When preparing for an assessment, the assessor determines that the client’s proprietary data resides within an enclave. However, the assessor is unable to review policies containing proprietary data onsite and plans to have the policies copied on removable media by the client’s IT staff, whom they are scheduled to interview. What should the assessor consider as part of their planning?
While examining controls on the use of portable storage devices, an assessor conducts an interview with a mid-level internal system administrator. The administrator describes the process to check out portable storage devices, which includes a user emailing IT staff directly, verifying that the media classification label matches the data classification, and limiting use of the device to a specified external system.
What is a MISSING element for the assessment of AC.L2-3.1.21: Portable Storage Use?
While reviewing CA.L2-3.12.3: Security Control Monitoring, the CCA notices that the assessment period is defined as one year. An OSC's SSP states that under CA.L2-3.12.3, security controls are monitored using the same one-year periodicity to ensure the continued effectiveness of the controls. The assessor understands that some CMMC practices can reference other practices for the entirety of their implementation. Is the OSC’s implementation under CA.L2-3.12.3: Security Control Monitoring acceptable?
During an assessment, the team is interviewing the IT staff to understand the ways in which the organization protects backup data. Because the company’s backups contain CUI, the Lead Assessor asks the IT engineer which method is used to ensure that the confidentiality of the backup data is being protected. Which implementation is LEAST LIKELY to be acceptable?
An OSC has a hardware and software list used to manage company assets. Which is the BEST evidence to show the OSC is managing the system baseline?
An OSC has contracted a C3PAO to perform a Level 2 Assessment. As the Lead Assessor is analyzing the assessment requirements, it is found that the OSC does not have a document detailing the assessment scope. How can this problem BEST be fixed?
While conducting a CMMC Level 2 Assessment for a small waveguide manufacturer, the client provides a copy of their CMMC Level 1 Self-Assessment that their senior official has recently approved and uploaded to the Supplier Performance Risk System (SPRS). What type of information may be covered within the Level 1 Self-Assessment that is OUTSIDE the scope of a Level 2 assessment?
While conducting a CMMC Level 2 gap analysis with a large defense contractor, a CMMC RP confirms that the organization uses a RADIUS server for authentication. What additional method could be used to comply with AC.L2-3.1.17: Wireless Access Protection?
In order to perform an interview, the Lead Assessor MUST ensure interview questions are:
During a company’s assessment, the CCA notices that the server room door is kept open with a fan in the entryway because the cooling system is inadequate and the machines are overheating. According to the physical protection policy, the server room’s keypad is the mechanism for managing and controlling access to this equipment, and only the IT team should have access to the server room. However, with the door open, the keypad is not necessary, and anyone can enter the room.
The CCA asks the IT manager how access to this room is protected while the door is open. Which response would allow the company to still meet the physical security requirement?
Some OSCs share real estate with other companies. To protect FCI/CUI behind unmanned entrances to buildings, floors, or other areas where FCI/CUI is created, used, stored, or transmitted, which of the following is the BEST method?
In validating the OSC’s implementation of AC.L2-3.1.16: Wireless Access Authorization, the CCA observes various personal and non-enterprise devices connected to the OSC’s Wi-Fi. Because organizations handle wireless access differently, the CCA must locate evidence showing who has ultimate authority over wireless access. Which authority is acceptable for authorizing wireless access?
A company has a CUI enclave for handling all CUI processed, stored, and transmitted through the organization. While interviewing the IT manager, the CCA asks how assets that can, but are not intended to, handle CUI are identified. The IT manager refers to the CUI system’s network diagram (which includes these assets) as well as the asset inventory (which lists these assets as Contractor Risk Managed Assets). Which other artifact MUST also mention these assets?
While conducting a CMMC Level 2 Third-Party Assessment of a small defense contractor, an assessor discovers that the contractor’s Information Security Policy has no documented change records demonstrating executive approval. The IT director states that they will add change records in the future, but that other evidence exists. Which documentation is MOST able to demonstrate persistent and habitual adherence to CMMC requirements?
A C3PAO is conducting a Level 2 assessment of a midsized construction contractor that does both private (commercial) and federal work. The contractor’s documentation states that all CUI flows through a single building on their office campus and is logically, physically, and administratively isolated from the rest of the environment. Why might an assessor request access to assess controls within a building or area not listed as in-scope in the documentation?
Both the SSP and network diagrams presented to the Lead Assessor by the OSC indicate managed service providers (MSPs) within the assessment boundary. In order to BEST understand the impact of the MSPs, what should the Lead Assessor do?
An assessor is assigned by the Lead Assessor to the pre-assessment template regarding evidence. There are several entries that include how the Assessment Team will identify, obtain, and inventory evidence. What else is required to determine readiness to conduct the assessment?
While conducting a Level 2 Assessment, the Assessment Team begins reviewing assessment objects. The team identifies concerns with several of the objects presented. Which artifacts would require the MOST verification?
An OSC has an established password policy. The OSC wants to improve its password protection security by implementing a single change. Which of the following is an acceptable element to add to the OSC’s password policy?
An OSC seeking Level 2 certification is working with an ESP. The organization is trying to determine if the ESP is considered within the assessment and is reviewing the Service Level Agreement (SLA) between the organization and the ESP. Which SLA component should be taken into consideration to determine if the ESP is within the assessment scope?
While assessing a company, the CCA is determining whether the company controls and manages connections between its corporate network and all external networks. The company has: (1) a strict employee policy prohibiting personal Internet use and personal email on company computers, and (2) firewalls plus a connection allow-list so only authorized external networks can connect to the company network. Are these safeguards sufficient to meet the applicable CMMC requirement?
