RA-7: Risk Response

To meet the ra-7: risk response requirement, you must run a repeatable process that takes findings from assessments, continuous monitoring, and audits, then drives documented decisions and actions (remediate, accept, transfer, or avoid) that align to your organization’s risk tolerance. Your output is evidence: tickets, risk acceptances, POA&Ms, and closure validation. ¹

Key takeaways:

• Convert every finding into a tracked decision and an owned action aligned to risk tolerance. ¹
• Prove closure: remediation plus validation, or formal risk acceptance with approval and expiry. ¹
• Auditors grade RA-7 on throughput and evidence quality, not on how good your policy reads. ²

RA-7 is the control that prevents your risk program from becoming a “report factory.” You can run strong security and privacy assessments, scan continuously, and pass audits, then still fail RA-7 if findings do not reliably turn into decisions, actions, and documented outcomes. The requirement is short, but the operational expectation is not: you need a governance path from finding intake to triage, to disposition, to corrective action, to verification, with escalation and sign-off when risk is accepted.

For a Compliance Officer, CCO, or GRC lead, the fastest way to operationalize RA-7 is to define a single workflow that handles findings from multiple sources (pen tests, internal audits, third-party assessments, privacy reviews, continuous monitoring alerts) and produces consistent artifacts. The process must be calibrated to “organizational risk tolerance,” which means you need an explicit threshold and decision authority model so teams don’t improvise. ¹

This page gives requirement-level implementation guidance: who owns what, what steps to run, what evidence to retain, what auditors ask, and what mistakes repeatedly cause control failures.

Regulatory text

Requirement excerpt: “Respond to findings from security and privacy assessments, monitoring, and audits in accordance with organizational risk tolerance.” ¹

Operator meaning: You must (1) receive findings, (2) decide what to do with each finding using defined risk tolerance, (3) execute the response, and (4) document both the decision and the outcome so it is auditable. A pile of open findings, or undocumented “we’ll fix it later,” is an RA-7 failure even if the finding source process is strong. ¹

Plain-English interpretation (what RA-7 is really testing)

RA-7 tests whether your organization can close the loop on security and privacy issues:

• Input: findings from assessments, monitoring, audits
• Decision: disposition aligned to risk tolerance (fix, accept, transfer, avoid)
• Execution: assigned owner, tracked work, deadlines or review cycles
• Proof: closure evidence and validation, or approved acceptance with conditions ¹

If your program produces findings faster than you resolve them, RA-7 becomes a governance and capacity control. Auditors typically look for a consistent mechanism that prevents “stuck” items and forces explicit risk decisions. ²

Who it applies to

RA-7 applies wherever you use NIST SP 800-53 as your control baseline, especially:

• Federal information systems implementing NIST SP 800-53 controls. ²
• Contractor systems handling federal data, where the contract, ATO path, or customer security requirements call for NIST SP 800-53 alignment. ²

Operationally, RA-7 applies to any environment that generates formal findings:

• Enterprise IT and cloud platforms
• SDLC and product security (appsec findings, code scanning, pen tests)
• Privacy program outputs (PIAs, DPIAs, privacy audits)
• Third-party risk findings (security questionnaires, SOC report gaps) ¹

What you actually need to do (step-by-step)

Use one workflow, even if multiple tools feed it.

1) Define the “finding” intake standard

Create a minimum required data model for any finding:

• Source (audit, monitoring, assessment)
• Affected system/service and data type
• Control mapping (include RA-7 as the response control; optionally map the underlying control that failed)
• Severity/impact statement and likelihood rationale (brief is fine)
• Recommended fix or required corrective action
• Owner candidate (team) and due-date candidate (if your org uses them) ¹

Practical tip: do not accept free-text findings with no owner or system. They will die in backlog.

2) Establish disposition options tied to risk tolerance

Write down the allowed responses and approval thresholds so teams can’t invent new categories:

• Remediate: implement corrective action, then validate.
• Accept: formal risk acceptance; document why within tolerance and for how long.
• Transfer: shift risk via contract/insurance/outsourcing; document residual risk.
• Avoid: stop the activity or decommission the component. ¹

Tie each disposition to authority:

• What a control owner can approve
• What requires CISO/CCO/Authorizing Official approval
• What triggers escalation (high-impact systems, regulated data, repeat findings) ²

3) Triage and prioritize consistently

Run a recurring triage meeting or queue review with security, privacy, and system owners:

• Validate scope and evidence
• Confirm severity and exposure
• Choose disposition
• Assign a single accountable owner (not a shared mailbox)
• Record the planned response and target completion or review cadence ¹

Daydream fit: many teams centralize this in Daydream so findings from audits, scanning, and third parties land in a single workstream with owners, SLAs you define, and evidence attachments.

4) Execute remediation with change control discipline

For remediation items:

• Create implementation tickets (engineering/IT)
• Link code changes, config changes, SOP updates
• Require peer review where applicable
• Update related documentation (procedures, runbooks)
• Track exceptions that block remediation (dependency, business constraint) ²

Your audit story should show that remediation followed normal operational controls, not ad hoc heroics.

5) Run validation before closure

Closure requires proof. Define acceptable validation methods by finding type:

• Re-scan results
• Re-test from assessor or internal security
• Evidence of configuration state (screenshots, exported settings, policy-as-code output)
• Privacy validation (updated notice, updated data mapping, updated DPIA action items closed) ¹

Common hangup: teams “close” tickets when work is done, but never store validation evidence in the GRC record.

