnerability assessments

reasoning: Paragraph describes Audit Committee and Board oversight, frequency (at least annually), and discussion topics like vulnerability assessments, directly answering 'How does the board oversee cybersecurity?' → Board Governance. Specificity driven by 'vulnerability assessments' as a domain term passing ERM test (cyber-specific practice), no firm-specific roles/committees or verifiable claims like numbers/dates.


reasoning: Paragraph describes the incident response program, including team coordination, escalation processes, tracking, and annual testing, directly answering 'What does the cybersecurity program do?' (RMP); person-removal test leaves substantive program activities intact. No domain-specific terminology (all ERM-generic language like incident response and escalation), no firm-specific roles/committees/programs, and no verifiable facts (generic 'at least one annual' cadence), yielding empty specific_facts and Generic Boilerplate specificity.


content_category: Third-Party Risk

reasoning: The paragraph primarily describes a third-party risk management program to handle cybersecurity risks from third-party service providers, making Third-Party Risk the central topic per category rules. No domain terminology passing ERM test, firm-specific facts, or verifiable claims are present anywhere in the text, resulting in Generic Boilerplate specificity.


content_category: None/Other

reasoning: This paragraph is a cross-reference to the Risk Factors section, providing no substantive cybersecurity disclosure, fitting None/Other per category rules for cross-references. No specific facts, domain terms, or verifiable claims are present, resulting in Generic Boilerplate specificity.


category_confidence: medium

reasoning: Paragraph primarily assesses cybersecurity's lack of impact to date ('we have not had a cybersecurity incident') and potential future material effects, fitting Strategy Integration per Rule 5's negative assertion and materiality conclusion guidelines, despite speculative language and cross-reference suggesting None/Other. No specific facts of any level found: generic risk language lacks domain terminology passing ERM test, firm-specific details, or verifiable claims like dates/numbers.


content_category: Incident Disclosure

fact: announced on October 28, 2023

fact: impacting certain internal operations and information technology systems

fact: adversely affected our ability to ship orders in the first quarter of fiscal 2024

fact: All of our facilities were operational by mid-December 2023

fact: incurred $1.5 million of expenses...in the first fiscal quarter of fiscal 2024

type: quantified

reasoning: Paragraph primarily describes a real cybersecurity incident's nature, timing (Oct 28, 2023 announcement, Q1 FY2024 impact, mid-Dec 2023 resolution), scope (internal ops/IT systems, shipping), impact ($1.5M expenses), and remediation, fitting Incident Disclosure over Strategy Integration despite materiality statement; specificity driven by multiple verifiable facts like dates and quantified costs.


fact: Chief Technology Officer

fact: Executive Vice President – Operations

fact: CTO reports to EVP-Operations

fact: technology services team

reasoning: Paragraph describes management reporting lines (CTO to EVP-Operations, incidents to legal) and qualifications/experience of specific leaders and team, directly answering 'How is management organized?' per MR definition and person-removal test (collapses without roles). Firm-specific named VP+ roles (CTO, EVP-Operations) and reporting line elevate to Firm-Specific; no domain terms or verifiable claims.


reasoning: This paragraph is pure forward-looking speculation about potential costs and impacts of hypothetical security breaches, matching the 'could have a material adverse effect' pattern excluded from Strategy Integration by Rule 5 and qualifying as None/Other under Rule 6 for lacking substantive cybersecurity disclosure. No specific facts of any level are present anywhere in the paragraph, resulting in Generic Boilerplate specificity.


reasoning: Paragraph describes working with third-party service providers to develop cybersecurity processes and response plan, primarily answering 'What does the cybersecurity program do?' (RMP), with third parties hired internally per Rule 3. No domain terms, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes employee training and awareness as part of the cybersecurity program, directly answering 'What does the cybersecurity program do?' under Risk Management Process; no domain-specific terminology, firm-unique facts, or verifiable claims are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph centers on assessing and managing cybersecurity threats from third-party service providers' IT systems, directly addressing third-party risk management as the primary topic per Rule 3 (vendor oversight central). It contains no domain terminology passing the ERM test, firm-specific facts, or verifiable claims, warranting Generic Boilerplate specificity.


fact: CISO

fact: over 30 years of industry experience

fact: joining Visa in November 2015

fact: President of Technology

fact: joined Visa in November 2013

fact: over 30 years of experience

fact: Zero Trust Architecture

fact: VisaNet

reasoning: Paragraph focuses on leadership roles, qualifications, tenure, and responsibilities of CISO and President of Technology, directly answering 'How is management organized?' per Management Role; person-removal test confirms no remaining program description. Specificity reaches Quantified-Verifiable due to multiple verifiable claims like specific join dates (Nov 2015, Nov 2013) and quantified experience (>30 years), alongside firm-specific roles and domain terms like Zero Trust Architecture.


fact: Steering Committee

reasoning: Paragraph primarily describes the responsibilities and oversight activities of the management-level Steering Committee in monitoring and reviewing the cybersecurity program, fitting Management Role per Rule 1 (management-level committee activities) and person-removal test leaving oversight processes but centered on committee role. Specificity driven by the named Steering Committee as a firm-specific fact elevating to Firm-Specific; no domain terms pass ERM test beyond generics, no verifiable claims.


reasoning: Paragraph describes board-level oversight of cybersecurity risks via the Audit Committee, including review frequency and reporting flow, directly answering the Board Governance question. No domain terms, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph primarily assesses the lack of material past or likely future cybersecurity impacts on business strategy, results of operations, or financial condition, directly matching Strategy Integration per Rule 5 (backward- and forward-looking materiality statements). No specific facts elevate specificity beyond Generic Boilerplate, as it contains only negative self-assertions, vague mitigation language, and no domain terms, firm-specific details, or verifiable claims.


reasoning: The paragraph primarily describes employee security awareness training and integration of cybersecurity into the ERM framework via tracking KRIs and risk mitigation, directly answering 'What does the cybersecurity program do?' (RMP). No domain-specific terminology passing the ERM test, firm-specific facts, or verifiable claims are present, resulting in Generic Boilerplate specificity.


fact: service organization controls reports provided by the third parties

fact: Risk Management, Legal and/or Information Security Departments

reasoning: Paragraph centrally describes third-party service provider management program, contract reviews for cyber risks, SOC reports, and due diligence to ensure data security obligations, directly answering 'How are third-party cyber risks managed?' (TP). Specificity reaches Firm-Specific due to named departments (Risk Management, Legal, Information Security) as specific team composition and domain term 'service organization controls reports' (SOC); no verifiable facts.


reasoning: This paragraph primarily addresses the lack of material impact from cybersecurity risks, including past incidents, on business strategy, operations, and finances, along with insurance coverage, fitting Strategy Integration per Rule 5. It contains no domain terminology, firm-specific details, or verifiable facts, warranting Generic Boilerplate specificity.


fact: on October 3, 2024, the Company identified unauthorized activity within its information technology computer networks and systems, which was determined to be the result of a cybersecurity incident

reasoning: Paragraph primarily describes a specific past cybersecurity incident including timing, nature (unauthorized activity), and impact assessment, fitting Incident Disclosure as it references a real event with timeline and scope. Specificity reaches Quantified-Verifiable due to the externally verifiable specific date of October 3, 2024, tied to the incident.


reasoning: Paragraph describes oversight structure with Audit Committee (board-level) overseeing CEO's cybersecurity responsibilities and reporting material threats to the Board, fitting Board Governance per Rule 1 on governance-chain and board-level committees. No domain terms, firm-specific facts (CEO and Audit Committee are generic), or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


fact: announced on October 28, 2023

fact: impacting certain internal operations and information technology systems

fact: adversely affected our ability to ship orders in the first quarter of fiscal 2024

fact: All of our facilities were operational by mid-December 2023

fact: $1.5 million of expenses related to the cybersecurity incident in the first fiscal quarter of fiscal 2024

reasoning: Paragraph primarily describes a specific cybersecurity incident including its announcement date, scope, timeline, operational impacts, and remediation costs, directly answering 'what happened in a cybersecurity incident' per Incident Disclosure criteria. Specificity reaches Quantified-Verifiable due to multiple externally verifiable facts like the October 28, 2023 announcement, mid-December 2023 recovery, and $1.5 million expenses.


fact: Our Third Party Program

reasoning: Paragraph centrally describes the company's Third Party Program for managing third-party risks (identification, measurement, etc.), directly answering how third-party cyber risks are managed per TPR definition in cybersecurity disclosure context. Specificity reaches Firm-Specific due to the named 'Third Party Program' as a distinguishing internal program; no domain terms or verifiable claims present.


reasoning: This paragraph speculates on general IT system failures disrupting business without mentioning cybersecurity programs, oversight, or measures, classifying as None/Other per Rule 6 and Rule 5 (pure speculation). No domain terms, firm-specific facts, or verifiable claims anywhere, yielding Generic Boilerplate specificity.


reasoning: This paragraph describes the existence and periodic testing of incident response and recovery plans, directly answering what the cybersecurity program does (RMP), not oversight structure or roles. No domain-specific terms, firm-unique facts, or verifiable claims are present, resulting in Generic Boilerplate specificity.


fact: InfoSec Director

fact: eRISC committee

reasoning: Paragraph describes reporting lines from InfoSec Director through eRISC committee and executives to the Board, directly answering how the board oversees cybersecurity via information flow (BG). Firm-specific facts include the InfoSec Director role and eRISC committee, elevating specificity to Firm-Specific with no higher verifiable claims.


