Cyber AB CMMC-CCP - Certified CMMC Professional (CCP) Exam

In the context of a Cybersecurity Maturity Model Certification (CMMC) Level 2 Assessment, specific practices must be evaluated to ensure compliance with established security requirements. One such practice is AC.L2-3.1.19, which mandates the encryption of Controlled Unclassified Information (CUI) on mobile devices and mobile computing platforms.

Step-by-Step Explanation:

Requirement Overview:

Practice AC.L2-3.1.19 requires organizations to "Encrypt CUI on mobile devices and mobile computing platforms." This ensures that any CUI accessed, stored, or transmitted via mobile devices is protected through encryption, mitigating risks associated with data breaches or unauthorized access.

Assessment of Provided Evidence:

During the assessment, the Organization Seeking Certification (OSC) provided an inventory list encompassing servers, workstations, and network devices. Notably, this list lacks any mention of mobile devices or mobile computing platforms.

Implications of the Omission:

The absence of mobile devices in the inventory suggests that the OSC may not have accounted for all assets that process, store, or transmit CUI. Without a comprehensive inventory that includes mobile devices, it's challenging to verify whether the OSC has implemented the necessary encryption measures for CUI on these platforms.

Assessment Determination:

Given the incomplete inventory, the evidence is insufficient to make a definitive scoring determination for practice AC.L2-3.1.19. The OSC must provide a detailed inventory that encompasses all relevant devices, including mobile devices and computing platforms, to demonstrate compliance with the encryption requirements for CUI.

Step 1: Define CUI (Controlled Unclassified Information)CUI is information thatrequires safeguarding or dissemination controlspursuant to and consistent with applicable law, regulations, and government-wide policies, butis not classifiedunder Executive Order 13526 or the Atomic Energy Act.

✅Step 2: Authority over CUI — NARA’s RoleNARA – National Archives and Records Administration, specifically theInformation Security Oversight Office (ISOO), is thegovernment-wide executive agentresponsible for implementing the CUI program.

Source:

32 CFR Part 2002 – Controlled Unclassified Information (CUI)

Executive Order 13556 – Controlled Unclassified Information

CUI Registry – https://www.archives.gov/cui

NARA:

Maintains theCUI Registry,

Issuesmarking and handling guidance,

DefinesCUI categoriesand their authority under law or regulation,

Trains and informs Federal agencies and contractors on CUI policy.

B. NIST✘ NIST (National Institute of Standards and Technology) developstechnical standards(e.g., SP 800-171), but it doesnot define or mark CUI. It helps secure CUI once it’s identified.

C. CMMC-AB (now Cyber AB)✘ The Cyber AB is theCMMC ecosystem’s accreditation body, not a government agency, and hasno authority over CUI classification or marking.

D. Department of Homeland Security (DHS)✘ While DHS mayhandle and protect CUI internally, it is not the executive agent for the CUI program.

❌Why the Other Options Are Incorrect

NARAis theofficial U.S. government authorityresponsible for defining, categorizing, and marking CUI via theCUI Registryand associated policies underExecutive Order 13556.

TheCybersecurity Maturity Model Certification (CMMC) 2.0is primarily based on two key National Institute of Standards and Technology (NIST) Special Publications:

NIST SP 800-171– "Protecting Controlled Unclassified Information (CUI) in Nonfederal Systems and Organizations"

NIST SP 800-172– "Enhanced Security Requirements for Protecting Controlled Unclassified Information: A Supplement to NIST Special Publication 800-171"

NIST SP 800-171

This document is thecore foundationof CMMC 2.0 and establishes the security requirements for protectingControlled Unclassified Information (CUI)in non-federal systems.

The 110 security controls fromNIST SP 800-171 Rev. 2are mapped directly toCMMC Level 2.

NIST SP 800-172

This supplement includesenhanced security requirementsfor organizations handlinghigh-value CUIthat faces advanced persistent threats (APTs).

These enhanced requirements apply toCMMC Level 3under the 2.0 model.

B. DFARS, FIPS 100, and NIST SP 800-171→Incorrect

WhileDFARS 252.204-7012mandates compliance withNIST SP 800-171,FIPS 100 does not existas a relevant cybersecurity standard.

