9 unchanged sentences
• a compliance team principally responsible for managing our risk assessments, which are designed to help identify material cybersecurity risks to our critical systems and information;
−Removed: • the use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security controls;
+Added: • the use of external service providers, where appropriate, to assess, test or otherwise assist with aspects of our security processes;
• cybersecurity awareness training for our employees, incident response personnel, and senior management;
4 unchanged sentences
We face certain continuing and ongoing material risks from cybersecurity threats, which the SEC defines as any potential unauthorized occurrence on or conducted through our information systems that may result in adverse effects on the confidentiality, integrity, or availability of our information systems or any information residing therein.
−Removed: See "Risk Factors—Risks Relating to Cybersecurity or Data Privacy—A breach or other compromise of our security measures or those of third parties we rely on could result in unauthorized access to personal information about our clients’ customers and other individuals and other data, or disruptions to our systems or operations, which could materially and adversely impact our reputation, business, financial condition and results of operations." Otherwise, however, we have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition.
+Added: See "Risk Factors—Risks Relating to Cybersecurity or Data Privacy—A breach or other compromise of our security measures or those of third parties we rely on could materially and adversely impact our reputation, business, financial condition and results of operations.” Otherwise, however, we have not identified risks from known cybersecurity threats, including as a result of any prior cybersecurity incidents, that have materially affected or are reasonably likely to materially affect us, including our operations, business strategy, results of operations, or financial condition.
Cybersecurity Governance
6 unchanged sentences
Directors receive presentations on cybersecurity topics from our CISO as part of the board of directors’ continuing education.
−Removed: Our management team, including our CISO and CCO, is responsible for assessing and managing our material risks from cybersecurity threats.
−Removed: The team has primary responsibility for our overall cybersecurity risk management program and supervises both our internal cybersecurity personnel and our retained external cybersecurity consultants.
−Removed: Our CISO’s experience includes over 25 years of helping to build global cybersecurity programs in companies ranging from Fortune 50 to early stage entities.
+Added: Although our CISO resigned in January of 2025, we have elevated an internal candidate to the role of interim CISO while we search for a replacement.
+Added: As designed, our CISO and CCO are members of the management team and are primarily responsible for assessing and managing our
+Added: material risks from cybersecurity threats, as well as our overall cybersecurity risk management program.
+Added: As designed, our CISO is responsible for supervising both our internal cybersecurity personnel and our retained external cybersecurity consultants.
+Added: Our interim CISO’s experience includes over 20 years of helping to build global cybersecurity programs in various industries.
Our CCO, who is responsible for our technology risk management program, has over 25 years of experience building and leading risk management and compliance programs in large institutions across multiple geographies.
Our management team, led by our CISO and CCO , stays informed about and monitors efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include briefings from internal security personnel, threat intelligence and external consultants engaged by us, and alerts and reports produced by security tools deployed in the information technology environment.
+Added: Our principal executive offices are located in Plano, Texas.
+Added: The leased space in Plano, Texas has approximately 83,939 square feet with a remaining term until August 31, 2033.
+Added: We believe our current facilities will be adequate for our needs for the current term.
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.