reasoning: Paragraph describes engaging external experts for audits, threat assessments, and security enhancements as part of internal risk management, fitting RMP per Rule 3 (third parties serving the company, not vendor oversight). No domain terms passing ERM test, firm-specific facts, or verifiable claims found anywhere, resulting in Generic Boilerplate.


fact: CISO

reasoning: Paragraph describes board-level oversight by the Audit Committee, including quarterly CISO briefings on risks, trends, assessments, incident response, and threats, with flow to full Board and ad hoc engagements, directly answering 'How does the board oversee cybersecurity?'; specificity reaches Firm-Specific due to mention of CISO as a firm-unique cybersecurity leadership role, with no domain terms passing ERM test or verifiable facts.


reasoning: The paragraph asserts no material past cybersecurity impacts on operations/financials and mentions cyber liability insurance, fitting Strategy Integration per the materiality rule for backward-looking assessments and insurance coverage. No domain terms, firm-specific details, or verifiable facts (negative assertions and generic insurance reference do not qualify), yielding Generic Boilerplate specificity.


reasoning: Paragraph describes a Vendor Management program specifically for managing risks from third-party providers with access to confidential information, making third-party risk the central topic (TP per Rule 3). No domain terms passing ERM test, firm-specific facts, or verifiable claims found anywhere, resulting in Generic Boilerplate specificity.


fact: quarterly vulnerability scanning

fact: PCI DSS compliance requirements

type: framework

fact: annual network assessments

fact: annual penetration testing

fact: vulnerability scans as part of cyber insurance underwriting process

reasoning: Paragraph describes specific cybersecurity assessments and scans (vulnerability scanning, penetration testing, network assessments, PCI DSS), which are program activities, fitting Risk Management Process per Rule 3 (third-party assessors hired by the company → RMP, not TP). Specificity driven by multiple domain terms passing ERM test (cyber-specific practices and PCI DSS standard), with no firm-specific roles/committees or verifiable hard facts like numbers/dates/named firms.


reasoning: Paragraph primarily describes generic processes to assess, identify, and manage cybersecurity risks and mentions reliance on the Adviser's program, directly answering 'What does the cybersecurity program do?' (RMP); third-party dependence is subordinate. No domain terms passing ERM test, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


fact: Prudential's CISO

fact: CIO

fact: Operational Risk Management

reasoning: Paragraph describes Board oversight of cybersecurity risks, review of IT security controls, and receipt of updates from specific roles like CISO/CIO, directly answering 'How does the board oversee cybersecurity?' (BG). Specificity reaches Firm-Specific due to named cybersecurity leadership roles (CISO, CIO) and team (Operational Risk Management), with no higher verifiable facts like quantities or dates.


reasoning: This paragraph speculates on potential cybersecurity risks like hacking without describing any oversight, processes, roles, incidents, or materiality assessments, making it None/Other per rules on speculation and lack of substantive disclosure. No domain terms passing the ERM test, firm-specific facts, or verifiable claims are present anywhere in the text, confirming Generic Boilerplate specificity.


reasoning: Paragraph states conclusions on no material past or likely future impacts from incidents and lack of cyber insurance, fitting Strategy Integration per materiality rule for assessments of business/financial effects. No domain terminology, firm-specific facts, or verifiable claims (negative assertions not externally verifiable) → Generic Boilerplate.


reasoning: The paragraph centers on the company's third-party risk management program specifically for cybersecurity risks from service providers, directly answering the Third-Party Risk question as the central topic per Rule 3 (TP vs RMP). No domain terminology passing the ERM test, firm-specific elements like named roles/committees, or verifiable facts like quantities/dates/named firms are present anywhere, yielding Generic Boilerplate.


fact: ransomware attack

fact: In 2021, the Bank was the target of a ransomware attack

fact: external actor illegally accessed and/or acquired certain data on its network

fact: sued in a purported class action lawsuit currently in process of settlement

reasoning: The paragraph primarily describes a specific past cybersecurity incident including its nature (ransomware), timing (2021), scope (data access), and impacts/remediation (lawsuit in settlement), fitting Incident Disclosure as the dominant frame despite some materiality statements. Specificity reaches Quantified-Verifiable due to the 2021 date and verifiable incident details like the ransomware attack and ongoing lawsuit, which are externally checkable via court records.


reasoning: Paragraph details incident response procedures (detection, containment, response, remediation) and a written plan, directly answering what the cybersecurity program does, classifying as Risk Management Process. No domain-specific terms passing ERM test (e.g., 'incident response plan' is explicitly Level 1), firm-specific facts, or verifiable claims found, resulting in Generic Boilerplate.


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

reasoning: This paragraph describes the cybersecurity program's design and assessment using the NIST CSF framework for risk identification, assessment, and management, primarily answering the Risk Management Process question. Specificity is Domain-Adapted due to the named cybersecurity framework (NIST CSF), which demonstrates domain expertise via specific vocabulary passing the ERM test; no firm-specific or verifiable facts present.


reasoning: This paragraph states a conclusion about no material cybersecurity impacts on business strategy, results of operations, or financial condition over specific years, directly matching Strategy Integration per materiality rule (backward- and forward-looking negative assertions). No domain terms, firm-specific facts, or verifiable claims are present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph primarily describes board-level oversight of risks including cybersecurity, reporting protocols, and lack of regular briefings, directly answering 'How does the board oversee cybersecurity?' with no substantive program details. No domain-specific terminology, firm-unique facts (e.g., named roles or committees beyond generic board), or verifiable claims (e.g., numbers, dates, named firms) anywhere in the text, resulting in Generic Boilerplate.


reasoning: The paragraph describes key elements of the cybersecurity risk management program, specifically risk assessments for identifying material risks to critical systems and information, directly answering 'What does the cybersecurity program do?' (RMP). No domain terms, firm-specific facts, or verifiable claims are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes ongoing activities like regularly reviewing and updating systems, processes, and procedures to address evolving cybersecurity threats, directly answering 'What does the cybersecurity program do?' making it Risk Management Process; third-party review is a minor generic mention, not central to Third-Party Risk. No domain terms, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


reasoning: The paragraph centrally describes processes for assessing third-party providers' cybersecurity practices and including cybersecurity requirements in contracts, directly answering the Third-Party Risk question per Rule 3 (requirements imposed on vendors). No domain terms passing the ERM test, firm-specific facts, or verifiable claims appear anywhere, resulting in Generic Boilerplate specificity.


reasoning: Paragraph describes Board oversight of cybersecurity risks, including direct and committee-level review, risk assessments, and annual CISO reports on incidents, projects, and threat response, directly answering 'How does the board oversee cybersecurity?'; Firm-Specific due to mention of CISO as a cybersecurity leadership role, with no higher verifiable facts.


reasoning: This paragraph centrally describes requirements imposed on third-party service providers for security measures and breach reporting, directly answering the Third-Party Risk question per Rule 3 (requirements ON vendors). No domain terminology passing the ERM test, firm-specific facts, or verifiable claims are present anywhere, yielding Generic Boilerplate specificity.


reasoning: This paragraph describes the responsibilities of specific management roles (CFO and Head of IT) in handling cybersecurity, directly answering 'How is management organized to handle cybersecurity?' per MR definition and person-removal test (collapses without roles). No domain terms passing ERM test, no firm-specific facts (CFO and Head of IT are generic roles per rules), and no verifiable claims, resulting in Generic Boilerplate specificity.


reasoning: Paragraph describes use of external third parties to assess and test internal cybersecurity controls, which is part of the RMP (third parties hired to assist company's program, per Rule 3). No domain terms passing ERM test, firm-specific facts, or verifiable claims found anywhere, resulting in Generic Boilerplate specificity.


fact: Chief Information Security Officer (CISO)

fact: Chief Information Officer (CIO)

fact: internal Technology and Operations Committee

fact: Bank's Management Committee

reasoning: Paragraph describes management-level leadership roles (CISO, CIO), reporting lines, and internal committee structure for cybersecurity oversight, fitting Management Role per Rule 1 (management-level) and Rule 2 (focus on organization over activities). Specificity reaches Firm-Specific due to named cybersecurity roles (CISO, CIO) and named committees, with no domain terms or verifiable claims elevating higher.


reasoning: Paragraph describes the CISO's leadership role over the security team and specific responsibilities (risk assessments, security controls, incident response), answering 'How is management organized?' per MR definition and person-removal test showing role focus. Specificity driven by firm-specific named role (CISO) at Level 3; no domain terms elevate beyond and no verifiable facts for Level 4.


reasoning: Paragraph states a conclusion about no material past or likely future cybersecurity impacts on business, directly matching SI materiality rule for backward- and forward-looking assessments; cross-reference is secondary. No specific facts of any level: negative assertions about absence are not verifiable, no domain terms, roles, or quantifiable claims present.


reasoning: This paragraph describes general cyberattacks and threats in the world at large, without referencing the company's own governance, management, processes, incidents, or strategy, making it None/Other speculation. No domain-specific terminology, firm-specific details, or verifiable facts are present, resulting in Generic Boilerplate specificity.


fact: intrusion detection and prevention systems

fact: vulnerability and patch management processes

fact: firewalls

fact: phishing tests

reasoning: The paragraph details the cybersecurity program's measures, controls, tools (firewalls, IDS/IPS, vulnerability/patch management), training, and plans, directly answering 'What does the cybersecurity program do?' for Risk Management Process. Domain-specific terminology like intrusion detection systems, vulnerability management, and phishing tests drives Domain-Adapted specificity, with no firm-specific or verifiable facts.


