NIST SP 800-171 Rev 3 covers 28.2% of CFTC System Safeguards (17 CFR 37, 38, 39, 49)
11 of the 39 controls in CFTC System Safeguards (17 CFR 37, 38, 39, 49) are already satisfied by evidence you collected for NIST SP 800-171 Rev 3. 28 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.
What this leaves you to do
CFTC System Safeguards (17 CFR 37, 38, 39, 49) has 39 controls. Holding NIST SP 800-171 Rev 3 already evidences 11 of them, so the work in front of you is 28 controls, not 39, which is 72% of the standard rather than all of it.
That is the whole claim. Every number in that sentence comes from the two counts above it and can be re-derived from the free tools without taking our word for any of it.
In money, using only our numbers. The full report is $299 and names 11 controls of CFTC System Safeguards (17 CFR 37, 38, 39, 49) you do not have to implement again, which is $27.18 per control identified. That arithmetic uses our price and our count and assumes nothing about you.
In your hours, using your assumption. We do not know what a control costs you to implement, so pick the column that looks like your organisation. These are your figures, not our claim.
| If a control takes you | 4 hours | 8 hours | 16 hours |
|---|---|---|---|
| the 11 already evidenced are | 44 hours | 88 hours | 176 hours |
| and the 28 remaining are | 112 hours | 224 hours | 448 hours |
Multiply by your own rate. We publish no rate because we have not measured yours, and a number built on an invented rate is the kind of claim this platform exists to argue against.
This number is directional. It says how much of CFTC System Safeguards (17 CFR 37, 38, 39, 49) your NIST SP 800-171 Rev 3 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.
32 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.
Users and devices are uniquely identified and authenticated before access.
Security literacy training is provided initially, annually and after defined events.
Least privilege allows only the access necessary to accomplish assigned tasks.
Duties requiring separation are identified and access authorizations support that separation.
An inventory of system components is developed and reviewed periodically.
Least functionality restricts functions, ports, protocols, software and services.
Change control defines, reviews and approves changes with security impact considered.
Current baseline configurations are developed, documented and maintained.
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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