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Today on our Tech for Business podcast, Todd, our COO and CISO and Ann, our Quality Assurance

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Analyst and GMC Specialist.

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Just joked about all these letters.

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I'm here to discuss CMMC.

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So we get Cybersecurity Maturity Model Certification.

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Did I get it?

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You did?

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Yeah!

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I love it.

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And that's the last time we'll say it.

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We'll just say the letters.

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Ann or Todd, I was hoping you'd give a really quick overview and my question is really who

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are we talking to today?

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Who is affected by the changes coming to this CMMC?

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And then what is it?

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Yeah, why don't we start with what is it real quick?

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Yeah.

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Let Ann do that and then I'll jump into some who and she can expand on it.

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It's a program.

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CMMC, not anything longer, is a program that was built to protect the defense industrial

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base which you'd hear Dibb referred to because we all love making words out of acronyms.

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A lot of times people hear those words immediately or if they have a similar background to me

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they're like, what, why are we touching this?

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We should just let it go.

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And really it's to protect the real details, not the overly secured, it's the medium level

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things and it applies to prime and subcontracts of the DOD and that goes to many levels, say

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a tier one, two, three and more.

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I think we as a technology provider really hit that two and three level.

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We're not typically dealing with a prime contractor but it's the smaller manufacturing

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that CIT really deals with and it applies to them just the same as a prime which makes

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it interesting and hard.

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Yeah, so a couple of things.

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This started out, what was it, 2019 I think is when they had the first iteration of CMMC

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and it's gone through a couple of iterations since then.

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It was a little bit longer than that.

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I can look that up real briefly.

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It's gone through a couple of iterations.

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The reason why we're talking about it now is because 2.0 is out and we're anticipating

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that this will be the final version that will end up being live.

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The current timeline has it being included in contracts that will be accepted at the

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beginning of 2025 so you're looking at February through April timeframe roughly.

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And so with that in mind, the time to get serious about it is now.

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When we've gone through a couple of the previous iterations, most people wait until the very

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last moment which is a little scary because it's hard to put all of the pieces in place

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at the last minute.

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But expanding on the who, it's anybody that's providing any goods or services to the Department

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of Defense and it's extremely broad so it includes subcontractors, it includes any providers

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that happen to be within the supply chain.

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So it's big.

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I think the number they're estimating is roughly 76,000.

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Companies are impacted by this.

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So it's a big number and it does impact a lot of people.

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And like I said, if you find yourself in that supply chain at any rate, the reason that

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the last C I want to kind of highlight this is it's not as simple as just putting and

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policies in place.

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There's a certification process that needs to be completed.

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So you have to do all of the stuff before you can be certified.

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And then once you're certified, you can start applying for the contracts.

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Some of the minor changes that happened over the last couple of iterations is it used to

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be a couple of different levels and they've scaled it down from five down to three, which

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makes it a little bit easier.

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Level one is about as basic as it gets.

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I mean, there's literally 17 controls.

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It really isn't all that complicated.

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But if you're going to be doing any business, you really need to be gunning for level two.

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And that I think jumps up to 119 security controls.

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So you go from a few to, wow, we got to get serious here.

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The level two really parallels the NIST 800.

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So it is that like Todd said, it's really paralleling that I like to think of the CMMC

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controls, one, two, and three, which it went, I think Todd, you said that five to three

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in this iteration is it's similar to what a SOC-1 type one to SOC-1 type two.

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It's the now prove it.

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Okay.

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Now we have, okay, we've had these requirements for a really long time.

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Like a lot of these stem from DFARS that have been on these contracts and have been

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pushed or levied.

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I don't want to say just like signed off, checked off, and not thought about much.

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But they're like, yeah, we're pretty close to that.

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I think this should be good.

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But it's really having that extra level now that says, well, now someone else is going

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to come and certify.

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In level one, you can self-certify, but level two, you can't.

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And that's really a huge leap to say, okay, now we have to have the evidence that we meet

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all these practices they call them, that everything from minor auditing to how you handle and

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safeguard your information.

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So it's a big deal.

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It really is.

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And some organizations have had practices in place.

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They've just never documented them, nor been required to certify that they do them in a

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way or modify them year over year.

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So it is a big, big thing coming.

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I think it's, is it required in 2025 that it will be on every new contract coming.

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It, we are seeing it already.

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But it, the requirement I think has, that's the part, one of the few items.

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The 2.0 isn't entirely ratified, if you will, by all parties yet.

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But that has been one of the key pieces.

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When is this effective?

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Because there are people that are like, well, it should have been a long time ago.

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And now we need to put a hard and fast date where that, that'll be included.

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Yeah.

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And I believe that the, the timeline was supposed to be more, I mean, so it's gone through several

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iterations and I think they're trying to get it ratified a little bit later this year.

