TheArtOfService
CFTC System Safeguards (17 CFR 37, 38, 39, 49)NIST SP 800-53 Rev 5

CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 12.7% of NIST SP 800-53 Rev 5

38 of the 300 controls in NIST SP 800-53 Rev 5 are already satisfied by evidence you collected for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 262 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.

12.7%
of the target already covered
38
controls evidenced
262
genuine gaps
0
claims rejected in review

This number is directional. It says how much of NIST SP 800-53 Rev 5 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.

92 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.

CP - Contingency Planning7 of 12 evidenced, 5 to do
CA - Assessment, Authorization, and Monitoring4 of 8 evidenced, 4 to do
IR - Incident Response4 of 9 evidenced, 5 to do
RA - Risk Assessment3 of 9 evidenced, 6 to do
SA - System and Services Acquisition5 of 17 evidenced, 12 to do
CM - Configuration Management3 of 14 evidenced, 11 to do
AT - Awareness and Training1 of 5 evidenced, 4 to do
PM - Program Management5 of 32 evidenced, 27 to do
PE - Physical and Environmental Protection3 of 22 evidenced, 19 to do
PS - Personnel Security1 of 9 evidenced, 8 to do
SR - Supply Chain Risk Management1 of 12 evidenced, 11 to do
AC - Access Control1 of 23 evidenced, 22 to do
AU - Audit and Accountability0 of 15 evidenced, 15 to do
IA - Identification and Authentication0 of 13 evidenced, 13 to do
MA - Maintenance0 of 7 evidenced, 7 to do
MP - Media Protection0 of 8 evidenced, 8 to do
PL - Planning0 of 8 evidenced, 8 to do
PT - PII Processing and Transparency0 of 8 evidenced, 8 to do
SC - System and Communications Protection0 of 47 evidenced, 47 to do
SI - System and Information Integrity0 of 22 evidenced, 22 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)NIST800-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)NIST800-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)NIST800-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)NIST800-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)NIST800-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)NIST800-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)NIST800-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)NIST800-CM-2argued against and upheld
Baseline configuration

Systems operations expressly requires baseline configuration management.

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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