NASAA Series 65 Syllabus — Topic Weights & Learning Objectives

Use this page as your blueprint-aligned checklist. It’s generated from our curriculum data so it stays in sync as outlines evolve. Work in weight order, then drill until you can explain why the wrong answers are wrong.

What’s covered

• Topic I - Economic Factors and Business Information (15%)
• Topic II - Investment Vehicle Characteristics (25%)
• Topic III - Client Investment Recommendations and Strategies (30%)
• Topic IV - Laws, Regulations, and Guidelines Including Prohibition on Unethical Business Practices (30%)

Topic I - Economic Factors and Business Information (15%)

Basic Economic Concepts (Topic I.A)

• Describe major phases of the business cycle at a high level and how they can affect markets and investor behavior.
• Differentiate monetary policy and fiscal policy at a high level and identify common tools used to influence economic activity.
• Explain how inflation and deflation affect purchasing power, real returns, and interest rate expectations at a high level.
• Explain interest rates and the yield curve at a high level and describe what an upward-, flat-, or inverted-curve can imply.
• Define credit spreads at a high level and explain what wider or narrower spreads generally signal about credit risk and liquidity.
• Explain how currency valuation and changes in exchange rates can affect returns on foreign investments at a high level.
• Recognize global macro risks (sovereign debt and geopolitical risk) and how they can transmit to domestic markets at a high level.
• Interpret key economic indicators at a high level (GDP, employment measures, CPI) and how they relate to growth and inflation.
• Explain trade deficits and balance of payments concepts at a high level and how they can relate to currency and capital flows.

Financial Reporting and Accounting Fundamentals (Topic I.B)

• Identify the purpose of the income statement, balance sheet, and statement of cash flows and what each measures at a high level.
• Use an income statement at a high level to distinguish revenue, expenses, and earnings and recognize the impact of one-time items.
• Use a balance sheet at a high level to distinguish assets, liabilities, and equity and understand basic liquidity and leverage signals.
• Use a statement of cash flows at a high level to distinguish operating, investing, and financing cash flows and why cash flow can differ from earnings.
• Differentiate audited and unaudited financial statements at a high level and recognize how assurance affects reliability.
• Differentiate cash-basis and accrual accounting at a high level and identify common implications for reported earnings.
• Interpret auditor opinions at a high level, including the meaning of unqualified versus qualified opinions.
• Identify common corporate SEC filings at a high level and what types of information investors typically find in them.
• Explain the role of annual reports and management discussion disclosures at a high level when evaluating a company.

Analytical Methods (Topic I.C)

• Calculate present value (PV) and future value (FV) given a rate and time period.
• Interpret net present value (NPV) as the value added or removed by a series of cash flows at a required return.
• Interpret internal rate of return (IRR) as the discount rate that sets NPV to zero and compare IRR to a required return at a high level.
• Compute and interpret mean, median, and mode, and recognize when each measure is most informative.
• Compute and interpret standard deviation and correlation at a high level as measures of volatility and co-movement.
• Interpret alpha and beta at a high level and relate them to market risk and relative performance.
• Interpret the Sharpe ratio as a risk-adjusted return measure and compare two investments at a high level.
• Calculate and interpret basic financial ratios (current ratio, quick ratio, debt-to-equity) and what they indicate at a high level.
• Calculate and interpret valuation ratios (P/E and P/B) and recognize common comparability limitations at a high level.

Types of Risk and Capital Structure (Topic I.D)

• Differentiate systematic risk and unsystematic risk at a high level and explain why diversification helps reduce unsystematic risk.
• Identify common systematic risks (interest rate risk, sector risk, geopolitical risk) and how they can affect portfolios at a high level.
• Identify common unsystematic risks (credit risk, issuer-specific risk, legal/regulatory risk, financial risk) at a high level.
• Explain opportunity cost at a high level and how it affects investment decision-making and asset allocation.
• Explain the concept of capital structure at a high level and why debt and equity have different risk and return characteristics.
• Describe liquidation priority at a high level and the general ordering of claims for debt, preferred stock, and common stock.
• Distinguish liquidity risk from market risk at a high level and recognize why liquidity conditions can change in stress periods.
• Recognize that risk is multi-dimensional (market, credit, liquidity, concentration) and should be evaluated in the client context at a high level.