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But to Ann's point, it is showing up in contracts already.

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And I kind of wanted to highlight this.

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This does impact a lot of small and mid-sized businesses.

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I mean, when I gave that 76,000, the vast majority of them, and that's like well over

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50,000 of those 76 are small businesses.

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And I mentioned that because that, again, you most likely can't do this on your own.

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You're probably going to need some assistance walking through it because you probably haven't

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had a mature compliance process historically.

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And I know you can easily get into the people's head if you go, is it worth it?

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My answer would be yes.

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But most people do know already inherently.

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If you look at what it takes to start to go down that path, people are already doing business

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with the Department of Defense.

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And if you don't go through this process, that portion of your business is going to go away.

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And you can quickly put a dollar amount as to what that looks like.

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You can look at your percentage of it.

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And assuming that's true, again, my perspective is now is the time really waiting throughout

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the year is not going to get you where you want to go.

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And historically, we have seen that.

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So we've had a few starts and stops with a bunch of our customers throughout the years

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as they're going, okay, I'm getting ready to gear up, which is good because again, now

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they don't have to take massive leaps over the next quarter, a couple of months.

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So in any case, anybody's curious, we're still in the, we just started the second quarter

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of 2024.

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So the timing of this podcast is pretty early in the process still.

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But if you're needing assistance, it doesn't have to be us.

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Obviously, we're not, our podcast does reach all parts of the country and beyond.

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So there are plenty of people out there that can help with the process, but it's now's

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the time.

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Get your head around the fact that you need to start working on this because there are

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plenty of projects that will take more than a couple of days or weeks.

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I did quick find at least the information right now says that assessments will be available

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Q1 2025, but the requirements will be Q3 of 2025.

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That's what it is as of today.

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Yeah.

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So the assessment that Ariel's talking about is you will be required if you're in this

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industry, you will be required to complete a self assessment every single year.

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So those are the ones that you're going to start seeing at the beginning of 2025.

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So I know this is, compliance is always, at least in my mind, like a lot of information.

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So I was wondering if you could explain a little bit of the changes and is this going

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to be a heavy lift for businesses?

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Are they going to have a lot they're going to need to do in the next year to get up to

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speed?

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And it depends, but the average business, the average, if you're doing your due diligence,

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are you going to have a harder time with all the changes coming?

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I was going to say hit the sound bar.

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Should we just have one?

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Just hit the button just for that, that it's really, in the 2.0, there really is not a

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lot of new requirements, to be honest.

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It's still near's nist.

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It just went from the five to the three.

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And that actually gained a lot of clarity for who can certify who can't and whatnot.

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But the requirements kind of remain the same.

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Just because there was an iteration or an update to 2.0 didn't make those required by

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this in 1.0, have those requirements disappear.

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I think there may have been some people that chose to wait until 2.0 was out.

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But it is a heavy lift.

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It can be.

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And it really getting through each of the requirements and seeing where you're at.

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And even, I know, like Todd said, we can certainly help do these, the gap assessment help you

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through a process.

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But it won't go away.

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And if you, again, like Todd mentioned, you risk not having that portion of your business

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quickly.

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And I don't think this is something that a lot of businesses are willing to just give

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up.

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A lot of that bread and butter of a smaller organization is this DOD base.

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And they've never had those requirements enforced before.

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And this is really kind of where what rubber meets the road.

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And unfortunately, it is kind of a we mean business kind of deal.

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And no one wants to be the bad guy, but this is kind of forced that hand to say, we've

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said this to you many times.

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We still need you to meet these requirements.

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And now we've expanded those to make a little bit more to mirror the NIST.

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And now someone's going to assess against this.

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And even if you had tried to, you're over a year, you're still going to have to maintain

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that year over a year.

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Yeah.

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And I think the depends part comes from everybody's in a different spot, right?

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So if an organization has already started down the path, it's going to be a lot easier.

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If you're waiting and you have been waiting, which, you know, love it, hate it, other,

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when it comes to compliance, a lot of people will make the decision.

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I'll do it when I'm forced to do it.

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Personally, I'm not a big believer in that.

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But my career sent me through manufacturing.

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So I was always in the ISO world and in the constant improvement process in general.

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So when I grew up, if you will, through my career, that was just kind of part of who

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I was and how I learned.

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And so when it comes to that, I look at it as more volunteer, which I would naturally

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fall into and start doing that, which we started this at CIT before we have had any kind of

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requirements, but we do fall heavily into that category as well.

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I would love to say I have an idea what the cost would be for an organization to go through

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this.

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Unfortunately, since every organization is a different size, the pricing does vary, right?

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You may have some things already in place, whether that's training and policies and procedures,

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or you may have nothing.

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And you're starting from ground zero, in which case there's going to be a lot to go through

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and a lot of stuff you're going to try and get in place, which is still possible between

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now and the beginning of 25.