C. DFARS, NIST, and Carnegie Mellon University→Incorrect

CMMC is aligned with DFARS and NIST but isnot developed or directly influenced by Carnegie Mellon University.

D. DFARS, FIPS 100, NIST SP 800-171, and Carnegie Mellon University→Incorrect

Again,FIPS 100 is not relevant, andCarnegie Mellon Universityis not a defining entity in the CMMC framework.

CMMC 2.0 Scoping Guide (2023)confirms thatCMMC Level 2 is entirely based on NIST SP 800-171.

CMMC 2.0 Level 3 Draft Documentationexplicitly referencesNIST SP 800-172for enhanced security requirements.

DoD Interim Rule (DFARS 252.204-7021)mandates that organizations meetNIST SP 800-171 for CUI protection.

Reference and Breakdown:Eliminating Incorrect Answer Choices:Official CMMC 2.0 References Supporting the Answer:Final Conclusion:The CMMC 2.0 model is derivedsolely from NIST SP 800-171 and NIST SP 800-172, makingAnswer A the only correct choice.

What Happens in Phase 4 of the CMMC Assessment Process?Phase 4 of theCMMC Assessment Process (CAP)is theFinal Reporting and Decision Phase. During this phase, theLead Assessormust:

Review all assessment findings

Determine the Organization Seeking Certification’s (OSC) eligibility for certification

Make a recommendation to the C3PAO (Certified Third-Party Assessment Organization)

Ensure that the OSC hasmet the required practices and processes.

Confirm that anydeficiencieshave been corrected or appropriately documented.

Recommendwhether the OSC is eligible for certificationbased on assessment results.

Key Responsibilities of the Lead Assessor in Phase 4:Since theLead Assessor must determine and recommend the OSC’s eligibilityto the C3PAO, the correct answer isB. Eligibility.

A. Ability❌Incorrect. While assessing an OSC’s ability to meet CMMC requirements is part of the process, the final determination in Phase 4 is abouteligibilityfor certification.

C. Capability❌Incorrect. Capability refers to an organization'stechnical and operational readiness. The Lead Assessor is making a recommendation oneligibility, not just capability.

D. Suitability❌Incorrect. Suitability is not a defined term in theCMMC CAP processfor final assessment recommendations. The correct term iseligibility.

Why the Other Answers Are Incorrect

CMMC Assessment Process (CAP) Document– Specifies that the Lead Assessor must determine and recommend theeligibilityof the OSC in Phase 4.

CMMC 2.0 Model– Defines the assessment process, including certification decision-making.

CMMC Official ReferencesThus,option B (Eligibility) is the correct answer, as per official CMMC guidance.

Understanding the Reporting Process in a CMMC 2.0 Level 2 AssessmentACMMC Level 2 Assessmentconducted by aCertified Third-Party Assessor Organization (C3PAO)follows a structured approach to gathering evidence, evaluating compliance, and reporting findings to theOrganization Seeking Certification (OSC). The reporting process is outlined in theCMMC Assessment Process (CAP) Guide, which specifies how findings should be communicated.

Daily Checkpoints:

Throughout the assessment, the assessor team holdsdaily checkpoint meetingswith the OSC to provide updates on progress, observations, and preliminary findings.

These checkpoints help ensure transparency and allow the OSC to address minor issues as they arise.

Final Results Delivery:

Thefinal assessment resultsare typically shared during thefinal daily checkpointOR in aseparately scheduled findings and recommendations reviewmeeting.

This ensures that the OSC receives a structured and complete summary of the assessment findings before the official report is submitted.

TheCMMC Assessment Process (CAP) Guide, Section 4.5clearly states that assessment findings should be presentedeither at the last daily checkpoint or during a separately scheduled final review.

This aligns with best practices formaintaining transparency and ensuring the OSC has clarity on their assessment resultsbefore the final report submission.

Option A (End of every day)is incorrect because while assessors do provide updates, they do not deliver the "final results" daily.

Option B (Daily and a separate final review)is misleading, as the CAP Guide allows assessors tochoosebetween the final daily checkpoint OR a separate findings review—not both.

