CFTC System Safeguards (17 CFR 37, 38, 39, 49)HIPAA Security Rule

CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 28.4% of HIPAA Security Rule

19 of the 67 controls in HIPAA Security Rule are already satisfied by evidence you collected for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 48 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.

28.4%

of the target already covered

controls evidenced

genuine gaps

claims rejected in review

This number is directional. It says how much of HIPAA Security Rule 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.

46 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.

Administrative15 of 32 evidenced, 17 to do

Physical3 of 12 evidenced, 9 to do

Policies and Procedures1 of 5 evidenced, 4 to do

Technical0 of 12 evidenced, 12 to do

Organizational0 of 6 evidenced, 6 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), 38.1051(a), 39.18(b)(1), 49.24(a)(1) and 49.24(b)164.308(a)(1)(i)argued against and upheld

Security Management Process (Standard)

Requires a programme of risk analysis and oversight to identify and minimise operational risk.

37.1401(h)(7), 38.1051(h)(7), 39.18(e)(7), 49.24(j)(7)164.308(a)(1)(ii)(A)argued against and upheld

Risk Analysis (Required)

Requires an annual written risk assessment of threats and vulnerabilities against mitigating controls.

37.1401(m), 38.1051(m), 39.18(e)(10), 49.24(n)164.308(a)(1)(ii)(B)argued against and upheld

Risk Management (Required)

Requires documented decisions to remediate or accept risk and timely remediation.

37.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)164.308(a)(1)(ii)(D)argued against and upheld

Information System Activity Review (Required)

Expressly requires audit log maintenance and analysis and account monitoring.

37.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)164.308(a)(3)(ii)(B)argued against and upheld

Workforce Clearance Procedure (Addressable)

Expressly requires personnel security and screening.

37.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)164.308(a)(5)(i)argued against and upheld

Security Awareness and Training (Standard)

Expressly requires security awareness training for personnel.

37.1401(h)(6), 38.1051(h)(6), 39.18(e)(6), 49.24(j)(6)164.308(a)(6)(i)argued against and upheld

Security Incident Procedures (Standard)

Requires a written security incident response plan with classification and escalation.

37.1401(e), 38.1051(e), 39.18(g), 49.24(g)164.308(a)(6)(ii)argued against and upheld

Response and Reporting (Required)

Requires prompt reporting of security incidents and targeted threats to the regulator.

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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