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But you are starting to run out a little bit of a runway there.

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But there are some deep compliance requirements that are in there as well.

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I don't know how deep we're going to get into the security questions and controls today,

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but there is a lot there.

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And so it can be a significant amount of work.

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Just to kind of give you anything from a ballpark is if you've been going down a compliance

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path anyway, and there's a lot of them out there for a lot of different reasons, this

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had started and some people are on the path, you may have your antivirus, your security

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policy, your incident response plan.

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You may have good pieces in place already and you're just going, okay, the next big

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piece for me is a SIM.

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Well, that might be pretty straightforward.

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But again, if you're nowhere yet and you're going, that's fine.

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They're going to force me, I'll get to it.

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Then there's a lot and you are literally looking at months worth of work.

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One of the things that I think is interesting as you look at how CMMC has been evolving

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is it started out pretty heavy handed, which good, bad or other.

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It started because historically there was no enforcement of the rules, if you will.

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And then they got a lot of feedback going, you're asking an awful lot of us.

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And so they swung completely the opposite direction and made it extremely easy.

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And then it's kind of settling down in the middle where it's still a big lift, but it's

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not what it looked like in its original form.

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There's still a lot there.

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But again, the purpose behind it is it's time to get serious.

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We are going to enforce it.

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And if you can't do that, which is a whole certification phase, right?

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If you're not certified, you're not getting the business.

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So again, it was before we just kind of let it go and we figured we'd get there eventually.

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And unfortunately, the way the world is when it comes to cybersecurity and getting access

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to the state, even though it's been unclassified, it's still controlled.

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So they do have specific requirements about what you can do with it.

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And therefore, here comes CMMC to make sure you're doing what you're saying you're doing.

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For sure.

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So we can get into the nitty-gritty if you'd like.

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My quick question is, when I'm looking at some of the information provided for this

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podcast, I'm seeing these maturity levels and these framework levels.

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And when you go through this assessment, where you land, is that going to change the type

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of business you're able to do, the type of contracts you have?

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Are you able to reassess before that year?

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What does a little bit of that process look like just out of my own curiosity?

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Yes, to all of that.

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One of the more difficult pieces of this as they were approaching 2.0 is there were not

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assessors available and they had not been able to be trained on this nor certified.

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We had two, myself included, that went through registered practitioner training for this.

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And we have not recertified because this hasn't been ratified, if you will.

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And we want to make sure we're recertifying to the actual standard, not to a GUI standard

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that we can hope for.

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But I think I alluded to it earlier.

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Even once it's assessed, this is a requirement ongoing, not just a one time and then we'll

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come back.

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This could be one contractor can be required by one contract to be assessed or provide

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that information that they've been certified.

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But it could be that they have another assessment, if you will, by another entity, if you will.

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And I won't say it.

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It's not like an Army contract versus a Navy contract.

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They can go back and forth and have, they are all the same requirements, but they can

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go through and say, nope, we're not quite there.

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It looks like it's been nine months since your last assessment.

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We want to see your latest.

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And Todd mentioned that the requirement for the self-assessments, that is across the board,

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truly required whether you're any level.

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But the two and the three on this are other people being available outside entities coming

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to do that.

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And that can be tricky when there's not a lot of people.

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So to answer your question in a roundabout way, yes, you could have that follow on assessment,

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but the availability might not be there.

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Maybe you're scheduled and you're ready, but there's no one to do that.

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So it really is trying to ensure that you're going first and right the first time.

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So you wouldn't be required to do that.

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It sounds like the assessors are reasonable and fair, I guess I would say.

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But you don't, I would not want someone to have to come back and say, oh, are you sure?

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Do you still need it?

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Yeah.

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The answer to the original question is the contracts are going to come and it is a requirement.

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So it's part of the contract.

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You either participate and you don't.

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If you're not certified, you can't participate, you're done.

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If you were not certified by February and there's contracts that happened in there, those are

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the ones that you won't be able to.

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But if you got certified by April, then sure you could participate.

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There may be business cases as to why you would want to be fully ready to rock by February,

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assuming, hey, there's going to be a limited pool of people that are even able to do this

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work.

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We want to be one of those and that might be worthy of their time.

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But you can get assessed at any given time, of course, as Ann mentioned, assuming that

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you've got availability of the assessor.

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But again, I think the main thrust of it is you want to do it because it's going to be

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a requirement of a lot of those contracts.

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One of the things I think is really interesting when it looks at the assessment itself is there

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is a requirement in that you get that signed off by a senior official of your organization.

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And I mentioned that because the intent here is that you can't just say, go get that done,

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Jim, go turn the buttons and push the knobs.

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Sorry.

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No, you have to be fully engaged.

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So it is.

