Framework overlap

Does NIST Cybersecurity Framework 2.0 cover OCC Heightened Standards (12 CFR Part 30, Appendix D)?

You hold NIST Cybersecurity Framework 2.0 and have been told to do OCC Heightened Standards (12 CFR Part 30, Appendix D). Here is how much overlaps, control by control.

38% of OCC Heightened Standards (12 CFR Part 30, Appendix D) you already have

NIST Cybersecurity Framework 2.0 already covers about 38% of OCC Heightened Standards (12 CFR Part 30, Appendix D), leaving 5 of 8 controls as genuinely new work.

Already covered 0 Likely covered 3 New work 5

No control in NIST Cybersecurity Framework 2.0 maps directly to one in OCC Heightened Standards (12 CFR Part 30, Appendix D). Everything counted as covered is covered because both map to the same third standard, which is what a crosswalk is, but it is an inference rather than a lookup.

What is genuinely new work

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

OCCHS-2
Risk Governance Framework: Three Lines of Defense, Scope, and Charter
OCCHS-4
Independent Risk Management: CRO, Charter, Authority, and Oversight
OCCHS-5
Internal Audit: Independence, Scope, Methodology, and Reporting
OCCHS-6
Board of Directors: Composition, Independence, Oversight, and Self-Assessment
OCCHS-8
Third-Party Risk Within Heightened Standards and Integration with Broader Regulation
Show the 3 you already have
OCCHS-1
Scope, Applicability, and Definitions of Heightened Standards
OCCHS-3
Risk Appetite Statement, Risk Limits, Concentration Risk, and Limit Breach Protocols
OCCHS-7
Risk Data Aggregation, Reporting, Talent, Compensation, and Strategic Planning

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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