TheArtOfService
CFTC System Safeguards (17 CFR 37, 38, 39, 49)CMMC 2.0

CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 20% of CMMC 2.0

22 of the 110 controls in CMMC 2.0 are already satisfied by evidence you collected for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 88 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.

20%
of the target already covered
22
controls evidenced
88
genuine gaps
0
claims rejected in review

What this leaves you to do

CMMC 2.0 has 110 controls. Holding CFTC System Safeguards (17 CFR 37, 38, 39, 49) already evidences 22 of them, so the work in front of you is 88 controls, not 110, which is 80% of the standard rather than all of it.

That is the whole claim. We do not know your hourly rate, how long a control takes you, or how many people you have, so there is no figure here in dollars or weeks. 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.

This number is directional. It says how much of CMMC 2.0 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.

39 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.

Security Assessment4 of 4 evidenced
Incident Response3 of 3 evidenced
Risk Assessment3 of 3 evidenced
Physical Protection3 of 6 evidenced, 3 to do
Personnel Security1 of 2 evidenced, 1 to do
Configuration Management3 of 9 evidenced, 6 to do
Maintenance1 of 6 evidenced, 5 to do
System and Information Integrity1 of 7 evidenced, 6 to do
Access Control2 of 22 evidenced, 20 to do
System and Communications Protection1 of 16 evidenced, 15 to do
Awareness and Training0 of 3 evidenced, 3 to do
Audit and Accountability0 of 9 evidenced, 9 to do
Identification and Authentication0 of 11 evidenced, 11 to do
Media Protection0 of 9 evidenced, 9 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(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)AC.L2-3.1.4argued against and upheld
Separation of Duties

Information security category expressly requires separation of duties.

37.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)AC.L2-3.1.5argued against and upheld
Least Privilege

Information security category expressly requires least privilege access.

37.1401(h)(5), 38.1051(h)(5), 39.18(e)(5), 49.24(j)(5)CA.L2-3.12.1argued against and upheld
Security Control Assessment

Controls testing must assess each control included in the programme.

37.1401(m), 38.1051(m), 39.18(e)(10), 49.24(n)CA.L2-3.12.2argued against and upheld
Plan of Action

Deficiencies must be documented, decided upon and remediated in a timely manner.

37.1401(h), 38.1051(h), 39.18(e)(1)(i), 49.24(j)CA.L2-3.12.3argued against and upheld
Security Control Monitoring

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

37.1401(a), 38.1051(a), 39.18(b)(1), 49.24(a)(1) and 49.24(b)CA.L2-3.12.4argued against and upheld
System Security Plan

Requires a maintained documented programme covering systems, controls and procedures.

37.1401(a)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5)CM.L2-3.4.1argued against and upheld
System Baselining

Requires baseline configuration and inventory of devices and software.

37.1401(a)(6), 38.1051(a)(6), 39.18(b)(2)(v), 49.24(b)(6)CM.L2-3.4.3argued against and upheld
System Change Management

Requires change management procedures and approvals for system changes.

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.

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