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Todd signs our SOC report saying that everyone in our organization has met the requirements

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and all the evidence that we've provided is true and accurate.

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That's where that senior leadership endorsement and Todd's eyes are wide open to where we

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are as an organization.

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It's no different in the CMMC.

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And this doesn't allow for a senior leadership team to be covering their eyes like, I had

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no idea.

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Wow.

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What?

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And we're very fortunate at CIT that our leadership is absolutely focused on things like this.

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That's not always the case.

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They're like, just get it done.

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Just check it off and we'll just sign it.

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I'm like, it really avoids that endorsement is critical and I like it.

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But it's across the board for a lot of different frameworks, to be honest, not just CMMC.

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Right.

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Yeah.

314
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And there was one other thing that I thought and hit on a moment ago before I started babbling

315
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when she had kind of talked about this isn't a one time thing, right?

316
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This is a continuous process.

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So you don't start it.

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You don't get a quick stamp and I'm done.

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This is a continuous thing.

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The intent is that you're always trying to get better.

321
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Again, as I said, we are not under a heavy compliance, but as these kinds of things come,

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we do start to become part of the supply chain.

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So we need to follow along as well.

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We naturally do because we're trying to do the right things.

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It also helps us with what we do, giving this type of guidance in general.

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But to me, staying on the path of compliance is a good natural thing for a business to

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be doing regardless of whether a regulator is on you about it or not.

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Understand that there's a cost associated with it.

329
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So not everybody's on board with that.

330
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But in my opinion, it's a big deal and being engaged does matter.

331
00:22:51,480 --> 00:23:03,360
So we've kind of been talking this high overview and I always try to ask what the biggest challenges

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or what the biggest hurdles you see, what are the things that are new for this CMMC

333
00:23:10,760 --> 00:23:19,360
2.0 that are going to kind of stop people up or clog people as they are trying to get

334
00:23:19,360 --> 00:23:24,640
this new certification, if that kind of makes sense?

335
00:23:24,640 --> 00:23:27,960
Where are the hiccups for businesses that they're going to maybe have problems with

336
00:23:27,960 --> 00:23:35,240
that are new or you've seen them lacking in the previous generation of this?

337
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I think we hit it from a couple different angles and that's really like the, I see maybe

338
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three right off the top of my head.

339
00:23:44,600 --> 00:23:48,600
One is it's not just a, oh yeah, we do it.

340
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It is you have to certify and then be ready with evidence that you can do this and continue

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to do this.

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That would be your self assessment, but then being prepared for having an assessment by

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an external entity.

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We're fortunate that we've gone through the process of, say, a SOC audit, but many people

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have not ever had that requirement of having external auditors or assessors to come into

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their organization.

347
00:24:19,480 --> 00:24:23,800
ISO is a big deal and it's in a similar vein.

348
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That might be one of the only manufacturing elements that they would kind of drop parallel,

349
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but then that compliance as a voluntary kind of implementation.

350
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That has a completely dovetailing that the voluntary commitment to getting to compliance

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standards and maintaining them because it's the right thing to do.

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00:24:53,680 --> 00:24:58,840
Matt, unfortunately, he's right that there are always going to be the people that don't

353
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do it till the very last second because it's stupid and I don't have time for this.

354
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I don't want to put the budget towards it.

355
00:25:05,880 --> 00:25:14,480
But in reality, most of any framework to very much importantly include CMMC are really trying

356
00:25:14,480 --> 00:25:20,680
to guide people in the right direction of meeting standards that are really important

357
00:25:20,680 --> 00:25:28,680
for you as an organization to maintain, in this case, your cyber hygiene.

358
00:25:28,680 --> 00:25:32,560
From my perspective, I think the thing that's going to be the hardest for organizations,

359
00:25:32,560 --> 00:25:35,960
there hasn't been a significant change on the security controls.

360
00:25:35,960 --> 00:25:41,400
There's domains that you have, so you need to do things like do you have physical security,

361
00:25:41,400 --> 00:25:45,480
that's door badge access, it's cameras on the buildings, there's security training.

362
00:25:45,480 --> 00:25:50,400
A lot of those things really didn't change from one version to the other.

363
00:25:50,400 --> 00:25:55,160
From my perspective, I think the hardest thing to kind of get your arms around is the maturity

364
00:25:55,160 --> 00:25:56,160
of it.

365
00:25:56,160 --> 00:26:00,520
I'll use this example of one of the things that you need to do under here is, and this

366
00:26:00,520 --> 00:26:03,320
is just an example, this is one piece of the puzzle.

367
00:26:03,320 --> 00:26:08,840
This is not like, hey, boom, we've got the answers, is the incident response.

368
00:26:08,840 --> 00:26:13,120
Typically the way that CIT addresses this is we go, we build the incident response plan,

369
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which includes a call tree.

