TheArtOfService
CFTC System Safeguards (17 CFR 37, 38, 39, 49)FedRAMP Moderate

CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 9.9% of FedRAMP Moderate

32 of the 323 controls in FedRAMP Moderate are already satisfied by evidence you collected for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 291 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.

9.9%
of the target already covered
32
controls evidenced
291
genuine gaps
1
claims rejected in review

What this leaves you to do

FedRAMP Moderate has 323 controls. Holding CFTC System Safeguards (17 CFR 37, 38, 39, 49) already evidences 32 of them, so the work in front of you is 291 controls, not 323, which is 90% 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 FedRAMP Moderate 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.

82 candidate mappings were examined and 1 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.

CP - Contingency Planning7 of 23 evidenced, 16 to do
CA - Assessment, Authorization, and Monitoring4 of 14 evidenced, 10 to do
RA - Risk Assessment3 of 11 evidenced, 8 to do
IR - Incident Response4 of 17 evidenced, 13 to do
SA - System and Services Acquisition4 of 21 evidenced, 17 to do
AT - Awareness and Training1 of 6 evidenced, 5 to do
PE - Physical and Environmental Protection3 of 19 evidenced, 16 to do
CM - Configuration Management3 of 27 evidenced, 24 to do
PS - Personnel Security1 of 10 evidenced, 9 to do
SR - Supply Chain Risk Management1 of 12 evidenced, 11 to do
AC - Access Control1 of 43 evidenced, 42 to do
AU - Audit and Accountability0 of 16 evidenced, 16 to do
IA - Identification and Authentication0 of 27 evidenced, 27 to do
MA - Maintenance0 of 10 evidenced, 10 to do
MP - Media Protection0 of 7 evidenced, 7 to do
PL - Planning0 of 7 evidenced, 7 to do
SC - System and Communications Protection0 of 29 evidenced, 29 to do
SI - System and Information Integrity0 of 24 evidenced, 24 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-6argued against and upheld
Least Privilege

Expressly requires access to systems and data on a least privilege basis.

37.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)AT-2argued against and upheld
Literacy Training and Awareness

Expressly requires security awareness training for personnel.

37.1401(h)(5), 38.1051(h)(5), 39.18(e)(5), 49.24(j)(5)CA-2argued against and upheld
Control Assessments

Controls testing must cover each control in the programme, with key controls independently assessed.

37.1401(m), 38.1051(m), 39.18(e)(10), 49.24(n)CA-5argued against and upheld
Plan of Action and Milestones

Deficiencies must be documented, risk analysed and tracked to timely remediation.

37.1401(h), 38.1051(h), 39.18(e)(1)(i), 49.24(j)CA-7argued against and upheld
Continuous Monitoring

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

37.1401(h)(4), 38.1051(h)(4), 39.18(e)(4), 49.24(j)(4)CA-8argued against and upheld
Penetration Testing

Requires annual internal penetration testing by independent or non operating staff.

37.1401(h)(3), 38.1051(h)(3), 39.18(e)(3), 49.24(j)(3)CA-8argued against and upheld
Penetration Testing

Requires annual external penetration testing by independent contractors for covered entities.

37.1401(a)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5)CM-2argued against and upheld
Baseline Configuration

Systems operations expressly requires baseline configuration management.

Claims that did not hold

1 proposed mappings for this pair were rejected. They are kept in the graph rather than deleted, so what was thrown out is as inspectable as what survived. A crosswalk that never rejects anything is not being judged.

39.18(b)(4)SA-2
Allocation of Resources

control identity corrected 2026-08-19: FedRAMP SA-2 held the title 'Common Operating Picture' and the text 'Establish a common operating picture across IT, OT and physical security functions for cyber events.', which is not a NIST SP 800-53 Rev 5 control. SA-2 is Allocation of Resources: determine the high-level security and privacy requirements in mission and business process planning, determine, document and allocate the protecting resources through capital planning and investment control, and establish a discrete line item for information security and privacy in programming and budgeting documentation. This mapping was judged against the wrong requirement, so its judgement is void. The claim on record was that CFTC-SS-23 (CFTC System Safeguards (17 CFR 37, 38, 39, 49)) evidences SA-2 at high confidence; it does not evidence resource determination, allocation or a budget line item.

Claimed at high confidence before it was rejected.

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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