Option D (After C3PAO approval)is incorrect because theC3PAO does not approve findings before they are communicated to the OSC. The assessment team directly presents the results first.

CMMC Assessment Process (CAP) Guide, Section 4.5: Reporting and Findings Communication

CMMC 2.0 Level 2 Assessment Process Overview

CMMC Assessment Final Report Guidelines

Assessment Communication StructureWhy Option C is CorrectOfficial CMMC Documentation ReferencesFinal VerificationBased on officialCMMC 2.0 documentation, thefinal assessment results should be presented to the OSC either at the last daily checkpoint or in a separately scheduled review session, making Option C the correct answer.

Understanding the Principle of Least Functionality in the CM DomainTheConfiguration Management (CM) domainin CMMC 2.0 focuses on maintaining the security and integrity of an organization’s systems through controlled configurations and restrictions on system capabilities.

The principle ofLeast Functionalityrefers to limiting a system’s features, services, and applications to only those necessary for its intended purpose. This principle reduces the attack surface by minimizing unnecessary components that could be exploited by attackers.

CMMC Practice CM.L2-3.4.6 (Use Least Functionality)explicitly states:"Employ the principle of least functionality by configuring organizational systems to provide only essential capabilities."

Thegoalis to prevent unauthorized or unnecessary applications, services, and ports from running on the system.

Examples of Implementation:

Disabling unnecessary services, such as remote desktop access if not required.

Restricting software installation to approved applications.

Blocking unused network ports and protocols.

A. Least Privilege

This principle (associated with Access Control) ensures that users and processes have only the minimum level of access necessary to perform their jobs.

It is relevant to CMMC PracticeAC.L2-3.1.5 (Least Privilege)but does not define system capabilities.

B. Essential Concern

There is no officially recognized cybersecurity principle called "Essential Concern" in CMMC, NIST, or related frameworks.

D. Separation of Duties

This principle (covered under CMMCAC.L2-3.1.4) ensures that no single individual has unchecked control over critical functions, reducing the risk of fraud or abuse.

While important for security, it does not define essential system capabilities.

CMMC 2.0 Level 2 Assessment Guide – Configuration Management (CM) Domain

CM.L2-3.4.6 mandatesleast functionalityto enhance security by removing unnecessary features.

NIST SP 800-171 (which CMMC is based on) – Requirement 3.4.6

States:"Limit system functionality to only the essential capabilities required for organizational missions or business functions."

NIST SP 800-53 – Control CM-7 (Least Functionality)

Provides detailed recommendations on configuring systems to operate with only necessary features.

Justification for the Correct Answer: Least Functionality (C)Why Other Options Are IncorrectOfficial CMMC and NIST ReferencesConclusionTheprinciple of Least Functionality (C)is the basis for defining essential system capabilities in theConfiguration Management (CM) domainof CMMC 2.0. By applying this principle, organizations reduce security risks by ensuring that only the necessary functions, services, and applications are enabled.

Understanding CMMC Asset CategorizationTheCMMC 2.0 Scoping Guidedefines how assets are categorized based on their involvement withFederal Contract Information (FCI)andControlled Unclassified Information (CUI).

In this scenario:

Thegovernment services divisioninteracts withfederal clientsandreceives FCI, making its assetsin-scopefor CMMC Level 1.

Thecommercial services divisioninteractsonly with non-federal clientsanddoes not handle FCI—this means its assets arenot subject to CMMC Level 1 requirementsand should be classified asOut-of-Scope Assets.

CMMC 2.0 Definition of Out-of-Scope AssetsAs per theCMMC Scoping Guide, assets that:

✅Do not store, process, or transmit FCI/CUI

✅Do not directly impact the security of in-scope assets

✅Are completely segregated from the FCI/CUI environment

are classified asOut-of-Scope Assets.

Since thecommercial services divisiononly processespublicly available information and has no interaction with FCI, its assets areout-of-scopefor CMMC Level 1 assessment.

A. FCI Assets❌Incorrect. FCI assets areonly those that store, process, or transmit FCI. The commercial services division doesnothandle FCI, so its assets donotqualify.

B. Specialized Assets❌Incorrect. Specialized assets refer toInternet of Things (IoT), Operational Technology (OT), and test equipment. These donot applyto a general commercial services division.