370
00:26:15,840 --> 00:26:19,680
Inevitably at every organization I have never been at, I have never started out where they

371
00:26:19,680 --> 00:26:23,320
didn't have a single person that was the answer to every question.

372
00:26:23,320 --> 00:26:24,480
When this happens, what do you call?

373
00:26:24,480 --> 00:26:25,480
You call Joe.

374
00:26:25,480 --> 00:26:26,960
Great.

375
00:26:26,960 --> 00:26:30,960
What we typically do is we build the plan and then we build the tabletop exercise.

376
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The tabletop exercise we start as a maturity level is we try to bring in leadership, and

377
00:26:36,040 --> 00:26:37,960
this is the maturity I'm talking about.

378
00:26:37,960 --> 00:26:41,960
Again, more often than not, you got a doer that's doing the work and senior management

379
00:26:41,960 --> 00:26:44,680
is going, great, let me know when that's done and I'll sign off on it.

380
00:26:44,680 --> 00:26:47,120
Well, in this situation, that doesn't work, right?

381
00:26:47,120 --> 00:26:51,760
Because in the event something happens, senior management is going to want to know what happens.

382
00:26:51,760 --> 00:26:56,360
We start the plan, we do the tabletop, and the vast majority of our tabletop exercises

383
00:26:56,360 --> 00:27:01,320
to begin with are, do you know you're supposed to go grab the plan?

384
00:27:01,320 --> 00:27:02,320
It's that basic, right?

385
00:27:02,320 --> 00:27:03,320
Where's the plan?

386
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Then phase two is, okay, Joe's not available.

387
00:27:06,880 --> 00:27:07,880
Now what are you going to do?

388
00:27:07,880 --> 00:27:09,760
They're like, well, wait a minute, Joe's always available.

389
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He never goes on vacation, even when he does, he's got a cell phone.

390
00:27:12,520 --> 00:27:13,520
I can always get a phone.

391
00:27:13,520 --> 00:27:14,640
I'm like, great, he's out to see.

392
00:27:14,640 --> 00:27:15,640
His phone's not working now.

393
00:27:15,640 --> 00:27:16,640
What are you going to do?

394
00:27:16,640 --> 00:27:17,640
He won the lottery.

395
00:27:17,640 --> 00:27:18,640
He's out to see.

396
00:27:18,640 --> 00:27:19,640
Right.

397
00:27:19,640 --> 00:27:20,640
Whatever it is, right?

398
00:27:20,640 --> 00:27:25,080
Now all of a sudden, this maturity kicks in and the leadership finally gets it.

399
00:27:25,080 --> 00:27:28,400
So it isn't Joe, this is everybody.

400
00:27:28,400 --> 00:27:29,640
And then we keep building for that.

401
00:27:29,640 --> 00:27:35,240
So to me, that's the biggest hurdle to overcome is this isn't something you assign and delegate

402
00:27:35,240 --> 00:27:36,240
off.

403
00:27:36,240 --> 00:27:37,800
This is something that impacts your entire organization.

404
00:27:37,800 --> 00:27:42,960
And it does take a while to kind of embrace that and go, no, this is who we are now.

405
00:27:42,960 --> 00:27:45,560
And that is going to be by far, in my opinion, the biggest hurdle.

406
00:27:45,560 --> 00:27:49,760
And I know that sounds probably a little cheesy and whatnot, but it's the only way that you

407
00:27:49,760 --> 00:27:52,760
get this and you get it in place and it's repeatable.

408
00:27:52,760 --> 00:27:55,440
And again, if this is your business, you're working with the Department of Defense, there's

409
00:27:55,440 --> 00:27:57,160
a lot of money to be had out there, right?

410
00:27:57,160 --> 00:28:00,680
Everybody knows what Lockheed Martin's making and whatnot.

411
00:28:00,680 --> 00:28:01,780
It's significant.

412
00:28:01,780 --> 00:28:06,080
So there's a good reason why a lot of businesses choose to work with the Department of Defense.

413
00:28:06,080 --> 00:28:08,880
These are the kinds of things you're going to have to get your arms around and build

414
00:28:08,880 --> 00:28:10,200
it into the culture of your organization.

415
00:28:10,200 --> 00:28:17,280
And in my opinion, that's going to be the hardest thing to get in place.

416
00:28:17,280 --> 00:28:19,280
Looking at these changes.

417
00:28:19,280 --> 00:28:27,160
Is there anything that you are really, and maybe we answered it already, excited that's

418
00:28:27,160 --> 00:28:29,040
new in it?

419
00:28:29,040 --> 00:28:35,440
Or is there anything that you feel like is glaringly missing?

420
00:28:35,440 --> 00:28:37,800
From my perspective, I don't think there's a lot that's glaringly missing.