Topic II - Investment Vehicle Characteristics (25%)

Cash and Cash Equivalents (Topic II.A)

• Differentiate demand deposits and certificates of deposit (CDs) at a high level (liquidity, interest, insured deposit concept).
• Identify common money market instruments (commercial paper, Treasury bills) and describe their typical risk characteristics at a high level.
• Compare insured deposits and money market instruments for safety, liquidity, and yield at a high level.
• Recognize interest rate risk and reinvestment risk considerations for short-term instruments at a high level.

Fixed Income Securities: Types and Tax Considerations (Topic II.B)

• Differentiate U.S. Treasury bills, notes, and bonds at a high level and identify how maturity and coupon structure can differ.
• Explain Treasury Inflation-Protected Securities (TIPS) at a high level and how they relate to inflation protection.
• Differentiate corporate bonds, municipal bonds, and foreign-issued bonds at a high level, including key risk drivers.
• Differentiate general obligation and revenue municipal bonds at a high level and identify common credit considerations.
• Describe asset-backed securities at a high level and identify key risks such as prepayment and underlying collateral performance.

Fixed Income Securities: Characteristics, Risks, and Valuation (Topic II.C)

• Explain, at a high level, how coupon, yield, and price interact for bonds (discount, par, premium).
• Differentiate yield-to-maturity (YTM) and yield-to-call (YTC) and identify when each measure is most relevant.
• Interpret duration as a measure of interest rate sensitivity and compare fixed income securities by duration at a high level.
• Explain credit risk concepts including bond ratings and credit spreads at a high level.
• Recognize call features and conversion features and explain, at a high level, how embedded options can affect valuation.
• Recognize tax implications and market liquidity considerations for fixed income securities and apply discounted cash flow intuition at a high level.

Equity Securities: Types and Characteristics (Topic II.D-E)

• Differentiate common stock, preferred stock (including floating-rate preferred), and convertible preferred stock at a high level.
• Explain American Depositary Receipts (ADRs) and identify key considerations for foreign equity exposure (currency, political, disclosure) at a high level.
• Describe shareholder rights at a high level (voting rights, preemptive/anti-dilution concepts, liquidation preferences).
• Recognize restricted stock and resale restriction concepts at a high level.
• Differentiate incentive stock options and nonqualified stock options at a high level and recognize how they can affect compensation and incentives.

Equity Valuation Methods (Topic II.F)

• Differentiate technical analysis and fundamental analysis at a high level and identify the types of inputs each uses.
• Explain dividend discount valuation intuition at a high level and when it is more or less applicable.
• Explain discounted cash flow valuation intuition at a high level and why assumptions about growth and discount rates matter.
• Recognize common limitations and risks in equity valuation methods (inputs, comparability, model risk) at a high level.

Equity Offerings and Capital Raising (Topic II.G)

• Differentiate an initial public offering (IPO) and a secondary offering at a high level and identify what changes for the issuer and investors.
• Describe SPAC/blank-check structures at a high level and identify common investor risks (sponsor incentives, dilution, timing).
• Recognize the role of underwriters and the concept of primary versus secondary distribution at a high level.

Pooled Investments: Types and Structures (Topic II.H)

• Distinguish open-end mutual funds and closed-end funds at a high level (creation/redemption, trading, pricing).
• Distinguish ETFs from mutual funds at a high level and explain how ETF shares can be created/redeemed through authorized participants.
• Explain unit investment trusts (UITs) at a high level and compare them with actively managed pooled products.
• Describe private funds at a high level (hedge funds, private equity, venture capital) and identify common features and risks (limited liquidity, leverage, fees).
• Explain REITs at a high level, including exchange-listed versus non-traded REIT characteristics and liquidity differences.

Pooled Investments: Fees, Pricing, Tax, and Comparisons (Topic II.I)

• Explain pooled investment share classes at a high level and how distribution/fee structures can differ.
• Identify and compare common pooled investment fees and costs at a high level (loads, CDSCs, 12b-1 fees, management fees, trading costs).
• Explain breakpoints at a high level and why they matter for front-end sales charges.
• Interpret net asset value (NAV) and explain, at a high level, when a product can trade at a premium or discount to NAV (e.g., closed-end funds, ETFs).
• Compare liquidity and tax implications across pooled investments at a high level.
• Evaluate pooled investments using relative comparison factors at a high level (benchmarks, manager tenure, indexes, style, policy changes, risk profile).

