Perform the required testing either by engaging independent contractors or by using employees who are not responsible for the development or operation of the systems or capabilities being tested, and engage independent contractors where the rules require it.
CFTC System Safeguards (17 CFR 37, 38, 39, 49) CFTC-SS-18 is one control. If you already hold one of the frameworks below, a reviewed crosswalk already says how much of CFTC System Safeguards (17 CFR 37, 38, 39, 49) your existing evidence covers. Hold NIST Cybersecurity Framework 2.0 and 28 of 39 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls already carry evidence.
Each report names every control your existing framework evidences, every one it does not, the reasoning behind each claim, and the claims that were argued against and rejected. 5 were rejected on the NIST Cybersecurity Framework 2.0 pair alone.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.