421
00:28:37,800 --> 00:28:41,240
They've got a lot of smart people that have contributed to this.

422
00:28:41,240 --> 00:28:43,520
So it is a very robust process.

423
00:28:43,520 --> 00:28:44,840
It's a great framework.

424
00:28:44,840 --> 00:28:45,840
There's a lot there.

425
00:28:45,840 --> 00:28:49,440
It excites me personally, and you're going to have to deal with the fact that I'm a security

426
00:28:49,440 --> 00:28:50,440
nerd.

427
00:28:50,440 --> 00:28:55,800
The fact that people are going to have to embrace it, right?

428
00:28:55,800 --> 00:28:59,680
From my perspective, the easiest thing that actually gets the security culture in place

429
00:28:59,680 --> 00:29:00,680
is the compliance.

430
00:29:00,680 --> 00:29:04,160
And I know that that sounds like it's really designed to be a hammer.

431
00:29:04,160 --> 00:29:07,600
And quite frankly, in a lot of cases it is.

432
00:29:07,600 --> 00:29:11,600
To me, that is the biggest boom from something like this, is most organizations should be

433
00:29:11,600 --> 00:29:13,880
doing a lot of stuff.

434
00:29:13,880 --> 00:29:19,120
Just to give you a little context out there is the way that CIT builds our offerings is

435
00:29:19,120 --> 00:29:20,720
we just include security.

436
00:29:20,720 --> 00:29:24,480
Because if I said, hey, we think you should do this, more often than not, the response

437
00:29:24,480 --> 00:29:25,560
is, let me think about that.

438
00:29:25,560 --> 00:29:26,760
I'll get back to you.

439
00:29:26,760 --> 00:29:31,120
But if we say it's just included and you get it, we'll set it up for you and we'll help

440
00:29:31,120 --> 00:29:34,680
you through the process, then people are pretty, okay, that makes sense.

441
00:29:34,680 --> 00:29:38,200
Well when that happens, those people that have been working for us, and I'm guessing

442
00:29:38,200 --> 00:29:43,560
there's other people that are out there like this, they're already set on that first level

443
00:29:43,560 --> 00:29:44,800
one, they're ready to rock.

444
00:29:44,800 --> 00:29:48,640
They're okay, we've got ports in place, we could even get certified on that today if

445
00:29:48,640 --> 00:29:50,280
we wanted to.

446
00:29:50,280 --> 00:29:54,680
That's great, but this compliance does help get us to the next level, which again, it

447
00:29:54,680 --> 00:29:59,080
can be a fight when people say I don't see the value in that.

448
00:29:59,080 --> 00:30:04,640
And I can only make so many business propositions on how it does actually make sense before

449
00:30:04,640 --> 00:30:08,640
I kind of go, okay, well, it's your decision, it's your risk, it's not mine.

450
00:30:08,640 --> 00:30:15,080
It's like the addition into cyber insurance requirements for ADR, where we had been ahead

451
00:30:15,080 --> 00:30:21,160
of the game putting that as part of our managed service offering.

452
00:30:21,160 --> 00:30:26,480
And I don't want to make this all about CIT because these are about technology for business,

453
00:30:26,480 --> 00:30:34,680
but to spot on, we are almost always ahead of the game in our compliance requirements

454
00:30:34,680 --> 00:30:42,240
and can confidently say it's important to us, it's important for us to deliver this quality

455
00:30:42,240 --> 00:30:45,280
of service to organizations.

456
00:30:45,280 --> 00:30:51,360
And oh, by the way, this meets XYZ amount of your compliance requirements.

457
00:30:51,360 --> 00:30:57,800
I mean, we're not, we're humble breaking, I don't know.

458
00:30:57,800 --> 00:30:59,960
Wait, just a break.

459
00:30:59,960 --> 00:31:06,120
Oh, you need to be able to have a show ADR.

460
00:31:06,120 --> 00:31:09,000
Okay, you're so good at this.

461
00:31:09,000 --> 00:31:11,600
I do think that's a part of it.

462
00:31:11,600 --> 00:31:15,000
One of the things, it came up a little bit earlier and I was going to jump in and mention

463
00:31:15,000 --> 00:31:17,680
that and I kind of forgot about it and I let it go.

464
00:31:17,680 --> 00:31:23,280
But Anne was kind of talking about earlier in the podcast about how going through the

465
00:31:23,280 --> 00:31:27,560
audit and being prepared for it is sometimes difficult to do.

466
00:31:27,560 --> 00:31:32,360
When you've got all the things in place, it really isn't that hard.

467
00:31:32,360 --> 00:31:35,120
And I know that's easy for me to say I've been doing this for a long time.

468
00:31:35,120 --> 00:31:38,160
I got all kinds of gray hair on my chin.

