Framework overlap

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

You hold NIST Cybersecurity Framework 2.0 and have been told to do CFTC System Safeguards (17 CFR 37, 38, 39, 49). Here is how much overlaps, control by control.

57% of CFTC System Safeguards (17 CFR 37, 38, 39, 49) you already have

NIST Cybersecurity Framework 2.0 already covers about 57% of CFTC System Safeguards (17 CFR 37, 38, 39, 49), leaving 9 of 21 controls as genuinely new work.

Already covered 9 Likely covered 3 New work 9

What is genuinely new work

Nothing in NIST Cybersecurity Framework 2.0 reaches these. This is the list to scope.

CFTC-SS-10
Geographically Separate Backup Resources
CFTC-SS-15
Controls Testing
CFTC-SS-18
Testing by Independent Professionals
CFTC-SS-20
Recordkeeping of System Safeguards
CFTC-SS-21
Remediation of Deficiencies
CFTC-SS-4
Systems Operations
CFTC-SS-5
Systems Development and Quality Assurance
CFTC-SS-6
Physical Security and Environmental Controls
CFTC-SS-7
Generally Accepted Standards and Best Practices
Show the 12 you already have
CFTC-SS-1
Program of Risk Analysis and Oversight
CFTC-SS-13
Vulnerability Testing
CFTC-SS-14
Penetration Testing
CFTC-SS-16
Security Incident Response Plan Testing
CFTC-SS-17
Enterprise Technology Risk Assessment
CFTC-SS-2
Enterprise Risk Management and Governance
CFTC-SS-3
Information Security
CFTC-SS-8
Business Continuity-Disaster Recovery Plan and Resources
CFTC-SS-9
Recovery Time Objective
CFTC-SS-11
Business Continuity-Disaster Recovery Testing
CFTC-SS-12
Capacity and Performance Planning
CFTC-SS-19
Notification to the Commission

How this is calculated

Already covered means a mapping runs from a control in NIST Cybersecurity Framework 2.0 to that control. Likely covered means no direct mapping exists but both frameworks map to the same control in a third standard. New work means neither. We keep those separate rather than adding them into one friendlier number, because blending them would present a two-hop inference as a verified fact.

Coverage is not symmetric. Run it the other way and you will get a different number; both are correct.

From 332,959 cross-framework control mappings across 723 frameworks, 531 of them verified against their source documents. It does not tell you that you are compliant: a mapped control means the two standards ask for the same thing, not that you have done it.

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