fact: Advisory Committee of the Board of Managers of the general partner of our General Partner

fact: Board of Managers

reasoning: This paragraph primarily describes board-level oversight of cybersecurity risks, including the Advisory Committee's responsibilities, reporting to the full Board, and briefing cadences, directly answering the Board Governance question per Rule 1 (board/committee oversight structure). Specificity reaches Firm-Specific due to the named, company-unique 'Advisory Committee of the Board of Managers' and 'Board of Managers', distinguishing this LP's governance from generic structures; no domain terms pass ERM test and no verifiable claims present.


reasoning: The paragraph primarily describes the third-party management process for cybersecurity risks with vendors and service providers, directly answering the Third-Party Risk question as the central topic. No domain terms passing the ERM test, firm-specific facts, or verifiable claims are present, warranting Generic Boilerplate specificity.


fact: Chief Information Security Officer

fact: Chief Technology Officer

fact: Chief Operations Officer

fact: over 25 years' experience

reasoning: Paragraph primarily describes management roles (CISO responsibilities, oversight by CTO/COO) and qualifications, fitting Management Role per person-removal test as it centers on who and their expertise rather than program activities. Specificity reaches Quantified-Verifiable due to 'over 25 years' experience' (verifiable quantified claim) and named cybersecurity leadership roles (firm-specific).


reasoning: Paragraph states conclusions on past non-material impact and forward-looking potential material effects of cybersecurity on business/finances, directly matching Strategy Integration materiality rule (backward and Item 106(b)(2) forward-looking assertions), with cross-reference to Risk Factors. No domain terms passing ERM test, firm-specific details, or verifiable facts (negative assertions not verifiable), so empty specific_facts yields Generic Boilerplate.


fact: CISO has served in the role since 2015

fact: experience in application security, intrusion detection, penetration testing, complex threat modeling, and unconventional cyber-attack vectors

fact: RCOC (quarterly meetings)

reasoning: Paragraph primarily describes the CISO's leadership role, qualifications, tenure, team oversight, and reporting to RCOC, answering 'How is management organized to handle cybersecurity?' (MR per person-specific focus and Rule 1/2). Specificity reaches Quantified-Verifiable due to 'since 2015' (verifiable start date) and other L3/L2 facts like named CISO role and domain terms.


reasoning: This paragraph is generic boilerplate introducing cybersecurity risks without describing any oversight, processes, roles, incidents, or strategy, fitting None/Other per Rule 6 as pure speculation without measures. No domain terms, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


reasoning: Paragraph lists components of the cybersecurity program (risk assessments, backups, external testing, training), directly answering 'What does the cybersecurity program do?' making it Risk Management Process; external providers are hired to assist the company's controls (RMP per Rule 3), not vendor oversight (TP). No domain terms passing ERM test (all generic processes any ERM pro would describe), no firm-specific or verifiable facts, so Generic Boilerplate.


fact: Bimini (external manager handling information systems and cybersecurity processes)

reasoning: Paragraph primarily describes reliance on an external manager (Bimini) for information systems and cybersecurity risk processes, centrally addressing third-party risk management. Specificity reaches Quantified-Verifiable due to the named external firm Bimini, which is independently verifiable.


fact: detected unauthorized occurrences on July 10, 2024

fact: threat actor was ejected from our IT systems on July 10, 2024

reasoning: This paragraph describes a specific cybersecurity incident including detection date, response actions, and resolution timeline, directly answering 'What happened in a cybersecurity incident?' making it Incident Disclosure. Specificity reaches Quantified-Verifiable due to multiple specific dates tied to verifiable event claims.


fact: penetration testing

fact: offensive testing

fact: maturity assessments

fact: cyber phishing tests

reasoning: Paragraph lists components of the cybersecurity program (assessments, third-party due diligence as one element, incident response, training, phishing tests), primarily answering 'What does the cybersecurity program do?' → Risk Management Process; third-party is not central. Specificity driven by multiple domain terms (penetration testing, offensive testing, maturity assessments, phishing tests) passing ERM test, no firm-specific roles/committees or verifiable claims.


reasoning: This paragraph details how the Committee receives periodic reports and updates from management on cybersecurity risks and incidents, primarily describing board-level oversight and information flow, fitting Board Governance. It contains no domain terminology beyond generic phrases, no firm-specific elements like named committees or roles, and no verifiable facts, warranting Generic Boilerplate specificity.


fact: Company's Chief Compliance Officer ("CCO") plays an oversight role in the area of cybersecurity preparedness with respect to third-party entities

reasoning: Paragraph primarily describes oversight of cybersecurity risks from third-party vendors/suppliers/service providers using Adviser personnel and CCO, making third-party risk management the central topic (TP per Rule 3). Specificity reaches Firm-Specific due to the named CCO role in cybersecurity oversight, a firm-unique leadership detail; no domain terms or verifiable facts elevate further.


fact: cybersecurity assessments

reasoning: Paragraph describes the company's use of third-party providers for internal cybersecurity activities like program evaluation, monitoring, threat assessment, and mitigation, directly answering 'What does the cybersecurity program do?' (RMP); third parties here are service providers aiding the internal program, not vendor risks (per Rule 3). Specificity driven by domain terms like 'continuous system monitoring and threat detection' that demonstrate cybersecurity expertise (L2 via ERM test), with no firm-specific roles or verifiable claims.


reasoning: Paragraph describes cybersecurity insurance coverage, directly matching Strategy Integration's inclusion of insurance as a financial/business integration element. No domain terms, firm-specific details, or verifiable facts present, resulting in Generic Boilerplate specificity.


fact: CISO

fact: Executive Steering Committee

fact: Executive Vice President, Engineering

fact: Senior Director, IT

reasoning: Paragraph primarily details management organization including CISO's role, Executive Steering Committee structure and membership (management-level), multidisciplinary teams, and reporting lines, fitting Management Role per Rule 1 (management-level committee focus over board reporting at end). Specificity reaches Firm-Specific due to named cybersecurity leadership roles (CISO) and non-generic committee (Executive Steering Committee), with no domain terms or verifiable claims elevating higher.


fact: protect the confidentiality, integrity and availability of our critical systems and information

reasoning: Paragraph describes the cybersecurity program's core function of protecting systems via risk management processes, directly answering 'What does the cybersecurity program do?' (RMP); includes CIA triad terminology passing ERM test for domain expertise, setting specificity to Domain-Adapted with no higher-level facts.


fact: Cybersecurity Steering Committee

fact: one director is the President of a major cybersecurity services provider

reasoning: Paragraph primarily describes board oversight of cybersecurity through updates, education, reports, and Audit Committee expertise, with CISO/Steering Committee as part of the governance chain flowing to the board (BG per Rule 1). Specificity driven by firm-specific facts like CISO role, named Cybersecurity Steering Committee, and unique director position (Level 3), with no domain terms or verifiable claims elevating higher.


reasoning: This paragraph primarily describes board-level oversight of cybersecurity risks, including discussion frequency and audit committee responsibilities, directly answering 'How does the board oversee cybersecurity?' → Board Governance. No domain-specific terminology passing the ERM test, no firm-specific roles/committees beyond generic 'Audit Committee', and no verifiable facts like specific dates or quantities → Generic Boilerplate.


reasoning: Paragraph centrally describes oversight of 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.


reasoning: Paragraph describes board's oversight responsibility for cybersecurity risks and lack of relevant expertise, directly answering 'How does the board oversee cybersecurity?' with no other category dominant. No domain terms, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph discusses generic threats from cybersecurity breaches despite defensive measures and cross-references to Risk Factors, providing no substantive disclosure on oversight, processes, or incidents, thus None/Other. It contains no domain terminology, firm-specific details, or verifiable facts, warranting Generic Boilerplate specificity.


reasoning: This paragraph is a cross-reference to Item 1A risk factors, providing no substantive cybersecurity disclosure on governance, management, processes, or incidents, fitting None/Other per rules on cross-references. No specific facts of any level are present, confirming Generic Boilerplate specificity.


reasoning: Paragraph states a conclusion on no material cybersecurity impacts in 2024 (backward- and forward-looking), directly answering how cybersecurity affects business/finances per SI definition and Rule 5; cross-reference is secondary. No specific facts: '2024' anchors a non-verifiable negative assertion, no domain terms, roles, or verifiable claims present anywhere.


fact: oversight of our cybersecurity and risk management programs since the second half of 2021

reasoning: Paragraph primarily describes the Chief Financial Officer's role, responsibilities, qualifications (lack of experience), tenure, and reliance on third parties for cybersecurity oversight, fitting Management Role per person-removal test (collapses without role details). Specificity reaches Quantified-Verifiable due to the verifiable specific timeframe 'second half of 2021' for when oversight began; no qualifying domain terms or firm-specific roles like CISO (CFO excluded per rules).


fact: chief information security officer

reasoning: Paragraph describes board-level oversight via quarterly CISO reports to the Audit Committee on cyber risks and mitigations, answering 'How does the board oversee cybersecurity?' (BG per Rule 1). Specificity driven by firm-specific CISO role (Level 3); no domain terms pass ERM test and no verifiable claims.


reasoning: Paragraph describes general dependence on IT systems and software integration without any cybersecurity content, processes, oversight, or risks, fitting None/Other. No specific cybersecurity facts, domain terms, or verifiable claims present, resulting in Generic Boilerplate specificity.