Derivative Securities: Types (Topic II.J)

• Define call options and put options at a high level and identify common uses (hedging, income, speculation).
• Define warrants at a high level and differentiate them from listed options.
• Define futures and forward contracts at a high level and identify how standardized futures differ from forwards.

Derivative Securities: Characteristics, Costs, and Risks (Topic II.K)

• Explain leverage and margin concepts at a high level for derivatives and how small price moves can create large gains or losses.
• Identify common derivative risks at a high level (time decay, volatility sensitivity, liquidity, counterparty/clearing considerations).
• Explain, at a high level, how derivatives can change portfolio risk/return and why costs and suitability matter.

Alternative Investments (Topic II.L)

• Describe limited partnerships at a high level and identify common features (pass-through taxation, limited liquidity, suitability considerations).
• Describe exchange-traded notes (ETNs) at a high level and differentiate them from ETFs.
• Explain leveraged and inverse funds at a high level and why returns can diverge from simple multiples over time due to compounding.
• Describe structured products at a high level and identify common risks (issuer credit risk, complexity, limited liquidity).
• Identify when alternative investments might be used (diversification, hedging) and key suitability considerations at a high level.

Insurance-Based Products (Topic II.M)

• Differentiate fixed, variable, and indexed annuities at a high level and identify key features (tax deferral, surrender charges, riders) and risks.
• Explain variable annuity subaccounts at a high level and how market performance affects contract values.
• Explain fixed and indexed annuity crediting concepts at a high level and identify key limitations and risks.
• Differentiate term, whole, universal, and variable life insurance at a high level and identify typical uses and risks.
• Recognize how insurance-based products can create liquidity and tax considerations and why time horizon matters at a high level.

Other Assets Including Digital Assets (Topic II.N)

• Describe commodities and precious metals at a high level and identify common drivers of price changes and risks.
• Differentiate commodity exposure vehicles at a high level (direct holding, funds, derivatives) and recognize key tradeoffs.
• Define digital assets at a high level and differentiate how a digital asset might be viewed as a security, currency, or other asset depending on facts.
• Identify major risks of digital assets at a high level (volatility, custody, fraud, regulatory uncertainty, technology risk).
• Recognize suitability and disclosure considerations for alternative and digital assets at a high level, including liquidity and concentration.

Topic III - Client Investment Recommendations and Strategies (30%)

Client Types and Legal Structures (Topic III.A)

• Differentiate individuals, natural persons, and sole proprietorships at a high level for account opening and authority.
• Differentiate general partnerships and limited partnerships at a high level, including who can bind the entity and common liability considerations.
• Describe limited liability companies (LLCs) at a high level and recognize account authority considerations (member-managed versus manager-managed).
• Differentiate C-corporations and S-corporations at a high level and recognize how entity structure can affect taxation and planning.
• Recognize basic trust and estate concepts relevant to accounts (grantor, trustee, beneficiary, executor) at a high level.
• Identify foundations and charities as clients and recognize governance and restricted-purpose considerations at a high level.

Client Profiling and Data Gathering (Topic III.B)

• Gather and categorize financial goals and objectives (growth, income, capital preservation, liquidity) at a high level.
• Analyze client cash flow and balance sheet information at a high level to assess liquidity needs and capacity for risk.
• Incorporate existing investments and concentration exposure when building a recommendation at a high level.
• Recognize how tax situation, Social Security, and pension benefits can affect planning and withdrawal needs at a high level.
• Differentiate risk tolerance from risk capacity and time horizon at a high level, and identify common mismatches.
• Identify nonfinancial considerations (values-based/ESG, religious constraints, life events, experience) and how they can constrain recommendations at a high level.
• Recognize behavioral finance biases (loss aversion, recency, overconfidence) and how they can influence client decisions at a high level.

Capital Market Theory (Topic III.C)

• Explain diversification and the concept of systematic versus unsystematic risk at a high level.
• Describe Modern Portfolio Theory (MPT) and the efficient frontier concept at a high level.
• Describe the Capital Asset Pricing Model (CAPM) and how beta relates to expected return at a high level.
• Explain the Efficient Market Hypothesis (EMH) and implications for active versus passive management at a high level.
• Recognize key assumptions and limitations of these models (inputs, correlations, distributions) at a high level.

