TheArtOfService
NIST SP 800-161 Rev 1CFTC System Safeguards (17 CFR 37, 38, 39, 49)

NIST SP 800-161 Rev 1 covers 48.7% of CFTC System Safeguards (17 CFR 37, 38, 39, 49)

19 of the 39 controls in CFTC System Safeguards (17 CFR 37, 38, 39, 49) are already satisfied by evidence you collected for NIST SP 800-161 Rev 1. 20 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.

48.7%
of the target already covered
19
controls evidenced
20
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 SP 800-161 Rev 1 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.

101 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: Registrant Specific Requirements2 of 3 evidenced, 1 to do
CFTC System Safeguards: Business Continuity and Disaster Recovery7 of 12 evidenced, 5 to do
CFTC System Safeguards: Cybersecurity Testing5 of 10 evidenced, 5 to do
CFTC System Safeguards: Notification, Records and Remediation2 of 4 evidenced, 2 to do
CFTC System Safeguards: Risk Analysis and Oversight Program3 of 10 evidenced, 7 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.

CM-337.1401(a)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5)argued against and upheld
Systems Operations Category

Brings vendor pushed and supplier initiated changes inside formal change control.

CM-237.1401(a)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5)argued against and upheld
Systems Operations Category

Establishes the baseline configuration against which later changes are detected.

SA-1137.1401(a)(6), 38.1051(a)(6), 39.18(b)(2)(v), 49.24(b)(6)argued against and upheld
Systems Development and Quality Assurance Category

Requires testing of what is delivered with results made available before acceptance.

SA-937.1401(a)(6), 38.1051(a)(6), 39.18(b)(2)(v), 49.24(b)(6)argued against and upheld
Systems Development and Quality Assurance Category

Governs outsourcing and vendor management across the service life cycle.

SA-437.1401(a)(6), 38.1051(a)(6), 39.18(b)(2)(v), 49.24(b)(6)argued against and upheld
Systems Development and Quality Assurance Category

Puts requirements and the evidence required into the acquisition and development contract.

RA-337.1401(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

Establishes ongoing risk analysis across enterprise, mission and system levels.

CP-237.1401(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

Requires a contingency plan and the resources to continue operating after disruption.

SA-937.1401(d), 38.1051(d), 49.24(f)argued against and upheld
Own Resources or Contractual Arrangements to Meet the Recovery Objective

Contractual arrangements with providers are governed, including the roles each party holds.

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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