The client has a Supervisory Control and Data Acquisition (SCADA) system as OT to be evaluated as part of its assessment. In reviewing network architecture and conducting interviews, the assessor determines that a firewall separates the SCADA system from the client’s enterprise network and that CUI is not processed by the SCADA system. Based on this information, what is an appropriate outcome?
An OSC is undergoing CMMC Assessment on an enterprise-wide basis. While walking to the conference room, the Assessor notices a printer repair technician in the hallway, unescorted, repairing a printer marked “Authorized for CUI printing.” What is the NEXT step the Lead Assessor should take regarding PE.L2-3.10.3: Escort Visitors?
The OSC’s network consists of a single network switch that connects all devices. This includes the OSC’s OT equipment, which processes CUI. The OT controller requires an unsupported operating system.
What can the Lead Assessor BEST conclude about the overall compliance with MA.L2-3.7.1: Perform Maintenance?
FIPS-validated cryptography is required to meet CMMC practices that protect CUI when transmitted or stored outside the OSC’s CMMC enclave. What source does the CCA use to verify that the cryptography the OSC has implemented is FIPS-validated?
A manufacturing company is seeking Level 2 certification. The loading docks are currently accessible directly from the company’s main parking lot, which may lead to unauthorized access to facilities. Based on this information, how should this method be modified to BEST meet Level 2 requirements?
While scoping the assessment, the assessor learns that the OSC uses various cloud-based solutions sporadically as part of its normal course of business. The OSC states that most business is conducted on-premises and that only a small amount of business uses the cloud. The OSC thinks the cloud is only used for system backups, but there are isolated exceptions.
Are the data provided sufficient to determine that the OSC limits connection to external information systems?
A company has a firewall to regulate how data flows into and out of its network. Based on an interview with their IT staff, all connections to their systems are logged, and suspicious traffic generates alerts. Examination of which artifact should give the CCA the details on how these are implemented?
An OSC outsources all of its security incident and event monitoring work to a third-party SOC. Additionally, the OSC utilizes a cloud-hosted antivirus (AV) system to fulfill the requirement of having virus protection without hosting additional servers on-site.
During the scoping discussion, both the SOC and AV should be listed as what type of asset?
ESPs are exceptionally common today, given that many organizations are turning to secure cloud offerings to establish and maintain compliance. Integral to these relationships is a responsibility matrix, which defines who is responsible for specific items such as security. This can be a very complex assortment of taskings associated with federal compliance, but what is the MOST important thing to remember?
What should the Lead Assessor do to BEST ensure the evidence supplied effectively meets the intent of the standard for a practice?
An Assessor is evaluating whether an OSC has implemented adequate controls to meet AC.L2-3.1.7: Privileged Functions. The OSC has procedures that define privileged vs. non-privileged account provisioning and an access control policy that restricts execution of certain functions only to privileged users.
What might the Assessor do to further evaluate the implementation of this practice?
A Lead Assessor is preparing to conduct a Level 2 Assessment for an OSC. The assessor already determined the assessment scope and systems included. In addition, the assessor requests:
Results of the most recent OSC self-assessment or any pre-assessments by an RPO,
The System Security Plan (SSP), and
A list of all OSC staff who play a role in in-scope procedures.
Based on this information, which item would the assessor MOST LIKELY request when preparing to conduct a Level 2 Assessment?
The assessor begins the assessment by meeting with the client’s stakeholders and learns that multiple subsidiaries exist. In order to perform a complete assessment, the assessor must review documents from multiple entities as multiple, corresponding Commercial and Government Entity (CAGE) codes were provided. Which of the following entities may receive certification as a result of this?
A CCA is assessing the concept of least functionality in accordance with CM.L2-3.4.6: Least Functionality.
Which method is the LEAST LIKELY to be useful as an assessment technique?
In an effort to understand whether the OSC appropriately defined the scope to exclude items that should not be assessed, which description does NOT belong in the scope?
While conducting a CMMC Level 2 assessment at a 100-person manufacturing company, the assessor receives a yellow badge labeled “SPECIAL ACCESS.” The assessor observes multiple badge types used by staff and visitors. The client explains that only three badge colors correspond to controlled access (with electronic access), while the rest are identifiers for seniority. How can the assessor BEST verify that the three colors are the only badges capable of accessing controlled areas for CUI-related activities?
An OSC is preparing for an assessment and wants to gather evidence that will be used by the Lead Assessor to determine the scope of the assessment. The OSC currently operates a hybrid network, with part of their infrastructure at their physical location and part of their infrastructure in a cloud environment.
What evidence should the OSC collect that would assist the Lead Assessor in determining cloud and hybrid environment constraints?
A company is undergoing a CMMC Level 2 Assessment. The Assessment Team is planning and preparing the assessment. Who is responsible for identifying methods, techniques, and responsibilities for collecting, managing, and reviewing evidence?
A Lead Assessor is conducting an assessment for an OSC. The Lead Assessor is collecting evidence regarding the OSC’s network separation techniques. Which technique would be considered a logical separation technique and would fall within the scope of the assessment?
During an assessment, the Assessment Team has identified, according to the SSP and network diagram, that there is a mission system that cannot be altered but that has privileged accounts which should have MFA applied. As it is not possible to deploy a typical type of MFA on the mission system, which of the following constitutes a sufficient second factor?
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