CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 25.8% of NIST SP 800-171 Rev 3
25 of the 97 controls in NIST SP 800-171 Rev 3 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.
What this leaves you to do
NIST SP 800-171 Rev 3 has 97 controls. Holding CFTC System Safeguards (17 CFR 37, 38, 39, 49) already evidences 25 of them, so the work in front of you is 72 controls, not 97, which is 74% 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 25 controls of NIST SP 800-171 Rev 3 you do not have to implement again, which is $11.96 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 you | 4 hours | 8 hours | 16 hours |
|---|---|---|---|
| the 25 already evidenced are | 100 hours | 200 hours | 400 hours |
| and the 72 remaining are | 288 hours | 576 hours | 1,152 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 NIST SP 800-171 Rev 3 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.
47 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.
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.
Information security category expressly requires separation of duties.
Information security category expressly requires least privilege access.
Expressly requires security awareness training for personnel.
Systems operations expressly requires baseline configuration.
Requires change management procedures and approvals for system changes.
Systems operations expressly requires least functionality.
Requires inventory of authorised and unauthorised devices and software.
Requires a written incident response plan covering classification, escalation and handling.
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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