D. Operational Technology Assets❌Incorrect.Operational Technology (OT) Assetsinvolveindustrial control systems, SCADA, and manufacturing equipment—which are not relevant to this scenario.

Why the Other Answers Are Incorrect

CMMC 2.0 Scoping Guide – Level 1 & Level 2

CMMC Assessment Process (CAP) Document

CMMC Official ReferencesThus,option C (Out-of-Scope Assets) is the correct answerbased on official CMMC scoping guidance.

Which NIST SP Defines the Assessment Procedures for CMMC?CMMC Level 2 isdirectly based on NIST SP 800-171, and the assessment procedures used in CMMC assessments are derived fromNIST SP 800-171A.

Step-by-Step Breakdown:✅1. NIST SP 800-171A Defines Assessment Procedures

NIST SP 800-171Ais titled"Assessing Security Requirements for Controlled Unclassified Information (CUI)".

It providesdetailed assessment objectives and test proceduresfor evaluating compliance withNIST SP 800-171 security requirements, whichCMMC Level 2 is fully aligned with.

CMMC Assessors use 800-171Aas abaseline for assessing the effectiveness of security controls.

✅2. Why the Other Answer Choices Are Incorrect:

(A) NIST SP 800-53❌

800-53 defines security controlsfor federal information systems, but it doesnot provide assessment procedures specific to CMMC.

(B) NIST SP 800-53A❌

800-53A provides assessment procedures for 800-53 controls, butCMMC is based on NIST SP 800-171, not 800-53.

(C) NIST SP 800-171❌

800-171 defines security requirements, butit does not provide assessment procedures. Theassessment proceduresare in800-171A.

TheCMMC Assessment Guide (Level 2)explicitly states that assessment procedures are derived fromNIST SP 800-171A.

Final Validation from CMMC Documentation:Thus, the correct answer is:

DoDI 5200.48 specifies that Authorized Holders of CUI are responsible for applying appropriate CUI markings. An authorized holder is an individual who has lawful government purpose access to the information. This ensures that responsibility for correctly marking information rests with those who create or handle the material, not only with original classification authorities (which apply to classified information, not CUI).

Reference Documents:

DoDI 5200.48, Controlled Unclassified Information (CUI)

During aCMMC assessment, assessors rely on interviews to validate the implementation of cybersecurity practices within anOrganization Seeking Certification (OSC). Ensuringconfidentiality and non-attributionallows employees to speak freely without fear of retaliation or bias, leading to more accurate and candid responses.

CMMC Assessment Process and the Role of Interviews

TheCMMC Assessment Guide(Level 2) states thatinterviews are a key methodto verify compliance with security controls.

Employees may hesitate to provide truthful information if they fear negative consequences.

To obtain accurate information, assessors must create an environment where team members feel safe.

Ensuring Non-Attribution for Accurate Responses

DoD Assessment Methodologyhighlights thatinterviewees should remain anonymousin reports.

Non-attribution reduces the risk of OSC leadership influencing responses or retaliating against employees.

Employees are more likely to provideaccurateandhonestdescriptions of their responsibilities when confidentiality is guaranteed.

Why the Other Answer Choices Are Incorrect:

(A) Interview groups of people to get collective answers:

Group interviews may limit honest responses due topeer pressure or management presence.

Employees mayhesitate to contradictsupervisors or peers in a group setting.

(B) Understand that testing is more important than interviews:

While testing (e.g., reviewing logs, configurations, and security settings) is crucial, interviews providecontexton how security practices are implemented and followed.

Interviewscomplementtesting rather than being less important.

(D) Let team members know the questions prior to the assessment:

Advanced notice may allow employees toprepare rehearsed answers, which might not reflect actual practices.

This couldreduce the effectivenessof the interview process.

Step-by-Step Breakdown:Final Validation from CMMC Documentation:TheCMMC Assessment Process Guideand DoDAssessment Methodologyemphasize the importance of confidentiality in interviews to ensure accuracy.Non-attribution protects employees and ensures assessors get honest, unfiltered answers.

Thus, the correct answer is:

C. Ensure confidentiality and non-attribution of team members.