CMMC
DoD framework certifying DIB cybersecurity maturity levels
GLBA
U.S. regulation for financial privacy notices and data safeguards.
Quick Verdict
CMMC mandates tiered cybersecurity certification for DoD contractors protecting FCI/CUI, while GLBA requires privacy notices and security programs for financial institutions safeguarding NPI. Organizations adopt CMMC for contract eligibility; GLBA to avoid FTC penalties and build consumer trust.
CMMC
Cybersecurity Maturity Model Certification 2.0
Key Features
- Three cumulative levels for FCI, CUI, APT protection
- C3PAO third-party assessments for Level 2 certification
- DIBCAC government assessments exclusively for Level 3
- Limited POA&Ms with strict 180-day closure rules
- DFARS flow-down mandates to subcontractors
GLBA
Gramm-Leach-Bliley Act (GLBA)
Key Features
- Privacy notices and opt-out rights for NPI sharing
- Written information security program with risk assessment
- Qualified Individual and annual board reporting
- 30-day FTC breach notification for 500+ consumers
- Service provider oversight and vendor safeguards
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 DoD certification framework verifying cybersecurity practices for the Defense Industrial Base (DIB). It protects Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) via tiered levels: Level 1 (basic FCI safeguards), Level 2 (NIST SP 800-171 for CUI), Level 3 (NIST SP 800-172 enhancements against APTs). Uses a risk-based, verification-focused approach with defined assessments.
Key Components
- 14 domains (e.g., Access Control, Incident Response) with 17 (Level 1), 110 (Level 2), +24 (Level 3) practices.
- Built on FAR 52.204-21, NIST SP 800-171 Rev 2, NIST SP 800-172.
- Certification model: self-assessments (Level 1/2), C3PAO (Level 2), DIBCAC (Level 3); triennial validity, annual affirmations via SPRS/eMASS.
Why Organizations Use It
Mandated for DoD contracts; ensures eligibility, reduces breach risks ($57B+ annual losses). Builds supply-chain trust, competitive edge; enhances resilience, lowers insurance costs.
Implementation Overview
Phased: scoping, gap analysis, remediation, assessment. Applies to DIB primes/subcontractors (300K+ firms); complex scoping/enclaves for SMEs/enterprises. Requires SSP, POA&Ms (180-day limits), evidence collection.
GLBA Details
What It Is
The Gramm-Leach-Bliley Act (GLBA) is a U.S. federal regulation enacted in 1999. It establishes privacy and security standards for financial institutions handling nonpublic personal information (NPI). GLBA's primary purpose is consumer protection through transparency in data sharing and robust safeguards. It employs a risk-based approach via the Privacy Rule and Safeguards Rule.
Key Components
- **Privacy Rule (16 C.F.R. Part 313)Initial/annual notices, opt-out rights for nonaffiliated sharing.
- **Safeguards Rule (16 C.F.R. Part 314)Written security program with administrative, technical, physical controls; Qualified Individual; board reporting.
- **Pretexting provisionsAnti-social engineering measures. Built on risk assessment; no fixed control count; enforced compliance model with FTC oversight.
Why Organizations Use It
- Mandatory for financial institutions (broad scope: banks, lenders, tax firms).
- Mitigates enforcement risks (fines up to $100K/violation).
- Enhances data security, vendor oversight, breach response.
- Builds customer trust, operational resilience, competitive edge.
Implementation Overview
Phased: scoping, risk assessment, policy development, technical controls, testing. Applies to U.S. financial entities of all sizes; FTC audits, no formal certification.
Key Differences
| Aspect | CMMC | GLBA |
|---|---|---|
| Scope | Cybersecurity for FCI/CUI in DoD contracts | Privacy notices and NPI security for financial institutions |
| Industry | Defense Industrial Base contractors/subcontractors | Financial institutions including non-banks (tax prep, lenders) |
| Nature | Mandatory tiered certification program | Mandatory privacy/security rules with FTC enforcement |
| Testing | Self-assess/C3PAO/DIBCAC every 3 years | Risk assessments, pen tests, vulnerability scans periodically |
| Penalties | Contract ineligibility, debarment | Civil penalties up to $100K/violation, imprisonment |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CMMC and GLBA
CMMC FAQ
GLBA FAQ
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