SOC 2CFTC System Safeguards (17 CFR 37, 38, 39, 49)

SOC 2 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 SOC 2. 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

What this leaves you to do

CFTC System Safeguards (17 CFR 37, 38, 39, 49) has 39 controls. Holding SOC 2 already evidences 19 of them, so the work in front of you is 20 controls, not 39, which is 51% of the standard rather than all of it.

That is the whole claim. We do not know your hourly rate, how long a control takes you, or how many people you have, so there is no figure here in dollars or weeks. 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.

This number is directional. It says how much of CFTC System Safeguards (17 CFR 37, 38, 39, 49) your SOC 2 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.

39 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: Risk Analysis and Oversight Program8 of 10 evidenced, 2 to do
CFTC System Safeguards: Cybersecurity Testing6 of 10 evidenced, 4 to do
CFTC System Safeguards: Business Continuity and Disaster Recovery4 of 12 evidenced, 8 to do
CFTC System Safeguards: Notification, Records and Remediation1 of 4 evidenced, 3 to do
CFTC System Safeguards: Registrant Specific Requirements0 of 3 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.

SOC2-CC3.237.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)argued against and upheld
Enterprise Risk Management and Governance Category

Risk identification and analysis is the enterprise risk management category.

SOC2-CC6.137.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld
Information Security Category

Logical access security software over protected assets is the information security category.

SOC2-CC6.337.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld
Information Security Category

Least privilege, separation of duties and account authorisation are named in both.

SOC2-A1.337.1401(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

Testing recovery plan procedures is the periodic testing this category requires.

SOC2-A1.237.1401(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

Data backup processes and recovery infrastructure are continuity and recovery resources.

SOC2-A1.137.1401(a)(4), 38.1051(a)(4), 39.18(b)(2)(iii), 49.24(b)(4)argued against and upheld
Capacity and Performance Planning Category

Maintaining, monitoring and evaluating processing capacity is capacity and performance planning.

SOC2-CC8.137.1401(a)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5)argued against and upheld
Systems Operations Category

Authorising, testing and approving changes to infrastructure is the systems operations category.

SOC2-CC8.137.1401(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

Change design, development, testing and approval is systems development and quality assurance.

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.

Buy this crosswalk