Asset Allocation Strategies (Topic III.D)

• Distinguish strategic asset allocation and tactical asset allocation at a high level and identify when each might be used.
• Map client objectives and constraints to a high-level asset allocation across equities, fixed income, cash, and alternatives.
• Explain rebalancing at a high level and how it can manage drift and risk over time.
• Describe risk budgeting concepts at a high level and how allocations can be adjusted to target a risk level.
• Recognize the relationship between time horizon, liquidity needs, and asset allocation decisions at a high level.

Portfolio Styles and Techniques (Topic III.D)

• Differentiate active and passive management at a high level and evaluate tradeoffs (fees, tracking error, tax efficiency).
• Differentiate growth and value styles at a high level and identify typical characteristics and environments.
• Differentiate income and capital appreciation approaches at a high level and identify common vehicles for each.
• Describe sector rotation strategies at a high level and identify key risks (timing risk, concentration).
• Explain dollar-cost averaging at a high level and identify when it can or cannot reduce risk.
• Explain leverage and inverse strategies at a high level and identify key risks, including compounding effects over time.

Tax Considerations (Topic III.E)

• Differentiate ordinary income and capital gains at a high level and recognize how holding period affects taxation.
• Explain qualified dividends versus non-qualified dividends at a high level and their impact on after-tax return.
• Define cost basis and explain how basis affects realized gain/loss and tax reporting at a high level.
• Explain marginal tax brackets at a high level and why after-tax planning focuses on incremental effects.
• Describe the alternative minimum tax (AMT) concept at a high level and why certain items can trigger it.
• Describe retirement plan distributions and taxation basics at a high level (pre-tax versus Roth, early distribution considerations).
• Explain required minimum distribution (RMD) concepts at a high level and why distribution timing can matter.
• Explain government benefit implications such as IRMAA at a high level and why income management can matter.

Retirement Plans (Topic III.F)

• Compare traditional and Roth IRAs at a high level (tax timing) and recognize why eligibility and withdrawal rules matter.
• Describe Solo 401(k) plans at a high level and how they differ from standard employer plans.
• Differentiate defined contribution and defined benefit plans at a high level and identify common examples.
• Describe common employer plan features at a high level (matching, vesting, loans, rollovers, distribution choices).
• Describe SIMPLE IRA and SEP concepts at a high level and typical use cases for small employers.
• Differentiate qualified and nonqualified plans at a high level and identify key risks (credit risk, limited protections).
• Recognize planning considerations for retirement accounts at a high level (asset location, liquidity needs, beneficiary designations).

ERISA Issues (Topic III.G)

• Explain ERISA fiduciary duty concepts at a high level and what it means to act prudently for plan participants.
• Recognize diversification and default investment concepts (QDIA) at a high level and why plan design matters.
• Explain the purpose of an investment policy statement at a high level and how it supports governance and monitoring.
• Recognize prohibited transaction concepts at a high level and common conflict scenarios.
• Differentiate plan sponsor responsibilities from service provider responsibilities at a high level.

Special Types of Accounts (Topic III.H)

• Differentiate 529 plans and Coverdell accounts at a high level (ownership, qualified expenses, tax treatment, limitations).
• Explain UTMA/UGMA custodial accounts at a high level, including irrevocable gift concepts and age-of-majority implications.
• Explain health savings accounts (HSAs) at a high level, including qualified expenses and tax advantages.
• Recognize documentation and control/beneficiary issues unique to special accounts at a high level.
• Identify when special accounts may create liquidity or tax constraints that affect recommendations at a high level.

Ownership and Estate Planning Techniques (Topic III.I)

• Differentiate joint ownership forms (JTWROS, tenants in common, tenancy by the entirety, community property with right of survivorship) at a high level.
• Explain transfer-on-death (TOD) and pay-on-death (POD) registrations at a high level and how they transfer assets outside probate.
• Explain beneficiary designations, including per stirpes concepts, at a high level and identify common pitfalls.
• Describe basic trust and will functions at a high level and how they interact with account titling and beneficiary designations.
• Describe qualified domestic relations orders (QDROs) at a high level and when they affect account transfers.
• Describe donor-advised funds at a high level and typical use cases for charitable planning.