6) Manage risk acceptance like a controlled document

If you accept risk, treat it as time-bound and reviewed:

• Statement of risk and impacted assets
• Compensating controls (if any)
• Business rationale tied to risk tolerance
• Approver and date
• Review trigger (time-based review or event-based review like architecture change) ¹

Do not allow indefinite acceptances by default. If you must accept longer-term risk, require periodic reaffirmation by the right authority.

7) Report and govern

Minimum RA-7 governance outputs:

• Aging/open findings list by owner and severity
• Exceptions and risk acceptances register
• Overdue remediation escalation log
• Trend notes for repeat findings (root cause themes) ²

Keep reporting tight. The point is decisions and action, not dashboards.

Required evidence and artifacts to retain

Auditors typically want to sample findings end-to-end. Retain:

• Findings register (central inventory) with unique IDs and status history ¹
• Triage records: meeting notes or workflow logs showing disposition decisions ¹
• Remediation tickets linked to findings (Jira/ServiceNow/etc.) ²
• Validation evidence: re-test results, scan outputs, configuration exports ¹
• Risk acceptance memos with approver, rationale, and review trigger ¹
• Audit/assessment reports that generated the findings and your response crosswalk ²

If you want RA-7 to be easy at exam time, map RA-7 to a named control owner, a written procedure, and recurring evidence artifacts in your GRC system. ¹

Common exam/audit questions and hangups

Expect questions like:

• “Show me a finding from monitoring and walk me from detection to closure.” ²
• “How do you decide when to accept risk, and who can approve it?” ¹
• “How do you ensure privacy findings are treated with the same rigor as security findings?” ¹
• “How do you prevent old findings from staying open indefinitely?” ²

Hangups that cause failed samples:

• No validation evidence attached
• Disposition recorded as “mitigated” with no explanation
• Risk acceptance exists but lacks approver authority or review trigger
• Finding ownership points to a departed employee or generic team ¹

Frequent implementation mistakes (and how to avoid them)

1. Separating “audit findings” from “security findings.”
   Fix: one common intake and response workflow with source tags. ¹

2. Treating risk acceptance as informal email.
   Fix: standard template, required fields, approval routing, and review trigger. Store it with the finding record. ¹

3. Closing tickets without proof.
   Fix: define closure criteria by finding type; make validation evidence mandatory in the record before closure. ²

4. No explicit tie to risk tolerance.
   Fix: document risk tolerance statements and embed them in disposition rules and escalation paths. ¹

5. Backlog becomes normal.
   Fix: governance escalation for overdue high-risk items, plus capacity planning and root cause tracking for repeats. ²

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific enforcement outcomes.

Operational risk is still straightforward: weak RA-7 means known issues persist without decision records, which increases the chance that incidents, privacy complaints, or customer assurance failures become “we knew and didn’t act” narratives. RA-7 exists to prevent that failure mode by forcing accountable decisions and traceable action. ¹

A practical 30/60/90-day execution plan

First 30 days (stand up the mechanism)

• Name an RA-7 control owner and backups; publish responsibility boundaries. ²
• Define the finding data model and required fields; configure in your ticketing/GRC tooling.
• Standardize disposition categories and approval thresholds tied to risk tolerance. ¹
• Create a risk acceptance template and routing.
• Pick a single “system of record” (often Daydream plus links to engineering tickets) for evidence and status.

Days 31–60 (make it run)

• Import active findings from audits, scans, and assessments into the register.
• Run recurring triage; assign owners; set response plans.
• Pilot validation evidence requirements on a subset of systems.
• Start an exceptions/risk acceptance register and require review triggers. ¹

Days 61–90 (make it auditable and durable)

• Perform an internal sample-based review: select closed items and confirm evidence completeness.
• Add escalation rules for overdue or high-impact items; document the escalation path. ²
• Build a lightweight RA-7 metrics pack for leadership: aging, closures, acceptances, repeats.
• Train control owners and system owners on what “closure” means under your RA-7 procedure.

Frequently Asked Questions

Does RA-7 require me to remediate every finding?

No. It requires you to respond in accordance with risk tolerance, which can include remediation, acceptance, transfer, or avoidance, as long as the decision and outcome are documented. ¹

What counts as “monitoring” findings for RA-7?

Treat any recurring security or privacy signal that generates actionable issues as monitoring output, then route it through the same disposition and tracking workflow. The key is a documented response tied to risk tolerance. ¹

How formal does risk acceptance need to be?

Formal enough that an auditor can see the risk statement, business rationale, approver authority, and a review trigger or revisit point. Store it with the finding record, not in inbox threads. ¹

We have multiple tools (SIEM, scanner, audit platform). Do we need to consolidate?

You do not need one tool, but you need one system of record for status, decisions, and evidence so sampling is possible. Many teams centralize this in Daydream and link out to source tools and tickets. ²

What evidence is most often missing in RA-7 audits?

Closure validation. Teams show a ticket marked “done” but cannot show re-test results, re-scan output, or configuration state proving the control gap is resolved. ¹

How do we apply RA-7 to third-party findings (SOC gaps, questionnaires)?

Log them as findings with a disposition and owner. Remediation may be a contract change, compensating control, or supplier corrective action plan; acceptance should follow the same approval and review rules. ¹

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5