DORACFTC System Safeguards (17 CFR 37, 38, 39, 49)

DORA covers 51.3% of CFTC System Safeguards (17 CFR 37, 38, 39, 49)

20 of the 39 controls in CFTC System Safeguards (17 CFR 37, 38, 39, 49) are already satisfied by evidence you collected for DORA. 19 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.

51.3%

of the target already covered

controls evidenced

genuine gaps

claims rejected in review

This number is directional. It says how much of CFTC System Safeguards (17 CFR 37, 38, 39, 49) your DORA 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 2026-08-20, 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.

CFTC System Safeguards: Risk Analysis and Oversight Program7 of 10 evidenced, 3 to do

CFTC System Safeguards: Cybersecurity Testing7 of 10 evidenced, 3 to do

CFTC System Safeguards: Business Continuity and Disaster Recovery4 of 12 evidenced, 8 to do

CFTC System Safeguards: Registrant Specific Requirements1 of 3 evidenced, 2 to do

CFTC System Safeguards: Notification, Records and Remediation1 of 4 evidenced, 3 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.

DORA-Art.537.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)argued against and upheld

Enterprise Risk Management and Governance Category

The management body owns, approves and oversees the ICT risk framework and funds it.

DORA-Art.937.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld

Information Security Category

Access management, encryption, secure configuration and network security are mandated protections.

DORA-Art.1137.1401(a)(3), 38.1051(a)(3), 39.18(b)(2)(ii), 49.24(b)(3)argued against and upheld

Business Continuity and Disaster Recovery Planning Category

An ICT continuity policy with response and recovery plans is required and regularly tested.

DORA-Art.737.1401(a)(4), 38.1051(a)(4), 39.18(b)(2)(iii), 49.24(b)(4)argued against and upheld

Capacity and Performance Planning Category

Systems must carry sufficient capacity and stay resilient under stressed processing conditions.

DORA-Art.937.1401(a)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5)argued against and upheld

Systems Operations Category

Secure configuration and continuous control of system security and functioning are required.

DORA-Art.637.1401(a), 38.1051(a), 39.18(b)(1), 49.24(a)(1) and 49.24(b)argued against and upheld

Program of Risk Analysis and Oversight

A sound, comprehensive and documented ICT risk framework must address ICT risk across operations.

DORA-Art.1137.1401(c), 38.1051(c), 39.18(c)(1), 49.24(a)(2) and 49.24(d)argued against and upheld

Business Continuity and Disaster Recovery Plan and Resources

Continuity plans with measures, procedures and arrangements must enable resumption and recovery.

DORA-Art.637.1401(c), 38.1051(c), 39.18(f)(1)argued against and upheld

Periodic Update of the Recovery Plan and Emergency Procedures

The framework and its continuity arrangements are reviewed at least annually.

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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