Understanding CMMC Asset Categorization

TheCMMC 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 Assets

As 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.

Why the Other Answers Are Incorrect

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.

CMMC Official References

CMMC 2.0 Scoping Guide – Level 1 & Level 2

CMMC Assessment Process (CAP) Document

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