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

NIST Cybersecurity Framework 2.0 covers 79.5% of CFTC System Safeguards (17 CFR 37, 38, 39, 49)

31 of the 39 controls in CFTC System Safeguards (17 CFR 37, 38, 39, 49) are already satisfied by evidence you collected for NIST Cybersecurity Framework 2.0. 8 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.

79.5%
of the target already covered
31
controls evidenced
8
genuine gaps
0
claims rejected in review

This number is directional. It says how much of CFTC System Safeguards (17 CFR 37, 38, 39, 49) your NIST Cybersecurity Framework 2.0 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.

81 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.

CFTC System Safeguards: Business Continuity and Disaster Recovery10 of 12 evidenced, 2 to do
CFTC System Safeguards: Risk Analysis and Oversight Program8 of 10 evidenced, 2 to do
CFTC System Safeguards: Cybersecurity Testing8 of 10 evidenced, 2 to do
CFTC System Safeguards: Notification, Records and Remediation3 of 4 evidenced, 1 to do
CFTC System Safeguards: Registrant Specific Requirements2 of 3 evidenced, 1 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.

NIST-CSF-GV.RM-0337.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)argued against and upheld
Enterprise Risk Management and Governance Category

Both require technology risk folded into the enterprise risk management programme.

NIST-CSF-GV.RM-0137.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)argued against and upheld
Enterprise Risk Management and Governance Category

Both require risk management objectives established and agreed for the programme.

NIST-CSF-PR.AA-0137.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld
Information Security Category

Both require identities and credentials for system and data access to be managed.

NIST-CSF-PR.AA-0537.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld
Information Security Category

Both require least privilege, separation of duties and managed access entitlements.

NIST-CSF-ID.IM-0437.1401(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

Both require continuity and recovery plans established and kept maintained.

NIST-CSF-PR.IR-0337.1401(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

Both require mechanisms delivering resilience in adverse situations.

NIST-CSF-PR.IR-0437.1401(a)(4), 38.1051(a)(4), 39.18(b)(2)(iii), 49.24(b)(4)argued against and upheld
Capacity and Performance Planning Category

Both require capacity maintained adequate to keep services available.

NIST-CSF-PR.PS-0137.1401(a)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5)argued against and upheld
Systems Operations Category

Both require configuration management with maintained baseline configurations.

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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