TheArtOfService
CFTC System Safeguards (17 CFR 37, 38, 39, 49)NIST Cybersecurity Framework 2.0

CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 32.1% of NIST Cybersecurity Framework 2.0

34 of the 106 controls in NIST Cybersecurity Framework 2.0 are already satisfied by evidence you collected for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 72 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.

32.1%
of the target already covered
34
controls evidenced
72
genuine gaps
0
claims rejected in review

This number is directional. It says how much of NIST Cybersecurity Framework 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.

84 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.

ID - Identify10 of 21 evidenced, 11 to do
PR - Protect9 of 22 evidenced, 13 to do
Govern1 of 3 evidenced, 2 to do
GV - Govern7 of 28 evidenced, 21 to do
RC - Recover2 of 8 evidenced, 6 to do
RS - Respond3 of 13 evidenced, 10 to do
DE - Detect2 of 11 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(h)(6), 38.1051(h)(6), 39.18(e)(6), 49.24(j)(6)NIST-CSF-DE.AE-08argued against and upheld
Incidents are declared when adverse events meet defined criteria

Plan must define and classify what constitutes a security incident.

37.1401(a)(7), 38.1051(a)(7), 39.18(b)(2)(vi), 49.24(b)(7)NIST-CSF-DE.CM-02argued against and upheld
The physical environment is monitored to find potentially adverse events

Physical security category requires monitoring of physical access to facilities.

37.1401(i)(3), 38.1051(i)(3), 39.18(c)(3)(iii)NIST-CSF-GV.OC-05argued against and upheld
Outcomes and dependencies of critical services are understood

Recovery plan must account for telecommunications, power, water and other essential service provider dependencies.

37.1401(i)(1), 38.1051(i)(1), 39.18(c)(3)(i)NIST-CSF-GV.OC-05argued against and upheld
Outcomes and dependencies of critical services are understood

Requires coordination with members and market participants on whom the registrant depends.

37.1401(l), 38.1051(l), 39.18(e)(9), 49.24(m)NIST-CSF-GV.OV-03argued against and upheld
Risk management performance is evaluated

Requires evaluation of the effectiveness of testing and assessment protocols and remediation procedures.

37.1401(a), 38.1051(a), 39.18(b)(1), 49.24(a)(1) and 49.24(b)NIST-CSF-GV.PO-01argued against and upheld
Cybersecurity risk management policy is established based on context and strategy

Requires establishing and maintaining a documented programme of risk analysis and oversight.

37.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)NIST-CSF-GV.RM-03argued against and upheld
Cybersecurity risk management activities and outcomes are included in enterprise risk

Enterprise risk management and governance category places technology risk inside enterprise risk management.

37.1401(l), 38.1051(l), 39.18(e)(9), 49.24(m)NIST-CSF-GV.RR-01argued against and upheld
Organizational leadership is responsible for cybersecurity risk management

Senior management and the board must receive, review and act on system safeguards results.

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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