This week we're joined by Fenando Machado of Cybersec Investments, an authorized CMMC C3PAO. Fernando has been around the CMMC space for years and has helped a ton of companies successfully pass their Joint Surveillance Assessments. Fernando shares what he's learned ahead of the effective date of the 32 CFR CMMC final rule and the rest of the phased roll-out.

Pathfinder 101: https://www.summit7.us/pathfinder

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

32 CFR CMMC Webinar: https://www.summit7.us/webinars/cmmc-32-cfr-final-rule

Fernando: https://www.linkedin.com/in/fernando-machado-cissp-cism-cca-ccp-5b5581124/

Cybersec Investments (C3PAO): https://cybersecinvestments.com/

(0:00 – 3:17): Intro (3:18 – 6:42): What's the key to assessment success? (6:43 – 8:48): What's the key to perfect scores? (8:49 – 11:42): Most problematic controls? (11:43 – 12:52): What's harder: technical or non-technical? (12:53 – 14:42): Are “False Starts” real? (14:43 – 17:44): How important is an MSP? (17:45 – 20:45): Current backlog? (20:46 – 22:38): $100k assessments? (22:39 – 24:27): Outro

What is the CMMC phased roll-out? How will the CMMC phased roll-out affect defense contractors and when? Most importantly: How should companies strategize based on the CMMC phased roll-out? We get into all of that and more this week.

Pathfinder 101: https://www.summit7.us/pathfinder

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

32 CFR CMMC Webinar: https://www.summit7.us/webinars/cmmc-32-cfr-final-rule

Who decides what CMMC status level is required in defense contracts? How do they decide? Q2 2025 is just around the corner and this week we dive into the decision factors that lead to CMMC status level requirements.

Pathfinder 101: https://www.summit7.us/pathfinder

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

32 CFR CMMC Webinar: https://www.summit7.us/webinars/cmmc-32-cfr-final-rule

48 CFR proposed rule podcast: https://youtu.be/Fzi3SFEs92U

A Joint Resolution of Disapproval has been submitted to disapprove the 32 CFR CMMC final rule. Is this the end of CMMC as we know it? Or, as is usually the case, has the ecosystem jumped to conclusions and let their confirmation bias get the better of them? This week we go deep into the Congressional Review Act and why there's much more to the story of Representative Palmer's resolution.

Pathfinder 101: https://www.summit7.us/pathfinder

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

32 CFR CMMC Webinar: https://www.summit7.us/webinars/cmmc-32-cfr-final-rule

Palmer's Resolution: https://www.congress.gov/bill/118th-congress/house-joint-resolution/221/text

GAO Report on the CMMC final rule: https://www.gao.gov/products/b-336776

CMMC Pathfinder Tool | In 5 minutes or less, this free tool will give you a clear path from where you are now to CMMC confidence: https://www.summit7.us/pathfinder

Start working on that beach body of evidence because all signs point to CMMC showing up in defense contracts in Summer 2025. Turns out that our Summer estimate is more conservative than government estimates. However, if you're a subcontractor then it doesn't matter much because the big primes are already telling people what time it is.

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

32 CFR CMMC Webinar: https://www.summit7.us/webinars/cmmc-32-cfr-final-rule

SBA Blog: https://advocacy.sba.gov/2024/10/24/dod-final-cmmc-rule/

32 CFR Final Rule: https://www.federalregister.gov/documents/2024/10/15/2024-22905/cybersecurity-maturity-model-certification-cmmc-program

CMMC Pathfinder Tool | In 5 minutes or less, this free tool will give you a clear path from where you are now to CMMC confidence: https://www.summit7.us/pathfinder

As a result of the 32 CFR Final CMMC rule, many organizations will be looking for help comprehending and implementing the imposed requirements. On this episode of the show, Jason and Joy dig into the differences between the Registered Practitioner (RP) certificate, and the Certified CMMC Professional (CCP) certification to highlight the value of the trainings for OSAs and ESP, and point out the importance of due dillegence above all!

[Webinar] CMMC Finalized: The 32 CFR CMMC Final Rule | Register Now: https://www.summit7.us/webinars/cmmc-32-cfr-final-rule

SPRS Scoring Webinar with Koren Wise - https://us06web.zoom.us/meeting/register/tZIoceihrTgoEtIS5scNKD_VWYB5IvLdYjSq

[Webinar] CMMC Finalized: The 32 CFR CMMC Final Rule | Register Now: https://www.summit7.us/webinars/cmmc-32-cfr-final-rule

The Cyber AB Townhall for the Month of October is the First TH since the publishing of the 32 CFR Final CMMC rule. On this episode of the show, Jason and Joy dig into the information distributed during the Townhall surrounding the re-authorization of C3PAOs and the eligibility of CMMC Certified Assesors (CCA).

CMMC Pathfinder Tool: https://www.summit7.us/pathfinder

[Webinar] CMMC Finalized: The 32 CFR CMMC Final Rule | Register Now: https://www.summit7.us/webinars/cmmc-32-cfr-final-rule

After years of waiting the FAR CUI rule has cleared regulatory review and we should see the proposed rule published in just a few weeks. In this episode we briefly cover the history of the FAR CUI rule and discuss what we know about it (and what we think we know).

The FAR CUI rule review page: https://www.reginfo.gov/public/do/eoDetails?rrid=539461

CMMC Pathfinder Tool: https://www.summit7.us/pathfinder

CMMC Pathfinder Tool | In 5 minutes or less, this free tool will give you a clear path from where you are now to CMMC confidence: https://www.summit7.us/pathfinder

The 32 CFR CMMC final rule is finally final! It's also 470 pages long. What gives? Public comment responses. Literally just 230 pages of responses to public comments. While some of the responses are helpful, much of the time DoD was forced to take the time and space to explain why comments weren't relevant to the CMMC program at all.

Final Rule Webinar: https://www.summit7.us/webinars/cmmc-32-cfr-final-rule

Effective Comments How To: https://youtu.be/1T_62cYiUA4?feature=shared

Pathfinder Demo: https://youtu.be/JiDTCchfCa0?feature=shared

CMMC Pathfinder Tool | In 5 minutes or less, this free tool will give you a clear path from where you are now to CMMC confidence: https://www.summit7.us/pathfinder

Yet another report analyzing defense contractor cybersecurity and compliance with DFARS contract clauses has found that adoption remains low. Even when companies are aware of their obligations, believe that CMMC will happen in 2024, and support minimum requirements there is no guarantee that implementation will happen. This week we dive into why that might be.