Trading Securities and Costs (Topic III.J)

• Define key trading terms (bid/ask, quotes, market/limit/stop orders) and identify trade-offs at a high level.
• Explain short sales and cash versus margin accounts at a high level, including key risks and suitability considerations.
• Differentiate principal and agency trades at a high level and recognize how compensation can be earned in each.
• Describe payment for order flow at a high level and explain how it can create conflicts relevant to best execution.
• Identify roles of introducing broker-dealers, clearing broker-dealers/custodians, market makers, and exchanges at a high level.
• Compare trading costs (commissions, markups/markdowns, spreads) and explain best execution at a high level.

Portfolio Performance Measures (Topic III.K)

• Calculate and interpret holding period return and annualized return at a high level.
• Differentiate time-weighted and dollar-weighted (money-weighted) returns and identify when each is appropriate.
• Interpret risk-adjusted returns and compare portfolios using metrics such as Sharpe, alpha, or beta at a high level.
• Explain inflation-adjusted and after-tax returns at a high level and why they matter for real-world outcomes.
• Select and evaluate relevant benchmarks at a high level and recognize benchmark pitfalls (mismatch, cherry-picking).

Topic IV - Laws, Regulations, and Guidelines Including Prohibition on Unethical Business Practices (30%)

Investment Adviser Definitions and Registration Scope (Topic IV.A)

• Define an investment adviser at a high level and distinguish advice about securities from general education.
• Identify the core elements of adviser status at a high level (in the business, compensation) and recognize direct versus indirect compensation.
• Differentiate state-registered advisers and federal covered advisers at a high level and why the regulator can differ.
• Describe notice filing requirements at a high level for federal covered advisers doing business in a state.
• Recognize common exclusions or exemptions from investment adviser registration at a high level without relying on numeric thresholds.
• Explain the concept of an exempt reporting adviser at a high level and why some advisers have limited reporting obligations.

IA Post-Registration Requirements, Records, and Supervision (Topic IV.A)

• Identify the role of Form ADV at a high level in adviser registration and client disclosure.
• Explain brochure delivery concepts at a high level and what clients should receive and when.
• Identify core books and records expectations for advisers at a high level (client agreements, trading records, communications, disclosures).
• Describe registration maintenance concepts at a high level (renewals, amendments, reportable events) and why timely updates matter.
• Explain the purpose of written policies and procedures at a high level (compliance program) and how supervision and review fit into that program.
• Explain investment adviser representative supervision expectations at a high level under adviser compliance programs.

Investment Adviser Representative (IAR) Regulation (Topic IV.B)

• Define an investment adviser representative (IAR) at a high level and identify typical IAR activities (soliciting, advising, managing accounts).
• Determine, at a high level, when an IAR must register in a state (place of business and client interactions) without relying on numeric thresholds.
• Differentiate how IAR registration works for state-registered advisers versus federal covered advisers at a high level.
• Identify core information captured on Form U4 at a high level and why accurate disclosures matter.
• Recognize ongoing maintenance obligations at a high level, including updates for reportable events and material changes.
• Recognize that clerical or administrative employees are generally excluded from IAR status at a high level and why role definitions matter.

Broker-Dealer and Agent Regulation (Topic IV.C-D)

• Define a broker-dealer at a high level and differentiate broker-dealer activity from investment advisory activity.
• Define an agent of a broker-dealer at a high level and identify typical agent activities.
• Explain what an underwriter does at a high level in a securities offering.
• Explain the role of market makers and associated persons at a high level in the trading ecosystem.
• Recognize high-level broker-dealer and agent registration and post-registration concepts and the importance of updates and supervision.

Securities and Issuers: Definitions, Registration, and Exemptions (Topic IV.E)

• Define security and issuer broadly at a high level and identify common security types versus common non-securities.
• Describe the purpose of securities registration at a high level (disclosure to investors) and distinguish registration from approval or endorsement.
• Differentiate federal registration, state registration, and notice filing concepts at a high level.
• Identify common exemptions and exclusions from securities registration at a high level without relying on numeric thresholds.
• Describe issuer agent and finder concepts at a high level and why compensation and solicitation activity can trigger regulation.
• Recognize state antifraud authority at a high level and that fraud is prohibited regardless of registration status.