469
00:31:38,160 --> 00:31:46,240
But where I was going with this is really what it is is when you've got it in place.

470
00:31:46,240 --> 00:31:52,040
It's a little nerving, unnerving to go through an audit or certification process, right?

471
00:31:52,040 --> 00:31:55,760
You're basically somebody's judging you and that's a hard thing for most people to get

472
00:31:55,760 --> 00:31:57,600
their arms around.

473
00:31:57,600 --> 00:32:01,240
But when you're working with a partner that's going, yep, we've got that.

474
00:32:01,240 --> 00:32:03,560
We've got these, we're checking the boxes.

475
00:32:03,560 --> 00:32:07,880
It's more than checking the boxes because like I said, I want that leadership accountability

476
00:32:07,880 --> 00:32:08,880
in there too.

477
00:32:08,880 --> 00:32:13,040
But when we know we've got the things in place and we've got the proof, the certification

478
00:32:13,040 --> 00:32:16,080
process is quite simple.

479
00:32:16,080 --> 00:32:17,080
There is a roadmap.

480
00:32:17,080 --> 00:32:19,600
There is a way to get there.

481
00:32:19,600 --> 00:32:25,280
I try to avoid tuning our own horn on this podcast to keep it educational.

482
00:32:25,280 --> 00:32:29,400
But the businesses that we work with, do they come to you and say, I'm doing this

483
00:32:29,400 --> 00:32:35,360
CMMC thing and you hand them a folder and say, here's the pieces that we provide?

484
00:32:35,360 --> 00:32:40,400
What does that conversation look like with businesses who are working with an outside

485
00:32:40,400 --> 00:32:41,400
person?

486
00:32:41,400 --> 00:32:44,480
So if you listened to any of our podcasts before, basically what ends up happening is

487
00:32:44,480 --> 00:32:46,920
we do what I refer to as a gap analysis.

488
00:32:46,920 --> 00:32:47,920
Where are you at today?

489
00:32:47,920 --> 00:32:50,840
Because if I can't tell you where you're at, I can't tell you what the next steps are.

490
00:32:50,840 --> 00:32:52,640
But yes, you can start to build.

491
00:32:52,640 --> 00:32:57,400
Like I said, this process is completely mapped out.

492
00:32:57,400 --> 00:32:59,400
It is very, very logical.

493
00:32:59,400 --> 00:33:02,680
There is a way from zero to 100 and it is mapped.

494
00:33:02,680 --> 00:33:05,920
So you can sit down and say, here's how we're going to do it.

495
00:33:05,920 --> 00:33:09,640
You build the plan, you build the budget, and then you implement the plan.

496
00:33:09,640 --> 00:33:11,880
As I mentioned, everybody's in a different spot.

497
00:33:11,880 --> 00:33:13,600
Some people might be on antivirus.

498
00:33:13,600 --> 00:33:15,640
Some people may have adopted EDR.

499
00:33:15,640 --> 00:33:17,920
That's going to change how you approach things.

500
00:33:17,920 --> 00:33:21,360
But that's typically how it goes as you start to work through what's in place today and

501
00:33:21,360 --> 00:33:23,200
where are the gaps that we need to fill in?

502
00:33:23,200 --> 00:33:26,400
Do I need to get additional buy-in from leadership?

503
00:33:26,400 --> 00:33:28,240
So on and so forth.

504
00:33:28,240 --> 00:33:29,360
But that's how it typically begins.

505
00:33:29,360 --> 00:33:34,520
And yes, most people, I think one of the larger things that's hard, especially for those 50,000

506
00:33:34,520 --> 00:33:40,320
small businesses is while it's written in English and it's clear to someone like myself

507
00:33:40,320 --> 00:33:43,840
and Ann, it isn't to everybody.

508
00:33:43,840 --> 00:33:47,280
And so they look at that and they go, I can read that, but I'll be darned if I have the

509
00:33:47,280 --> 00:33:48,960
slightest idea what that says.

510
00:33:48,960 --> 00:33:51,680
The words putting together things.

511
00:33:51,680 --> 00:33:52,680
Right, exactly.

512
00:33:52,680 --> 00:33:55,160
So that can be a big hurdle.

513
00:33:55,160 --> 00:33:59,240
And so, yeah, there are lots of people out there that can help through that process and

514
00:33:59,240 --> 00:34:04,120
translate that into plain, actionable English for organizations.

515
00:34:04,120 --> 00:34:13,160
Again, not horn-tutting it either is one of the benefits of the CI team as a whole is

516
00:34:13,160 --> 00:34:15,600
that we are translators.

517
00:34:15,600 --> 00:34:19,200
But we may even have the products ahead of time.

518
00:34:19,200 --> 00:34:23,520
We have the things that meet the requirements, but we also seek to educate.