reasoning: This is a cross-reference to Item 1A Risk Factors, providing no substantive cybersecurity content, fitting None/Other per rules on cross-references. No domain terms, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph centers on outsourcing financial functions to a third-party firm and evaluating their cybersecurity protections as a key factor in provider selection, directly addressing third-party risk management. No domain-specific cybersecurity terminology, firm-unique roles/committees, quantified metrics, named entities, or verifiable claims are present, resulting in Generic Boilerplate specificity.


fact: virtual Chief Information Security Officer ("vCISO")

reasoning: Paragraph describes how a quarterly third-party risk summary from the vCISO is presented to management and the Board, primarily answering how the board oversees cybersecurity risks via information flow and briefing frequency (BG), though third-party focus adds some TP ambiguity. Specificity driven by firm-specific named security leadership role (vCISO) reaching Firm-Specific level, with no domain terms or verifiable claims elevating higher.


fact: over 23 years of combined Cybersecurity experience

fact: Master's degree in Cybersecurity

fact: military veterans versed in forensic analysis and regulatory compliance

fact: forensic analysis

reasoning: Paragraph describes qualifications, experience, and team composition of cybersecurity leadership, directly answering 'How is management organized to handle cybersecurity?' (MR per person-removal test as it collapses without people). Specificity driven by verifiable quantified claim ('over 23 years') and specific degree, elevating to Level 4.


fact: hardening our environment, systems and infrastructure

fact: cyber readiness

reasoning: The paragraph primarily describes cybersecurity program activities like internal audits, cyber readiness evaluations, environment hardening (vulnerability management), and employee training, directly answering 'What does the cybersecurity program do?' (RMP); the negative risk assertion is subordinate. Specificity reaches Domain-Adapted due to cyber-specific terms like 'hardening' and 'cyber readiness' that demonstrate domain expertise beyond generic ERM language, with no firm-specific or verifiable facts.


reasoning: The paragraph primarily describes the company's cybersecurity processes for risk assessment, safeguards, tests, and reviews, directly answering 'What does the cybersecurity program do?' (RMP); external parties are a minor component, not central (per Rule 3). No domain terms passing ERM test, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


reasoning: This paragraph is a cross-reference to Item 1A risk factors without providing any substantive cybersecurity disclosure, content, or assessment, fitting None/Other per Rule 5 and Rule 6. No specific facts of any level are present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph primarily states a negative assertion of no cybersecurity incidents in 2024, fitting SI per Rule 5 for backward-looking materiality assessments, with the first sentence as generic commitment language. No domain terms, firm-specific facts, or verifiable claims present anywhere, resulting in Generic Boilerplate specificity.


reasoning: Paragraph asserts no past cybersecurity incidents or material impacts on operations/financial condition, directly matching SI materiality rule for negative assertions; contains no domain terms passing ERM test, firm-specific details, or verifiable facts like dates/numbers, resulting in Generic Boilerplate.


reasoning: This paragraph provides a general commitment to cybersecurity, references Item 1A risk factors, and speculates on potential impacts without describing any substantive processes, oversight, or incidents, making it None/Other per rules on speculation and cross-references. No domain terminology passing ERM test, firm-specific facts, or verifiable claims are present, resulting in Generic Boilerplate.


reasoning: This paragraph consists entirely of hypothetical, forward-looking speculation about potential cybersecurity risks and impacts, matching None/Other for pure disclaimers without substantive cybersecurity disclosure (Rule 5, Rule 6). No specific facts of any level are present anywhere in the text, resulting in Generic Boilerplate specificity.


reasoning: Paragraph primarily addresses potential material impacts of cybersecurity and asserts no incidents occurred as of a specific date, directly answering how cybersecurity affects business outcomes (SI per Rule 5 negative assertion). No domain terms, firm-specific facts, or verifiable claims present; negative incident assertion with date is not externally verifiable per guidelines.


fact: firewalls

fact: intrusion prevention and detection systems

fact: anti-malware functionality

fact: access controls

reasoning: Paragraph describes specific technical safeguards and tools deployed in the cybersecurity program (firewalls, IPS/IDS, anti-malware, access controls) and use of third-party assessors for internal evaluations, primarily answering 'What does the cybersecurity program do?' per RMP; third-party use is inbound services, not vendor risk management (Rule 3). Specificity driven by multiple cybersecurity domain terms passing ERM test (specific tools not usable in generic ERM contexts), reaching Domain-Adapted with no firm-specific or verifiable facts.


reasoning: Paragraph primarily describes board oversight through periodic updates on cybersecurity effectiveness, framework, and material incidents, with IT department responsibility as subordinate; fits BG per governance-chain default and Rule 1. No domain terms passing ERM test, no firm-specific roles/committees/teams, and no verifiable facts like numbers/dates/names, resulting in Generic Boilerplate specificity.


reasoning: Paragraph is a cross-reference to Item 1A Risk Factors, which rules classify as None/Other with no substantive cybersecurity disclosure. No specific facts, domain terms, or verifiable claims present anywhere, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes the integration of the cybersecurity program into the enterprise risk management program, including shared methodologies and processes, directly answering the Risk Management Process question on ERM integration. No domain-specific terminology, firm-specific facts, or verifiable claims are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph primarily recites generic cybersecurity risks, speculative impacts ('could have a material adverse effect'), and high-level measures without describing governance, management, processes, or incidents, fitting None/Other as pure speculation per rules. No domain terms passing ERM test, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


reasoning: Paragraph primarily assesses cybersecurity's lack of material impact on business strategy, operations, or finances (backward- and forward-looking per Rule 5), fitting Strategy Integration over generic risk discussion or RMP boilerplate. No domain terms passing ERM test, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


fact: recurring threat intelligence

fact: tactics, techniques, and procedures being utilized by threat actors

fact: phishing exercises

fact: monitoring and detection of our cybersecurity environment

fact: cybersecurity incident response plan ("CIRP")

reasoning: Paragraph describes cybersecurity program activities including threat intelligence, training/phishing, third-party monitoring, vendor assessments, and incident response planning, primarily answering 'What does the cybersecurity program do?' (RMP), with third-party elements as subordinate. Specificity reaches Firm-Specific due to named internal program 'CIRP'; includes multiple domain terms like TTPs and phishing exercises but no verifiable facts.


fact: NIST

fact: ISO

fact: confidentiality, integrity, and availability

reasoning: Paragraph primarily describes the cybersecurity program's frameworks (NIST, ISO), risk assessment methodology (annual assessments), and risk management approach (company-wide, CIA triad), directly answering 'What does the cybersecurity program do?' → Risk Management Process. Specificity at Domain-Adapted due to domain terms NIST, ISO, and CIA triad that demonstrate cybersecurity expertise beyond generic ERM language.


reasoning: This paragraph consists of forward-looking disclaimers about potential cyberattacks and a cross-reference to risk factors, which matches None/Other per Rule 5 and Rule 6 as pure speculation without substantive cybersecurity disclosure. No domain terms passing the ERM test, firm-specific facts, or verifiable claims are present anywhere in the text, resulting in Generic Boilerplate specificity.


fact: SVP, Engineering

fact: VP, Technology & CISO

reasoning: This paragraph details specific senior management roles (SVP Engineering and VP Technology & CISO) responsible for cybersecurity risk assessment, management, and supervision, directly answering the Management Role question per Rule 1 and Rule 2 person-removal test. Specificity reaches Firm-Specific due to named VP-level cybersecurity leadership roles, with no higher verifiable facts like quantifications or certifications.


fact: interrupted manufacturing at our domestic plants

fact: delayed order fulfillment for our retail network

fact: delay of some wholesale shipments

fact: core operating systems for manufacturing, wholesale and retail order processing and fulfillment, or financial reporting

reasoning: Paragraph details the nature, scope, timing ('within a few days'), operational impacts, remediation, and investigation results of a specific cybersecurity incident, directly answering 'What happened?'; firm-specific operational details (domestic plants, retail network, wholesale) distinguish this company's incident, elevating to Firm-Specific without domain terms or verifiable claims like dates/numbers.


fact: During 2024, the Company engaged a third-party technology firm to conduct an annual cyber risk assessment

fact: In early 2025, the Company engaged an independent cyber security firm to conduct a more comprehensive assessment

reasoning: Paragraph describes engaging external firms for cyber risk assessments and resulting network upgrades, directly answering 'What does the cybersecurity program do?' (RMP via external assessors per Rule 3); specificity driven by specific temporal facts ('2024' and 'early 2025') qualifying as verifiable dates for Level 4.


reasoning: The paragraph centers on managing cybersecurity risks from third-party service providers, including onboarding, monitoring, and limitations in oversight, directly answering the Third-Party Risk question as the central topic per Rule 3. No domain terminology passing the ERM test, firm-specific facts, or verifiable claims are present anywhere in the text, yielding Generic Boilerplate specificity.


reasoning: Paragraph primarily describes board oversight of cybersecurity risks and management's role in the governance chain, fitting Board Governance per Rule 1; the brief negative incident assertion is secondary and outweighed by oversight structure text. No domain terms passing ERM test, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate specificity.


fact: CIO (Chief Information Officer)

reasoning: Paragraph primarily describes management roles (CIO coordinating with CEO/CFO/GC, CIO's team deployment, management monitoring/reporting), answering 'How is management organized?' per MR definition and person-centric focus; defaults to MR over RMP as person-removal leaves thin program description. Specificity driven by firm-specific named role 'CIO' (VP+/IT leadership), elevating to Firm-Specific with no higher verifiable facts.


