CMMC
DoD certification verifying cybersecurity maturity for DIB
23 NYCRR 500
NY regulation for financial services cybersecurity
Quick Verdict
CMMC mandates tiered DoD contractor certification for FCI/CUI via NIST controls, ensuring supply chain security. 23 NYCRR 500 requires NY financial entities' risk-based programs with MFA, encryption, annual testing for NPI protection. Both drive compliance; CMMC gates contracts, Part 500 avoids fines.
CMMC
Cybersecurity Maturity Model Certification (CMMC) 2.0
Key Features
- Three cumulative maturity levels aligned to threat
- Verification through C3PAO and DIBCAC assessments
- NIST SP 800-171 110 controls for Level 2
- SPRS scoring with annual affirmations required
- POA&Ms limited to 180-day closure timelines
23 NYCRR 500
23 NYCRR Part 500 Cybersecurity Regulation
Key Features
- Annual CISO/CEO dual-signature certification
- 72-hour cybersecurity incident notification
- Phishing-resistant MFA for high-risk access
- Third-party service provider security policy
- Risk-based penetration testing and vulnerability management
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
CMMC Details
What It Is
Cybersecurity Maturity Model Certification (CMMC) 2.0 is a U.S. Department of Defense (DoD) certification framework verifying cybersecurity practices for the Defense Industrial Base (DIB). It operationalizes FAR 52.204-21 and NIST SP 800-171/172 requirements through a tiered model with three levels: Foundational (Level 1 for FCI), Advanced (Level 2 for CUI), and Expert (Level 3 for APT defense). The risk-based approach ensures protections match data sensitivity.
Key Components
- 14 domains mirroring NIST families (e.g., Access Control, Incident Response).
- **Level 117 FAR practices; Level 2: 110 NIST 800-171 controls; Level 3: +24 NIST 800-172 selections.
- Built on NIST standards with assessment guides using interview/examine/test methods.
- Certification via self-assessment (Level 1/2 select), C3PAO (Level 2), or DIBCAC (Level 3), valid 3 years with annual affirmations in SPRS/eMASS.
Why Organizations Use It
Mandated for DoD contractors handling FCI/CUI, ensuring contract eligibility. Reduces supply-chain risks, enhances resilience, lowers breach costs, and provides competitive edge via verified maturity. Builds prime-sub trust and supports M&A diligence.
Implementation Overview
Phased: governance, scoping/gap analysis, remediation, assessment prep, certification, sustainment. Applies to all DIB primes/subs; small/mid/large firms use enclaves for scoping. Requires SSP, POA&Ms (180-day close), evidence automation. (178 words)
23 NYCRR 500 Details
What It Is
23 NYCRR Part 500 is the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, a state-level mandate effective March 2017 with amendments in 2023. It establishes minimum, risk-based cybersecurity requirements for financial services entities to protect nonpublic information (NPI) and information systems. Its approach emphasizes governance, evidence-based outcomes, and prescriptive controls like MFA and incident reporting.
Key Components
- 14 core requirements including cybersecurity program, CISO appointment, risk assessments, MFA, encryption, TPSP oversight, penetration testing, and 72-hour incident notification.
- Built on risk assessment architecture; annual dual CISO/CEO certification with five-year record retention.
- Class A companies face enhanced audits and controls; no formal certification but NYDFS examinations enforce compliance.
Why Organizations Use It
- Mandatory for NY-licensed financial entities (banks, insurers, etc.) to avoid multimillion-dollar fines (e.g., Robinhood $30M).
- Enhances resilience, reduces incident risk, builds stakeholder trust, and aligns with NIST CSF.
- Provides competitive edge in vendor selection and insurance premiums.
Implementation Overview
- Phased roadmap: gap analysis, asset inventory, MFA rollout, TPSP contracts, testing; up to 24 months.
- Applies to Covered Entities in NY financial sector; small exemptions available.
- Involves governance setup, evidence repositories, and annual filings by April 15. (178 words)
Key Differences
| Aspect | CMMC | 23 NYCRR 500 |
|---|---|---|
| Scope | FCI/CUI protection via NIST controls across 14 domains | NPI protection via risk-based program and 14 requirements |
| Industry | Defense Industrial Base contractors/subcontractors | NY financial services licensees/regulated entities |
| Nature | Mandatory DoD certification with tiered assessments | Mandatory NYDFS regulation with annual certification |
| Testing | Self/C3PAO/DIBCAC assessments every 3 years | Annual pen testing, vulnerability assessments, risk reviews |
| Penalties | Contract ineligibility, debarment, no direct fines | Civil penalties, fines, license actions, consent orders |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CMMC and 23 NYCRR 500
CMMC FAQ
23 NYCRR 500 FAQ
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