519
00:34:23,520 --> 00:34:28,120
We're not just going to drop something and say, hey, here, good luck to you.

520
00:34:28,120 --> 00:34:30,320
Like, yeah, it's EDR.

521
00:34:30,320 --> 00:34:32,440
And really, do you know what an EDR is?

522
00:34:32,440 --> 00:34:34,120
Do you know what that is?

523
00:34:34,120 --> 00:34:35,720
Okay, let's talk about it.

524
00:34:35,720 --> 00:34:36,720
Do you know?

525
00:34:36,720 --> 00:34:39,960
I understand you've asked us about CMMC.

526
00:34:39,960 --> 00:34:41,960
Here's the requirements.

527
00:34:41,960 --> 00:34:46,640
And let's see where that cross-references.

528
00:34:46,640 --> 00:34:51,640
We can't certify you, but we can certainly get you where you need to be and where you

529
00:34:51,640 --> 00:34:55,440
can start to understand where those requirements are.

530
00:34:55,440 --> 00:35:00,240
Some people might not be as excited as I am to talk about those things.

531
00:35:00,240 --> 00:35:08,200
But it's really important, even on a super high level, to say that it educates someone.

532
00:35:08,200 --> 00:35:16,280
Tell me in easy terms, not the words putting together, terms that this is why EDR is important

533
00:35:16,280 --> 00:35:17,640
to you.

534
00:35:17,640 --> 00:35:23,640
This is why these products are important to you as an organization.

535
00:35:23,640 --> 00:35:27,800
Yeah, one thing that, as Ann was talking, popped into my head, and I thought it related

536
00:35:27,800 --> 00:35:32,040
pretty well, is if you are looking for someone to partner with, there's a couple of different

537
00:35:32,040 --> 00:35:33,840
ways that the approaches typically go.

538
00:35:33,840 --> 00:35:36,960
And so if you're starting to do this, just keep this in your head.

539
00:35:36,960 --> 00:35:40,200
The three that I would say is, do it yourself.

540
00:35:40,200 --> 00:35:43,360
So somebody can sell you a tool, you implement it, you get it done, or maybe you do it all

541
00:35:43,360 --> 00:35:45,480
on your own, you do the research, et cetera.

542
00:35:45,480 --> 00:35:46,640
Do it together.

543
00:35:46,640 --> 00:35:50,240
So someone like CIT comes in and says, OK, we're going to work together on it.

544
00:35:50,240 --> 00:35:53,800
I'll take this piece, you take that piece, you let us know when you need additional help.

545
00:35:53,800 --> 00:35:54,840
And then there's do it for you.

546
00:35:54,840 --> 00:36:01,040
So there'll be the all-in, everything's included approach where that organization may just take

547
00:36:01,040 --> 00:36:02,240
it, run with it.

548
00:36:02,240 --> 00:36:06,480
It's not as simple as they just do everything with something like this.

549
00:36:06,480 --> 00:36:08,880
Because as I mentioned, the business does need the buy-in.

550
00:36:08,880 --> 00:36:10,200
They do need to say yes.

551
00:36:10,200 --> 00:36:11,880
They are the ones signing on the bottom line.

552
00:36:11,880 --> 00:36:17,280
And so there's a lot of trust that would go into a decision like that for me where you're

553
00:36:17,280 --> 00:36:18,280
going.

554
00:36:18,280 --> 00:36:21,760
I really believe this person can do everything they said they can, and I'm just going to sign

555
00:36:21,760 --> 00:36:22,760
off on it.

556
00:36:22,760 --> 00:36:24,720
That would be a tough pill for me to swallow.

557
00:36:24,720 --> 00:36:26,120
But there are those three approaches.

558
00:36:26,120 --> 00:36:29,240
And just think about that if you're looking for a partner to help you through that, is

559
00:36:29,240 --> 00:36:31,600
which one of those best suits you.

560
00:36:31,600 --> 00:36:33,600
For sure.

561
00:36:33,600 --> 00:36:34,600
Definitely.

562
00:36:34,600 --> 00:36:39,640
It seems to be a topic we may come back to at the end of the year as it comes back top

563
00:36:39,640 --> 00:36:44,400
of mind for people because it's getting a little bit closer for sure.

564
00:36:44,400 --> 00:36:47,280
Thank you so much, Todd and Anne for joining us today.

565
00:36:47,280 --> 00:36:51,560
If you liked this podcast, please sure to like and subscribe.

566
00:36:51,560 --> 00:36:56,520
If you have a topic you'd like us to discuss or want to know more about CMMC and all the

567
00:36:56,520 --> 00:37:03,280
things coming for that, reach out to us at info at cIT-net.com or head out to our podcast

568
00:37:03,280 --> 00:37:09,640
cIT-net.com slash podcast and we'll be back next week with an all new episode.