reasoning: Paragraph describes outsourcing IT and cybersecurity operations (protection, detection, response) to a third-party as part of their program, answering 'What does the cybersecurity program do?' (RMP, not TPR since it's using a third-party for internal ops, not managing vendor risks). No domain terms passing ERM test, firm-specific facts, or verifiable claims found anywhere, so Generic Boilerplate.


reasoning: This paragraph primarily describes board awareness and delegation of cybersecurity oversight to the Audit Committee, directly answering the Board Governance question. It contains no domain terminology passing the ERM test, no firm-specific facts like unique roles or committees, and no verifiable claims, warranting Generic Boilerplate specificity.


reasoning: This paragraph contains forward-looking speculation about potential cybersecurity incidents and lack of insurance, which is generic boilerplate without substantive disclosure on any core category question, per Rule 5 and Rule 6. No domain terms, firm-specific facts, or verifiable claims anywhere in the text, confirming Generic Boilerplate specificity.


reasoning: Paragraph describes general IT services (vCIO, operational review, IT policy) from an MSP without any cybersecurity-specific content, processes, or measures, failing Rule 6's threshold for substantive cybersecurity disclosure → None/Other. No domain terms, firm-specific facts, or verifiable claims anywhere → empty specific_facts and Generic Boilerplate specificity.


fact: receives reports from the World Gold Council

reasoning: Paragraph describes board oversight via reports on service provider due diligence, risks, incidents, and cybersecurity programs, directly answering 'How does the board oversee cybersecurity?'; named 'World Gold Council' as report source is a verifiable named firm fact elevating to Quantified-Verifiable.


reasoning: The paragraph primarily states conclusions about no material past or anticipated cybersecurity impacts on the business (backward- and forward-looking assertions per SI materiality rule), with secondary mentions of enhancements and tabletop exercises; cross-reference and vigilance statements are ancillary. No domain terms passing ERM test (tabletop exercises are generic even with cyber qualifier), no firm-specific facts (no roles/committees), and no verifiable claims (negative assertions and vague 'prior incidents' not independently checkable), yielding empty specific_facts for Generic Boilerplate.


reasoning: This is a cross-reference to Item 1A Risk Factors discussing potential financial impacts, which per Rule 5 and N/O threshold is None/Other as it provides no substantive cybersecurity disclosure. No domain terms, firm-specific facts, or verifiable claims anywhere in the paragraph, confirming Generic Boilerplate specificity.


fact: Vice President of IT and Digital

fact: CISO

reasoning: Paragraph primarily describes how specific management roles (VP of IT and Digital, CISO) acquire cybersecurity knowledge, answering 'How is management organized/qualified to handle cybersecurity?' per MR definition and person-removal test (collapses without roles). Specificity driven by firm-specific named roles at VP/CISO level elevating to Firm-Specific; no domain terms pass ERM test, no verifiable claims.


reasoning: This paragraph lists components of the cybersecurity program (risk assessments, security team activities, external providers, training, IR plan, third-party process), primarily answering 'What does the cybersecurity program do?' making it Risk Management Process; third-party mention is minor, not central. No domain terms passing ERM test (all generic processes like risk assessments, IR plans), no firm-specific elements (unnamed security team), and no verifiable facts (no numbers, dates, names), so Generic Boilerplate.


reasoning: Paragraph primarily describes cybersecurity program activities including incident response planning, risk management processes, and employee training (prevention, mitigation, detection, remediation; annual training; ongoing awareness), answering 'What does the cybersecurity program do?'; person-removal test confirms RMP as substantive program description remains. No domain terms passing ERM test (e.g., 'incident response plan' is generic L1), no firm-specific roles/committees, no verifiable facts like numbers/dates/names, so Generic Boilerplate.


reasoning: Paragraph describes board oversight of cybersecurity risks, including updates from specific officers on the program and threats, directly answering the Board Governance question about oversight structure and information flow. No domain terminology passing ERM test, no firm-specific roles beyond generic CFO/CCO, and no verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: This paragraph primarily describes the audit committee's oversight of cybersecurity risks, management's periodic presentations to the committee, and updates to the board when material, fitting Board Governance as it details the oversight structure and information flow. No domain-specific terminology, firm-specific facts (e.g., Audit Committee is generic), or verifiable claims are present, warranting Generic Boilerplate specificity.


fact: penetration testing firms

fact: threat intelligence service providers

fact: encryption and authentication technology

reasoning: The paragraph primarily describes third-party providers utilized by the company for security-related services and to assist in identifying, assessing, and managing cybersecurity risks (e.g., penetration testing firms, threat intelligence), fitting Risk Management Process as these are components of the internal program rather than oversight of vendor risks (Rule 3). Specificity is Domain-Adapted due to cybersecurity-specific terms like 'penetration testing' and 'threat intelligence' that demonstrate domain expertise via the ERM test, with no firm-specific roles/committees or verifiable claims like numbers or named firms.


reasoning: Paragraph describes board oversight of cybersecurity risks through periodic briefings on risk management processes and delineates board vs. executive officer responsibilities, directly answering 'How does the board oversee cybersecurity?' with no substantive program details. No domain terms, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate specificity.


fact: 21 CFR 11 (Part 11) compliant

reasoning: Paragraph centers on managing cybersecurity risks from CRO vendors through oversight, reviews, and reporting requirements, directly answering the Third-Party Risk question. Specificity reaches Domain-Adapted via the domain-specific term '21 CFR 11 (Part 11) compliant,' demonstrating regulatory expertise in data integrity controls; no firm-specific roles or verifiable quantities present.


fact: SOC reports

reasoning: The paragraph centrally describes oversight of third-party providers through security assessments, ongoing monitoring, and annual SOC report reviews, directly answering the Third-Party Risk question with most text dedicated to it over the minor trailing materiality statement (SI). Specificity driven by domain term 'SOC reports' (passes ERM test as cybersecurity-specific audit evidence), no firm-specific roles/committees or verifiable claims like numbers/dates.


reasoning: Paragraph describes board oversight of cybersecurity investments, compliance, and legal counsel, with management involvement, fitting Board Governance as it details the governance-chain oversight structure (Rule 1). No domain terms passing ERM test, firm-specific facts (e.g., no named roles/committees), or verifiable claims (no numbers, dates, named entities), resulting in Generic Boilerplate specificity.


reasoning: Paragraph primarily assesses cybersecurity's lack of material impact on business strategy, results, or financial condition in FY 2023 (backward- and forward-looking), fitting Strategy Integration per materiality rule; no domain terms, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily addresses the lack of material impact from cybersecurity risks or incidents on business strategy, operations, or finances, and mentions partial insurance coverage, directly matching Strategy Integration per Rule 5 (backward- and forward-looking materiality assertions). No domain terms passing the ERM test, firm-specific details, or verifiable facts are present anywhere, resulting in Generic Boilerplate specificity.


reasoning: Paragraph states no formal cybersecurity programs or processes exist yet for an exploration-stage company with no customer data, providing no substantive disclosure on oversight, roles, processes, or incidents, thus None/Other per Rule 6 for no-operations companies; no domain terms, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate.


reasoning: The paragraph primarily states a conclusion about past lack of material impact from cybersecurity threats and speculates on future risks, directly matching Strategy Integration per Rule 5 (backward-looking materiality assessment); no substantive cybersecurity measures or processes are described. No domain terms, firm-specific facts, or verifiable claims are present anywhere, resulting in Generic Boilerplate specificity.


reasoning: Paragraph primarily asserts no material past incidents or expenses (SI negative assertion) and discusses potential future financial impacts and resource expenditures, directly answering how cybersecurity affects business/finances; no specific facts, domain terms, roles, or verifiable claims present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily states conclusions about no material past impact from cybersecurity risks and potential future effects on business strategy, operations, and finances, directly matching Strategy Integration per Rule 5 (backward- and forward-looking materiality assessments). No domain terms passing ERM test, firm-specific facts, or verifiable claims (e.g., no specific dates, numbers, roles, or tools) anywhere, so Generic Boilerplate.


fact: confidentiality, integrity, or availability

fact: protected health information

reasoning: Paragraph centrally describes a vendor qualification and management program to mitigate cybersecurity risks from third-party service providers handling sensitive data, directly answering third-party risk management (TP per Rule 3). Domain terms like CIA triad and 'protected health information' (HIPAA) demonstrate cybersecurity expertise (Level 2), with no firm-specific roles/committees or verifiable claims (no Level 3/4).


reasoning: This paragraph is generic boilerplate acknowledging the general importance of cybersecurity measures and the CIA triad without addressing any specific question about governance, roles, processes, incidents, or strategy, defaulting to None/Other. No domain-adapted terminology beyond basic concepts, no firm-specific details, and no verifiable facts, yielding Generic Boilerplate specificity.


reasoning: The paragraph primarily describes engaging third-party service providers for cybersecurity tasks and imposing specific requirements on them (certification of security measures, breach reporting), directly answering how third-party cyber risks are managed (TP per Rule 3). No domain-specific terminology, firm-unique facts, or verifiable claims are present anywhere, resulting in Generic Boilerplate specificity.


reasoning: Paragraph describes board-level oversight of cybersecurity risks via delegation to the Audit Committee, directly answering the Board Governance question per Rule 1 (board/committee oversight structure). No domain terms, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate specificity.


fact: threat intelligence feeds

fact: vulnerability management

reasoning: Paragraph describes cybersecurity program activities including incident response planning, threat monitoring, vulnerability management, and training/simulations, directly answering 'What does the cybersecurity program do?' (RMP). Specificity reaches Domain-Adapted due to domain terms like 'threat intelligence feeds' and 'vulnerability management' that demonstrate cybersecurity expertise beyond generic ERM language, with no firm-specific roles or verifiable facts.


