ISC2 Governance, Risk and Compliance (CGRC) Practice Question
You are the system owner of a U.S. federal moderate-impact information system that will go live with one low-impact security control missing. The deficiency is documented in the POA&M with a 90-day remediation milestone, and the Authorizing Official (AO) has determined the residual risk is within the agency's tolerance. Before the AO can sign the Authorization to Operate, which action is explicitly required by the NIST Risk Management Framework?
Re-categorize the system from moderate to low impact so the control is no longer required
Include the control deficiency and its 90-day remediation plan in the system's approved Plan of Action and Milestones (POA&M)
Obtain signed residual-risk acceptance letters from the system owner and mission/business process owners
Deploy an immediate compensating technical safeguard that fully mitigates the missing control
Under NIST SP 800-37 Rev. 2, the AO is the single official who determines whether the system's residual risk is acceptable and documents that decision in the authorization decision document (e.g., an ATO). As long as the weakness is recorded in the POA&M with an approved remediation plan and schedule, the RMF does not mandate additional signatures or compensating controls. Downgrading a system's impact level to avoid a required control would violate the RMF categorization process. Therefore, the only RMF-mandated step before issuing the ATO is to ensure the weakness and its remediation plan are documented in the POA&M that accompanies the authorization package.
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What is the NIST Risk Management Framework (RMF)?
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What is a Plan of Action and Milestones (POA&M)?
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What role does the Authorizing Official (AO) play in the RMF process?
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ISC2 Governance, Risk and Compliance (CGRC)
System Compliance
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