TheArtOfService
CFTC System Safeguards (17 CFR 37, 38, 39, 49)Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 19.3% of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

38 of the 197 controls in Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 are already satisfied by evidence you collected for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 159 are genuine gaps. Every claim below was judged against both control sets and then argued against; the ones that did not survive are published further down with the reason each failed.

19.3%
of the target already covered
38
controls evidenced
159
genuine gaps
0
claims rejected in review

What this leaves you to do

Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 has 197 controls. Holding CFTC System Safeguards (17 CFR 37, 38, 39, 49) already evidences 38 of them, so the work in front of you is 159 controls, not 197, which is 81% of the standard rather than all of it.

That is the whole claim. Every number in that sentence comes from the two counts above it and can be re-derived from the free tools without taking our word for any of it.

In money, using only our numbers. The full report is $299 and names 38 controls of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 you do not have to implement again, which is $7.87 per control identified. That arithmetic uses our price and our count and assumes nothing about you.

In your hours, using your assumption. We do not know what a control costs you to implement, so pick the column that looks like your organisation. These are your figures, not our claim.

If a control takes you4 hours8 hours16 hours
the 38 already evidenced are152 hours304 hours608 hours
and the 159 remaining are636 hours1,272 hours2,544 hours

Multiply by your own rate. We publish no rate because we have not measured yours, and a number built on an invented rate is the kind of claim this platform exists to argue against.

This number is directional. It says how much of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 your CFTC System Safeguards (17 CFR 37, 38, 39, 49) evidence satisfies. The reverse pair is a different number, often very different, because a security standard has enormous depth for access control and almost none for lawful basis or data subject rights.

80 candidate mappings were examined and 0 were removed. Signed off 2026-08-19, review level machine verified. Mappings were judged by Claude Code rather than read line by line by a practitioner. Every claim shows its reasoning so you can check it. Ask and a practitioner will review this pair.

Where the gaps are

Coverage is never evenly spread. A source standard usually satisfies one part of a target almost completely and barely touches another, and which part is which is the thing worth knowing before you plan the work.

A&A - Audit & Assurance5 of 6 evidenced, 1 to do
BCR - Business Continuity Management & Operational Resilience7 of 11 evidenced, 4 to do
TVM - Threat & Vulnerability Management5 of 10 evidenced, 5 to do
SEF - Security Incident Management, E-Discovery & Cloud Forensics4 of 8 evidenced, 4 to do
GRC - Governance, Risk & Compliance3 of 8 evidenced, 5 to do
CCC - Change Control & Configuration Management3 of 9 evidenced, 6 to do
DCS - Datacenter Security4 of 15 evidenced, 11 to do
HRS - Human Resources Security2 of 13 evidenced, 11 to do
STA - Supply Chain Management, Transparency & Accountability2 of 14 evidenced, 12 to do
AIS - Application & Interface Security1 of 7 evidenced, 6 to do
IVS - Infrastructure & Virtualization Security1 of 9 evidenced, 8 to do
UEM - Universal Endpoint Management1 of 14 evidenced, 13 to do
CEK - Cryptography, Encryption & Key Management0 of 21 evidenced, 21 to do
DSP - Data Security & Privacy Lifecycle Management0 of 19 evidenced, 19 to do
IAM - Identity & Access Management0 of 16 evidenced, 16 to do
IPY - Interoperability & Portability0 of 4 evidenced, 4 to do
LOG - Logging & Monitoring0 of 13 evidenced, 13 to do

Theme level, not control level, deliberately. The per-control list of what is evidenced and what is a gap is the report itself, so publishing it here would be publishing the thing being sold.

Claims that held

A sample. Each one names the control whose evidence does the work, the control it satisfies, and why.

37.1401(h), 38.1051(h), 39.18(e)(1)(i), 49.24(j)CCM-A&A-01argued against and upheld
Audit and Assurance Policy and Procedures

Requires regular periodic objective testing and review of automated systems and controls.

37.1401(h)(2)(iii), (3)(ii) and (iii), (4)(ii), (5)(ii) and (iii), (7)(ii); 38.1051(h) equivalents; 39.18(e) equivalents; 49.24(j) equivalentsCCM-A&A-02argued against and upheld
Independent Assessments

Testing must be by independent contractors or staff not responsible for the systems tested.

37.1401(h)(5), 38.1051(h)(5), 39.18(e)(5), 49.24(j)(5)CCM-A&A-03argued against and upheld
Risk Based Planning Assessment

Controls testing frequency is set by an appropriate risk analysis across programme controls.

37.1401(l), 38.1051(l), 39.18(e)(9), 49.24(m)CCM-A&A-05argued against and upheld
Audit Management Process

Requires reports to senior management and the board and procedures for remediation.

37.1401(m), 38.1051(m), 39.18(e)(10), 49.24(n)CCM-A&A-06argued against and upheld
Remediation

Requires documented analysis, decision and timely remediation of identified deficiencies.

37.1401(a)(6), 38.1051(a)(6), 39.18(b)(2)(v), 49.24(b)(6)CCM-AIS-04argued against and upheld
Secure Application Design and Development

Requires secure development covering requirements, testing, approvals and secure coding.

37.1401(c), 38.1051(c), 39.18(c)(1), 49.24(a)(2) and 49.24(d)CCM-BCR-01argued against and upheld
Business Continuity Management Policy and Procedures

Requires a maintained business continuity and disaster recovery plan and emergency procedures.

37.1401(c) and (d), 38.1051(c) and (d), 39.18(c)(2), 49.24(f)CCM-BCR-03argued against and upheld
Business Continuity Strategy

Sets an explicit recovery time objective of the next business day for resumption.

Claims that did not hold

Nothing proposed for this pair was rejected in review. That is unusual and worth knowing rather than hiding: it means the candidate set was small and every candidate held.

The full report

Everything above is a sample. The report is every evidenced control and every gap, with the reasoning and the source document behind each one, in a form you can hand to an assessor. $299, emailed immediately.

Buy this crosswalk