reasoning: Paragraph asserts no material past cybersecurity impacts on operations or finances, fitting Strategy Integration per Rule 5's materiality assessment for backward-looking negative statements, with cross-reference as secondary. No domain terms passing ERM test, firm-specific facts, or verifiable claims (negative assertion not QV), yielding empty specific_facts and Generic Boilerplate.


reasoning: This paragraph is promotional boilerplate summarizing a 'strategic approach to cybersecurity governance' without answering any core question substantively (no board oversight, management roles, processes, or incidents detailed); it vaguely references generic elements like third-party assessments and certifications that do not qualify as domain-specific under the ERM test. No specific facts elevate specificity beyond Level 1, resulting in an empty specific_facts list.


reasoning: Paragraph primarily describes using third-party consultants to assist with internal risk assessment, policy design/implementation, and safeguard monitoring/testing, answering 'What does the cybersecurity program do?' (RMP); future vendor certification requirements are secondary. No domain terms, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph states a conclusion about no material cybersecurity incidents affecting business (negative assertion), fitting Strategy Integration per materiality rule; cross-reference is secondary. No domain terms passing ERM test, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph primarily states conclusions about no material past cybersecurity incidents or costs and potential future impacts on business/financials, fitting Strategy Integration per Rule 5 (backward- and forward-looking materiality assessments); cross-reference is secondary. No domain terms, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph primarily describes the CEO's leadership responsibilities in cybersecurity risk management, oversight of processes, incident monitoring, and reporting to the Board, directly answering 'How is management organized to handle cybersecurity?' (MR per Rule 1 and person-removal test shows role focus). No domain terms passing ERM test, no firm-specific facts beyond generic CEO role, and no verifiable claims, resulting in Generic Boilerplate specificity.


fact: ransomware

fact: denial-of-service

reasoning: This paragraph discusses general cybersecurity threats and hypothetical material impacts without detailing oversight, processes, roles, or incidents, classifying as None/Other per speculation rule. It includes domain-specific threat types (ransomware, denial-of-service) that pass the ERM test, setting specificity to Domain-Adapted.


reasoning: Paragraph primarily states conclusions about no material past or likely future cybersecurity impacts on business strategy, results, or financial condition, directly matching SI materiality rule (backward- and forward-looking assertions). No specific facts of any level found: negative self-assertion unverifiable, vague 'from time-to-time' threats, and cross-reference lack domain terms, firm-specific details, or verifiable claims.


reasoning: The paragraph states conclusions about no material cybersecurity incidents, expenses, penalties, or settlements over the last three years, directly matching Strategy Integration's negative assertion examples in Rule 5. No domain terms, firm-specific details, or verifiable claims are present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph centrally describes management of third-party cyber risks through due diligence, contractual security controls, data restrictions, and incident notification requirements, directly matching Third-Party Risk. Lacks domain terminology passing ERM test (all generic vendor risk language), firm-specific elements, or verifiable facts, resulting in Generic Boilerplate.


reasoning: The paragraph primarily states conclusions about whether cybersecurity risks have materially affected or are reasonably likely to affect the business, strategy, results of operations, or financial condition, directly matching Strategy Integration per the materiality rule (backward- and forward-looking assessments). No domain terminology passing the ERM test, firm-specific facts, or verifiable claims are present anywhere, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily states a conclusion on cybersecurity's lack of material impact on business outcomes ('no known risks ... reasonably likely to materially affect'), fitting Strategy Integration per Rule 5, despite an opening generic Management Role reference; the cross-reference is None/Other but secondary. No domain terms, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


fact: SMIS

fact: Cybersecurity Committee

reasoning: Paragraph primarily describes board and committee oversight of cybersecurity risks, threats, program status, and incident reporting flows, directly answering 'How does the board oversee cybersecurity?' (BG). Firm-specific facts like SMIS and Cybersecurity Committee elevate specificity to Firm-Specific; no domain terms or verifiable claims present.


reasoning: Paragraph states no material cybersecurity impacts occurred in FY2024 (negative assertion) and notes potential future material effects, directly matching Strategy Integration materiality rule for conclusions on business outcomes; contains no domain terminology passing ERM test, firm-specific facts, or verifiable claims like dates/numbers tied to cybersecurity events.


fact: dedicated CISO

fact: CISO has more than 20 years of experience

fact: RACC

fact: CRO

fact: cyber defense

reasoning: The paragraph primarily answers 'What does the cybersecurity program do?' by detailing its management of strategy/policy/standards/architecture/processes, incident response escalation procedures, evaluations by experts, and engagements with vendors/industry; person-removal test leaves substantial program descriptions confirming RMP over MR. Specificity reaches Quantified-Verifiable due to the CISO's >20 years experience (verifiable quantified claim) alongside firm-specific elements like CISO, CRO, and RACC.


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


fact: Cybersecurity Governance Board

reasoning: The paragraph primarily answers whether cybersecurity has materially affected or is likely to affect business outcomes with a direct negative assertion, classifying as Strategy Integration per Rule 5, despite a brief board oversight mention suggesting Board Governance. Specificity is Firm-Specific due to the named 'Cybersecurity Governance Board' committee, with no higher verifiable facts.


fact: penetration testing

fact: ISAT

reasoning: Paragraph describes third-party assistance in assessing, testing, and monitoring the cybersecurity program, including specific activities like penetration testing, making it primarily about Risk Management Process (third parties hired to serve the company per Rule 3). Specificity reaches Firm-Specific due to the named internal team 'ISAT' distinguishing the company's structure, plus domain term 'penetration testing'.


reasoning: This paragraph primarily assesses the past and potential future material impact of cybersecurity risks on business strategy, results of operations, and financial condition, directly matching Strategy Integration per Rule 5 (backward- and forward-looking materiality conclusions). No domain terminology passing the ERM test, firm-specific facts, or verifiable claims (e.g., date is filing context, negative assertions not externally verifiable) are present, yielding Generic Boilerplate specificity.


reasoning: Paragraph primarily states conclusions about no material past or reasonably likely future cybersecurity impacts on business strategy, results, or financial condition, directly matching Strategy Integration per Rule 5 (backward- and forward-looking materiality assessments). No specific facts, domain terms, firm-specific details, or verifiable claims present anywhere, resulting in Generic Boilerplate specificity.


fact: SOC reports

reasoning: Paragraph primarily describes vendor oversight processes like pre-engagement security assessments, ongoing monitoring, and annual SOC report reviews, making Third-Party Risk the central topic with most text despite a minor SI concluding sentence. Specificity at Domain-Adapted due to 'SOC reports' as a domain term passing the ERM test; no firm-specific roles or verifiable claims present.


reasoning: Paragraph primarily states a backward-looking materiality conclusion that no cybersecurity incidents have materially affected business or finances (Rule 5 → SI), with secondary speculation and cross-reference not overriding. No domain terms, firm-specific facts, or verifiable claims present anywhere, resulting in Generic Boilerplate specificity.


reasoning: Paragraph primarily states that cybersecurity risks have not materially affected business outcomes to date, directly matching Strategy Integration's materiality assessment rule for backward-looking conclusions; no specific facts elevate specificity beyond Generic Boilerplate as it contains only vague references to threats/incidents without domain terms, firm-unique details, or verifiable claims.


reasoning: Paragraph primarily describes the cybersecurity program's activities including risk assessment, monitoring vulnerabilities, testing systems, use of security tools for incident handling, integration into ERM, board oversight as part of it, third-party collaboration for internal assessments (RMP per Rule 3), and TPRM process, making RMP the dominant category over BG/TP/SI elements; no domain terms pass ERM test (all generic processes any ERM pro could describe), no firm-specific roles/committees/teams, no verifiable facts like numbers/dates/names, so empty specific_facts yields Generic Boilerplate.


fact: Chief Technology Officer

fact: over 15 years of experience in software development and security architecture

fact: security architecture

reasoning: Paragraph primarily describes the CTO's leadership role, responsibilities, qualifications, and reporting lines in cybersecurity, fitting Management Role per person-removal test where roles dominate over process activities. Specificity reaches Quantified-Verifiable due to the verifiable 'over 15 years of experience' claim and firm-specific CTO role, with domain term 'security architecture' also present.


fact: CGNC's oversight

reasoning: Paragraph describes senior management's responsibilities for day-to-day cybersecurity operations, reporting lines for material events, and review for SEC filings, directly answering 'How is management organized to handle cybersecurity?' (MR per Rule 1 and person-removal test showing role focus). Specificity reaches Firm-Specific due to named committee 'CGNC' distinguishing governance structure; no domain terms, quantifiables, or verifiable claims elevate further.


reasoning: Paragraph describes the oversight structure with senior management (CEO/CFO) briefing the Audit Committee, which reports to the Board, answering 'How does the board oversee cybersecurity?' (BG per governance-chain rule); no domain terms, firm-specific facts, or verifiable claims found anywhere, resulting in Generic Boilerplate specificity.


reasoning: Paragraph describes third-party service providers assisting with risk assessments, procedure design/implementation, monitoring/testing (internal program activities → RMP per Rule 3, as these are hired to serve the company, not vendor risks managed); requirements on them are subordinate to program description. No domain terms, firm-specific facts, or verifiable claims anywhere → Generic Boilerplate.


reasoning: Paragraph provides backward- and forward-looking materiality assessments on cybersecurity's impact to business strategy, operations, and financial condition, fitting Strategy Integration per Rule 5. No domain terms, firm-specific details, or verifiable facts (2024 negative assertion not externally verifiable); empty specific_facts confirms Generic Boilerplate.


