CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 29.5% of SOC 2
18 of the 61 controls in SOC 2 are already satisfied by evidence you collected for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 43 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.
This number is directional. It says how much of SOC 2 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.
43 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.
Capacity category requires monitoring, testing and analysis of current and projected capacity.
Requires backup facilities and technological resources sufficient for timely recovery.
Requires power, telecommunication, environmental controls and fire protection for facilities.
Requires regular periodic testing of recovery capabilities with results retained.
Requires prompt external notification of security incidents, malfunctions and recovery plan activation to the Commission.
Annual written enterprise technology risk assessment identifies, estimates and prioritises risks against mitigating controls.
Controls testing covers every control in the programme, with key controls independently tested.
Requires regular periodic objective testing and review of automated systems and controls.
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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