Administrator Authority, Investigations, and Antifraud (Topic IV.E-F)

• Identify the role and powers of the state securities administrator at a high level (rulemaking, investigations, enforcement actions).
• Describe investigation tools at a high level (subpoenas, records requests, testimony) and the duty to cooperate.
• Explain cease-and-desist and stop order concepts at a high level and when they may be used.
• Describe denial, suspension, and revocation of registrations at a high level and common grounds (fraud, misstatements, failure to supervise).
• Recognize the ability of administrators to coordinate with other regulators and law enforcement at a high level.
• Identify red flags of potentially fraudulent offerings and advisory conduct at a high level (guarantees, pressure tactics, undisclosed conflicts).

Remedies, Penalties, and Liabilities (Topic IV.F)

• Differentiate administrative remedies from civil and criminal remedies at a high level.
• Explain rescission and restitution concepts at a high level and when investors may be entitled to recovery.
• Identify civil liability concepts at a high level for advisers, supervised persons, sellers, and control persons.
• Recognize that criminal penalties can apply for willful violations and fraud at a high level.
• Explain statute of limitations concepts at a high level (without relying on specific time periods) and why timing matters.

Communications, Disclosures, and Client Contracts (Topic IV.G)

• Identify common required disclosures to advisory clients at a high level (fees, services, conflicts, disciplinary history, scope of advice).
• Recognize unlawful representations about registration status or regulator approval at a high level.
• Explain why performance guarantees are generally prohibited and identify misleading guarantee language at a high level.
• Describe key elements of advisory client contracts at a high level (services, fees, termination, authority) and why clarity matters.
• Differentiate correspondence and advertising at a high level and recognize that social media, email, and websites can be advertising.
• Apply general advertising principles at a high level: fair and balanced, not misleading, and substantiated claims with appropriate disclosures.

Compensation and Conflicts of Interest (Topic IV.H)

• Differentiate advisory fees and brokerage commissions at a high level and recognize how each can create incentives.
• Explain performance-based fee concepts at a high level and why they can create conflicts and restrictions.
• Explain soft dollar arrangements at a high level and why disclosure, best execution, and policy controls matter.
• Recognize pay-to-play and political contribution risk at a high level and why certain contributions can be restricted.
• Identify common compensation conflicts and the expectation to disclose material conflicts at a high level.
• Recognize that disclosure alone may not be sufficient when a conflict cannot be effectively mitigated at a high level.

Client Assets: Custody, Discretion, Standards of Care, and AML (Topic IV.H)

• Define custody at a high level and identify situations that can create custody for an adviser (possession of client funds, fee deduction authority).
• Describe custody obligations at a high level (qualified custodian concept, account statements, independent verification concepts) without relying on numeric thresholds.
• Explain discretionary authority and trading authorization concepts at a high level and identify required documentation and limitations.
• Identify standards for safeguarding client funds and securities at a high level, including controls over disbursements and authorizations.
• Differentiate suitability-like considerations from adviser fiduciary duty concepts at a high level and how standard of care applies to advice.
• Describe anti-money laundering (AML) program basics at a high level (CIP/KYC, monitoring, SAR concepts) and identify common red flags.

Prohibited Practices and Unethical Business Conduct (Topic IV.H)

• Identify common prohibited conflicts at a high level (borrowing/lending with clients, profit/loss sharing) and why they are problematic.
• Explain client confidentiality expectations at a high level and when sharing client information can be permitted or prohibited.
• Recognize insider trading concepts at a high level and the importance of controlling material nonpublic information.
• Recognize selling away and undisclosed outside business activity risks at a high level and why supervision and disclosure matter.
• Recognize market manipulation concepts at a high level and why deceptive trading practices are prohibited.
• Identify personal securities transaction controls at a high level (policies, preclearance, reporting) and how they mitigate conflicts.
• Recognize exploitation of vulnerable adults and other dishonest or unethical practices at a high level and the duty to escalate/report concerns.

Cybersecurity, Privacy, and Business Continuity (Topic IV.H)

• Identify common cybersecurity risks at a high level (phishing, account takeover, data loss) and expectations for protecting client data.
• Explain privacy and data protection obligations at a high level and why access controls and secure transmission matter.
• Describe business continuity planning concepts at a high level and why disaster recovery and key-person risk matter.
• Describe succession planning concepts at a high level for advisory firms and how they protect clients.
• Recognize incident response and client communication considerations at a high level following a breach or major disruption.

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