fact: CISO

fact: CDO

fact: more than 20 years of executive IT leadership experience

fact: joining MPC in 2021

fact: employed by GE and its subsidiary companies for over 20 years

fact: quantified

fact: named Senior Vice President and Chief Information Officer of Services for parent company GE in 2017

fact: Vice President and Chief Information Officer of GE Healthcare

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

reasoning: This paragraph details the CDO's role, reporting structure with CISO, qualifications, career history at GE with specific titles and timelines, directly answering 'How is management organized?' (MR per Rule 1 and person-specific test). Multiple quantified facts (20+ years experience), specific dates (2021, 2017), named firms (GE, GE Healthcare), and named roles (CISO, CDO) drive Quantified-Verifiable specificity.


fact: Chief Information Security Officer (CISO)

fact: over 30 years of experience in cybersecurity

fact: Security Officer while in the United States Navy

fact: CISO at Amgen and Warner Bros

fact: Cybersecurity roles at KPMG and Forrester

reasoning: This paragraph primarily describes the CISO's leadership role, responsibilities, qualifications, and career history, fitting Management Role per Rule 1 and Rule 2 (person-removal test leaves role-focused content). Specificity reaches Quantified-Verifiable due to hard facts like 'over 30 years of experience' (lower-bound verifiable) and named past employers/roles (externally checkable via public records or LinkedIn).


fact: Deutsche Bank's Chief Security Officer

fact: more than 20 years in information security

fact: global Chief Information Security Officer (CISO)/CSO for three different large European financial institutions

fact: partner position in a global strategy and consulting firm, leading security work for financial service clients

reasoning: This paragraph details the Chief Security Officer's extensive qualifications, career history, and supporting team structure, directly answering 'How is management organized to handle cybersecurity?' (Management Role); person-removal test confirms no remaining program description. Specificity hits Quantified-Verifiable due to the verifiable 'more than 20 years' experience and specific named roles.


reasoning: Paragraph speculates on past and future cybersecurity incidents without details and cross-references to Risk Factors, fitting None/Other as pure speculation and non-substantive disclosure. No domain terms, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate specificity.


fact: in June 2018, we identified forged and fraudulently induced electronic payment disbursements we made to third parties in an aggregate amount of $10 million resulting from unauthorized third-party access to our email system

fact: $10 million

fact: ransomware and other forms of malware and computer virus attacks, unauthorized access, systems failures and temporary disruptions

reasoning: The paragraph primarily describes actual past cybersecurity incidents, including a specific June 2018 event with details on nature, timing, and scope, making it Incident Disclosure despite mentions of non-material impact (Rule 4: incident frame dominant). Specificity reaches Quantified-Verifiable due to the verifiable specific date (June 2018) and quantified amount ($10 million) tied to the real event, alongside domain terms like ransomware.


fact: ransomware attack

reasoning: This paragraph details a real ransomware attack including its nature, specific dates of occurrence (April 28, 2023) and resolution (May 1, 2023), and remediation, primarily answering 'What happened in a cybersecurity incident?' for Incident Disclosure. Specificity is Quantified-Verifiable due to the verifiable specific dates and domain term 'ransomware attack'.


fact: Clarium Managed Services, LLC conducted a Cybersecurity Assessment in 2022

fact: assessment resulted in a score of 4.8 on a scale of 0 to 5

reasoning: The paragraph primarily answers whether cybersecurity incidents or threats have materially affected or are likely to affect business strategy, results of operations, or financial condition, with explicit negative materiality assertions fitting Strategy Integration per Rule 5. Specificity reaches Quantified-Verifiable due to the named third-party firm (Clarium), specific year (2022), and quantified score (4.8/5), all externally verifiable facts.


reasoning: The paragraph primarily states a backward-looking materiality conclusion ('did not experience a material cybersecurity incident') fitting Strategy Integration per Rule 5's negative assertion example, with the rest being a cross-reference to Item 1A (N/O but secondary). No domain terms passing ERM test, firm-specific facts, or verifiable claims (negative assertion not externally verifiable per rules), so empty specific_facts and Generic Boilerplate.


reasoning: This paragraph centers on managing cybersecurity risks from third-party service providers via inclusion in risk programs, contractual requirements, and audits, directly answering the Third-Party Risk question as the central topic per Rule 3. No domain terminology passing the ERM test, firm-specific elements like named roles or committees, or verifiable facts like numbers/dates are present, yielding Generic Boilerplate specificity.


reasoning: This is a cross-reference to Item 1A risk factors with no substantive cybersecurity disclosure, qualifying as None/Other per rules on cross-references. No domain terms, firm-specific facts, or verifiable claims anywhere in the paragraph, confirming Generic Boilerplate specificity.


fact: became aware in January 2021 that certain of our information technology systems hosted by a third-party cloud provider were improperly accessed

fact: certain of our source code and the credentials used to access the information technology systems themselves had been compromised

fact: received a threat to publicly release these materials unless we made a payment, which we have not done

reasoning: This paragraph primarily describes a specific past cybersecurity incident including timing (January 2021), nature (improper access to IT systems, source code and credentials compromised), threat received, and response (no payment made), fitting Incident Disclosure as the dominant frame despite some impact speculation. Specificity reaches Quantified-Verifiable due to the verifiable specific date and event details from a previously disclosed real incident.


reasoning: Paragraph primarily states conclusions about no material past impacts from cybersecurity incidents and forward-looking materiality risks, directly matching SI per Rule 5 (backward- and forward-looking assessments); no specific incident details exclude ID. No domain terms, firm-specific facts, or verifiable claims anywhere, resulting in Generic Boilerplate specificity.


reasoning: The paragraph primarily describes the company's framework and processes for assessing and monitoring cybersecurity risks from third-party service providers, including onboarding, ongoing monitoring, and evaluations of controls and policies, directly answering 'How are third-party cyber risks managed?' and fitting Third-Party Risk as the central topic per Rule 3. It contains no domain-specific terminology passing the ERM test (e.g., no named standards, tools, or practices like SOC 2 or penetration testing), no firm-specific elements like named roles or committees, and no verifiable facts like quantities or dates, resulting in Generic Boilerplate specificity.


reasoning: Paragraph is a cross-reference to Item 1A risk factors with no substantive cybersecurity disclosure, fitting None/Other. No specific facts, domain terms, or verifiable claims present, resulting in Generic Boilerplate.


reasoning: Paragraph provides materiality assessments on past and potential cybersecurity impacts to business strategy, financial condition, and operations, directly answering Strategy Integration per Rule 5 (backward- and forward-looking conclusions); contains no domain terminology passing ERM test, firm-specific details, or verifiable facts like numbers/dates/names, resulting in empty specific_facts and Generic Boilerplate specificity.


fact: service provider oversight committee

fact: Security assessments of those service providers may include questionnaires, meetings and onsite visits

reasoning: Paragraph centrally describes oversight of third-party service providers, including a dedicated committee, policies, due diligence, monitoring, and security assessments, directly answering the Third-Party Risk question. Specificity reaches Firm-Specific due to the named 'service provider oversight committee'; domain terms like detailed security assessment methods (questionnaires, meetings, onsite visits) support but do not exceed Level 3.


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

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

fact: Energy Transfer IT team

fact: over 50 years of combined experience in IT

fact: 20 years dedicated to cybersecurity

fact: hold GICSP, CISSP, and CEH certifications

fact: USAC's IT department leads internal cybersecurity program

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

fact: over 10 years of experience in IT security

reasoning: Paragraph primarily describes management leadership roles (CIO, IT teams), their responsibilities, qualifications, and experience, fitting Management Role per person-specific focus on organization and credentials (MR vs RMP person-removal test). Specificity reaches Quantified-Verifiable due to multiple hard numbers (e.g., 'more than 35 years', 'over 50 years combined', specific certifications like CISSP) and verifiable claims throughout.


reasoning: Paragraph describes board-level oversight and delegation to the audit committee for cybersecurity risks, directly answering 'How does the board oversee cybersecurity?' with no substantive program details, fitting Board Governance per governance-chain rule. No domain terms passing ERM test, firm-specific facts (audit committee is generic), or verifiable claims, resulting in Generic Boilerplate specificity.


fact: CISO

fact: Risk and Compliance Committee

reasoning: Paragraph describes oversight structure and information flow from CISO to Risk and Compliance Committee to Board, with briefing frequencies, directly answering 'How does the board oversee cybersecurity?' (BG per governance-chain rule). Specificity reaches Firm-Specific due to named CISO role and named non-generic Risk and Compliance Committee, with no higher verifiable facts.


fact: threat modeling

fact: vulnerability testing

fact: information security maturity assessments

reasoning: Paragraph details the cybersecurity program's assessment and testing activities, including specific practices like threat modeling and vulnerability testing, directly answering 'What does the cybersecurity program do?' (RMP); third-party assessors are internal program tools, not vendor risk management (Rule 3). Specificity reaches Domain-Adapted due to cybersecurity-specific terms passing the ERM test (threat modeling, vulnerability testing), with no firm-specific roles or verifiable claims.


fact: cybersecurity infrastructure

fact: deployed cybersecurity products and services

fact: continuous monitoring of our cybersecurity environment

fact: investigation and remediation of events

fact: security controls

reasoning: The paragraph primarily describes cybersecurity program activities such as partnering with third parties for technology, monitoring, risk assessment, remediation, and supplier security reviews, answering 'What does the cybersecurity program do?' (RMP over TP as vendor oversight is not central). Specificity is Domain-Adapted due to multiple domain terms like 'continuous monitoring' and 'cybersecurity infrastructure' that pass the ERM test, with no firm-specific or verifiable facts.


reasoning: This is a cross-reference to Item 1A Risk Factors with no substantive cybersecurity disclosure, fitting None/Other per category rules for cross-references. No specific facts of any level are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph is a cross-reference to risk factor disclosures in Item 1A, with no substantive cybersecurity content, fitting None/Other per Rule 5 and 6. No specific facts of any level are present, confirming Generic Boilerplate specificity.


fact: BNY Mellon

reasoning: Paragraph centrally describes BNY Mellon's framework for managing cybersecurity risks from third-party service providers, including risk evaluation, protocols, contractual obligations, and controls, directly answering 'How are third-party cyber risks managed?' (TP per Rule 3). Specificity reaches Quantified-Verifiable due to the named firm 'BNY Mellon', a verifiable third-party service provider.


fact: regular scanning of both internal and externally facing systems

fact: annual third-party penetration testing

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

reasoning: The paragraph lists specific cybersecurity program activities like vulnerability scanning, penetration testing, log monitoring, and vendor due diligence, directly answering 'What does the cybersecurity program do?' making it Risk Management Process (vendor due diligence is subordinate, not central). Specificity is Domain-Adapted due to domain terms like penetration testing, system scanning, and network log monitoring that demonstrate cybersecurity expertise beyond generic ERM language, with no firm-specific roles or verifiable quantities.


fact: Chief Information Security Officer

fact: vulnerability assessments

reasoning: Paragraph primarily describes Audit Committee and Board oversight of cybersecurity risks, including briefing frequency, content scope, and discussions with CISO, answering 'How does the board oversee cybersecurity?' → Board Governance per governance-chain default. Specificity reaches Firm-Specific due to named CISO role (Level 3), with supporting domain term 'vulnerability assessments' (Level 2).


reasoning: Paragraph primarily describes CEO and executive management's responsibilities for day-to-day cybersecurity oversight, reporting to the Board, and incident response, answering 'How is management organized to handle cybersecurity?' (MR per Rule 1 and Rule 2 person-removal test leaves little program detail); touches BG but management roles dominate. No domain terms passing ERM test, no firm-specific roles beyond generic CEO/exec team/Board, no verifiable facts, so empty specific_facts yields Generic Boilerplate.


fact: on October 15, 2025, we learned that a threat actor had gained unauthorized access

fact: notified law enforcement, including the Federal Bureau of Investigation (FBI)

fact: deployment of encryption and monitoring software by a third party

reasoning: Paragraph describes a real cybersecurity incident with timing, nature (unauthorized access, encryption/monitoring software), response (incident plan activation, FBI notification, external experts), and investigation details, directly answering 'What happened in a cybersecurity incident?' fitting Incident Disclosure. Specificity is Quantified-Verifiable due to the specific date (October 15, 2025) and named FBI, with supporting domain term on attacker tactics.


fact: monitor for and detect anomalous activity

fact: penetration tests

fact: backup and recovery systems and disaster recovery

reasoning: Paragraph details the cybersecurity program's activities including controls, monitoring, risk assessment via risk register, penetration testing, and recovery systems, directly answering 'What does the cybersecurity program do?' (RMP); domain terms like penetration tests and anomalous activity detection demonstrate cybersecurity expertise (Level 2), with no firm-specific roles or verifiable claims elevating higher.


fact: February 2023 ransomware attack

fact: ransomware attack

reasoning: This paragraph details a specific past cybersecurity incident including timing, nature (ransomware), scope (sensitive personal information of employees), and remediation actions, directly answering 'What happened in a cybersecurity incident?' The February 2023 date is a verifiable fact elevating specificity to Quantified-Verifiable, with ransomware as a domain term.


reasoning: This paragraph describes the Audit Committee's oversight of cybersecurity risks, including briefing frequency and review of the enterprise risk management matrix covering cybersecurity topics, directly answering the Board Governance question of how the board oversees cybersecurity. No domain-specific terminology, firm-specific facts (e.g., Audit Committee and Risk Committee are generic), or verifiable claims (e.g., cadences like 'at least once each calendar year' are not qualifying) are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph is solely a cross-reference to the risk factors section in Item 1A, matching the explicit None/Other example for cross-references with speculative language. It contains no cybersecurity measures, processes, or facts of any kind, warranting Generic Boilerplate specificity with an empty specific_facts list.


reasoning: This paragraph describes board and Audit Committee oversight of cybersecurity risks, including briefing frequency, directly answering the Board Governance question; Audit Committee is a board-level committee per Rule 1. No domain terms passing ERM test, no firm-specific facts (Audit Committee is generic), and no verifiable claims, resulting in Generic Boilerplate specificity.


fact: Information Security Steering Committee ("ISSC")

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

reasoning: This paragraph primarily describes the structure, membership, and oversight responsibilities of a management-level Information Security Steering Committee (ISSC), fitting Management Role per Rule 1 (management-level committee focus on organization). Specificity is Firm-Specific due to the named committee (ISSC) and specific department composition, with no domain terms or verifiable claims elevating higher.


fact: Vendor Management Policy

reasoning: Paragraph centrally describes vendor oversight processes, requirements, and risk-based controls imposed on third-party vendors, directly answering 'How are third-party cyber risks managed?' (TP). Specificity reaches Firm-Specific due to the named 'Vendor Management Policy,' a distinguishing internal program; no domain terms pass ERM test and no verifiable facts present.


reasoning: The paragraph describes cybersecurity insurance coverage for specific loss types, directly addressing how cybersecurity risks are financially mitigated (Strategy Integration). No domain terms passing the ERM test, firm-specific details, or verifiable facts like coverage amounts or named policies are present, resulting in Generic Boilerplate specificity.


fact: review of the vendor's Information security and related controls (third-party audit)

reasoning: Paragraph centrally describes vendor due diligence factors like reviewing information security controls via third-party audits, making Third-Party Risk the primary category over RMP per Rule 3 (requirements imposed on vendors). Specificity at Domain-Adapted due to the domain term 'third-party audit' for security controls passing the ERM test, with no firm-specific or verifiable facts.


fact: threat intelligence service providers

fact: penetration testing firms

fact: cybersecurity software providers

fact: managed cybersecurity service providers

reasoning: Paragraph describes the company's use of external service providers (e.g., penetration testing, threat intelligence) as part of its internal cybersecurity risk management processes, fitting RMP per Rule 3 (third parties hired to support the program, not vendor oversight). Specificity is Domain-Adapted due to multiple cyber-specific domain terms like 'penetration testing' and 'threat intelligence service providers' that pass the ERM test, with no firm-specific or verifiable facts.


fact: DISH TV, SLING TV and Retail Wireless services

fact: wireless and data networks

fact: As of March 31, 2023, all significant systems had been restored

reasoning: This paragraph describes the scope, impact (no service disruption), timeline (restoration as of March 31, 2023), and conclusion of a specific cybersecurity incident, directly answering 'What happened in a cybersecurity incident?' making it Incident Disclosure. Specificity reaches Quantified-Verifiable due to the verifiable specific date (March 31, 2023) and named firm-specific services/systems like DISH TV and SLING TV.


fact: Chief Information Security Officer

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

fact: holds master's and bachelor's degrees in both Computer Information Systems and Business Administration

fact: Certified Internal Controls Auditor (CICA)

fact: Payment Card Industry Professional (PCIP)

fact: Certified Information Systems Security Professional (CISSP)

fact: Certified Information Systems Auditor (CISA)

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

reasoning: Paragraph focuses on the CISO's role, responsibilities, experience, education, and certifications, directly answering 'How is management organized?' per Management Role (person-removal test confirms no remaining program description). Specificity reaches Quantified-Verifiable due to hard facts like '25 years' experience and named certifications (e.g., CISSP) that are externally verifiable.


reasoning: Paragraph mentions maintaining a cyber liability insurance policy, directly addressing cybersecurity's financial/strategy integration via insurance; cross-reference does not change primary category. No domain terms, firm-specific facts, or verifiable claims present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph states conclusions about no material cybersecurity risks or incidents affecting business outcomes, fitting Strategy Integration per materiality rule (backward-looking negative assertions). No domain terms, firm-specific facts, or verifiable claims present anywhere, confirming Generic Boilerplate.


reasoning: Paragraph asserts no past material cybersecurity impacts and forward-looking potential material effects, directly matching Strategy Integration materiality rule (backward- and forward-looking conclusions). No domain terms passing ERM test, no firm-specific cybersecurity elements (roles, committees, programs), and no verifiable claims like numbers/dates/certifications, so Generic Boilerplate.


reasoning: Paragraph asserts no material past or likely future cybersecurity impacts on business strategy, operations, or finances, directly matching Strategy Integration materiality rule (backward- and forward-looking); contains no domain terminology passing ERM test, firm-specific facts, or verifiable claims like numbers/dates/names, resulting in Generic Boilerplate.


reasoning: This paragraph describes how the Committee presents cybersecurity review results, updates on threats/incidents, and notifications to the Board, directly answering 'How does the board oversee cybersecurity?' with details on information flow and briefing scope, fitting Board Governance per governance-chain rules. No domain terms passing ERM test, firm-specific facts (e.g., unnamed 'Committee', generic cadences), or verifiable claims appear anywhere, resulting in Generic Boilerplate specificity.